United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC
EPA 455/R-92-001
September 1991
Stationary Source Compliance Series
EPA COMPLIANCE INSPECTION AND
ASSISTANCE DOCUMENT:
PRIMARY AND SECONDARY LEAD
SMELTERS AND LEAD-ACID
BATTERY PLANTS
-------
EPA 455/R-92-001
COMPLIANCE INSPECTION AND ASSISTANCE DOCUMENT:
PRIMARY AND SECONDARY LEAD SMELTERS AND
LEAD-ACID BATTERY PLANTS
by
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Gary, North Carolina 27K13
Contract No. 68-02-4463
Work Assignment No. 91-47
EPA Work Assignment Manager: Laxmi Kesari
EPA Project Officer: Aaron Martin
US. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, DC 20460
September 1992
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OPERATION AND MAINTENANCE PRACTICES AND GUIDANCE PRODUCTION
FOR PRIMARY, SECONDARY LEAD SMELTERS
AND LEAD-ACID BATTERY PLANTS
FINAL REPORT
U. S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
STATIONARY SOURCE COMPLIANCE DIVISION
EN-341
401 M STREET SW
WASHINGTON, D.C.
PROJECT OFFICER: LAXMI KASARI
EPA CONTRACT NO. 68-02-4463
WORK ASSIGNMENT NO. 47
SEPTEMBER 1992
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ACKNOWLEDGEMENT
This report was prepared for the Office of Air Quality
Planning and Standards (OAQPS), Stationary Source Compliance
Division (SSCD), under EPA Contract No. 68-02-4463, Work
Assignment No. 47. The EPA Project Officer was Mr. Laxmi Kasari.
The report was prepared by Midwest Research Institute. Principal
authors were Mr. William T. "Jerry" Winberry, Mr. John Butler,
Mr. David Bullock and Mr. Dennis Wallace. Mr. Winberry served as
Project Leader for the work assignment.
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PREFACE
The 1977 amendments to the Clean Air Act of 1970 added lead
to the list of criteria pollutants and established the primary
and secondary NAAQS for lead as 1.5 micrograms per cubic meter
(/ig/m3) averaged over a calendar quarter. On July 1, 1987, EPA
promulgated a PM-10 specifies a 24-hour primary and secondary
standard of 150 Mg/m3 and an annual primary and secondary
standard of 50 M9/n3 (calculated as an annual arithmetic mean).
The lead standard still remained, now determined from the PM-10
filter. To attain and subsequently maintain the NAAQS for PM-10,
each State is required to adopt and submit to EPA a plan (State
Implementation Plan) providing for the implementation,
maintenance, and enforcement of the standards over the entire
State. Each SIP includes a major portion devoted to emission
limitations and other regulations and programs to prohibit
stationary sources from "emitting any air pollutant (point or
fugitive) in amounts which will prevent attainment with the NAAQS
or interface with measures to prevent significant deterioration
of air quality.1* Thus, each State directs its control
regulations towards its unique set of sources and circumstances
as long as the end result will be attainment of the NAAQS within
the required time frame.
A principal feature of the nonattainment provisions enacted
in the Clean Air Act Amendments of 1977 was strengthening the
permit program by requiring existing sources to install
reasonably'available control technology (RACT) in an effort to
minimize emissions to maintain the NAAQS. That requirement is
generally applicable to "major sources," i.e., those with
potential to emit 100 tons per year (tons/yr) or more. The four
source categories with significant nationwide emissions of lead
are secondary lead smelters, gray iron foundries, primary lead
smelters, and lead-acid storage battery manufacturers. In order
to attain the NAAQS, further reduction in lead emissions must be
obtained from both their point and fugitive source emissions
within these facilities. To date, point source lead emissions
ii
-------
have been controlled through new source performance standards
(NSPS); however, fugitive lead emissions can greatly exceed point
source emissions, thus further lead emission reductions are tied
to the control of fugitive emissions, coupled with continued
control of point emissions, through a strong permitting program.
To that end, the Clean Air Act Amendment of 1990 added an
entirely new permitting program. The 1990 Amendments
incorporates the RACT requirements of 1977 and best available
control technology (BACT) standards through source emission
control programs.
On May 10, 1991, EPA published proposed rules implementing
these new permit requirements, including RACT permits. This
Technical Assistance Document is not intended to provide guidance
directly associated with this rulemaking activity. Nevertheless,
it was prepared as a tool for use by State and local agencies in
developing and implementing continuous compliance monitoring
requirements and oversight programs as the RACT permit program is
carried out.
The objective of this Technical Assistance Document (TAD) is
to provide guidance to State/local permit writers on
implementation of a source emission minimization program (SEMP)
as part of the Agency RACT/BACT permit program, involving
operation and maintenance (O&M) procedures for point and fugitive
emission control, "baselining" source emissions, and proper
recordkeeping and reporting practices. The development of an
SEMP ensures continued compliance of lead emission standards
after initial compliance as part of the Agency's continuous
compliance program.
Specifically, the TAD identifies permit requirements for
proper O&M procedures for both process and fugitive control
systems and defines operating parameters of control equipment and
programs such as vehicular usage on paved/unpaved roads, pH for
scru&ber systems, pressure drop for baghouses, and visual
observations for opacity for area sources as indicators of proper
plant O&M practices. Where applicable, "baseline" technology is
incorporated into the TAD to define specific relationships
iii
-------
between initial facility control program performance operating in
compliance with continued emission levels. Incorporating these
requirements in future RACT/BACT permit regulations will enable
the Agency to detect shifts in source emission control programs
and control equipment operating parameters as early signs of
their performance deterioration as part of the Agency "continuous
compliance" strategy in maintaining the lead NAAQS.
iv
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 SOURCES AND AMBIENT CONCENTRATIONS OF LEAD . . 1-1
1.2 REGULATORY MANDATE FOR STRENGTHENING SOURCE
PERMIT . . . * 1-7
2.0 LEAD EMISSION SOURCES 2-1
2.1 INTRODUCTION 2-1
2.2 INDUSTRY PROCESS DESCRIPTION AND POINT
SOURCE EMISSIONS SPECIFIC POINT 2-1
2.2.1 Primary Lead Smelting . . 2-1
2.2.2 Secondary Lead Smelting 2-6
2.2.3 Lead-Acid Battery Manufacturing .... 2-9
2.3 OPEN DUST FUGITIVE EMISSIONS 2-11
2.3.1 Industrial Paved Roads 2-11
2.3.2 Unpaved Roads 2-12
2.3.3 Storage Piles 2-12
2.4 PROCESS FUGITIVE EMISSIONS . 2-14
2.4.1 Solid Materials Handling Operations . . 2-14
2.4.2 Materials Processing Operations .... 2-15
2.4.3 Furnaces 2-16
2.4.4 Hot Metal Transfer and Processing . . . 2-17
2.4.5 Metal Casting 2-17
3.0 LEAD EMISSION CONTROLS 3-1
3.1 INTRODUCTION 3-1
3.2 INDUSTRY SPECIFIC CONTROLS FOR POINT SOURCES
AND PROCESS 3-1
3.2.1 Baghousea 3-1
3.2.2 Venturi Scrubbers (Low/High Energy) . . 3-4
3.2.3 Cyclones/multicyclones 3-7
\
•» •» r-ENERAL OPEN DUST FUGITIVE CONTROL 3-9
3.3.1 Introduction 3-9
3.3.2 Paved Roads 3-10
3.3.3 Unpaved Roads 3-14
3.3.4 Storage Pile 3-16
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TABLE OF CONTENTS (continued)
Page
3.4 INDUSTRY SPECIFIC PROCESS FUGITIVE EMISSIONS . 3-19
4.0 RECOMMENDED OPERATION/MAINTENANCE AND RECORDKEEPING
PRACTICES FOR LEAD EMISSION CONTROL 4-1
4.1 INTRODUCTION 4-1
4.2 SPECIFIC CONTROL DEVICES 4-2
4.3 PROCESS FUGITIVE EMISSIONS 4-2
4.4 OPEN DUST FUGITIVE EMISSIONS 4-7
5.0 INDUSTRY CONTINUOUS COMPLIANCE PROGRAM 5-1
5.1 INTRODUCTION 5-1
5.2 SOURCE MANAGEMENT PLAN 5-2
5.3 SOURCE RECORDKEEPING PLAN 5-7
5.3.1 Equipment Record 5-7
5.3.2 Inspection Checklist 5-8
5.3.3 Baseline Logbook 5-10
5.3.4 Control Monitor Logbook 5-13
5.3.5. Equipment Maintenance/Work Order . . 5-13
5.4 SOURCE MEASUREMENT PLAN 5-17
5.4.1 Levels of Inspection 5-18
5.4.2 Activity Associated with Levels of
Inspection 5-20
6.0 AGENCY CONTINUOUS COMPLIANCE PROGRAM 6-1
iSK. -..,.-
6.1 INTRODUCTION 6-1
6.2 PHASED APPROACH TO CONTINUOUS COMPLIANCE
IMPLEMENTATION AND OVERSIGHT 6-2
6.3 INCLUSION OF PLANT SPECIFIC OPERATION AND
MAINTENANCE AND RECORDKEEPING PRACTICES IN
A SOURCE PERMIT 6-4
6.3^1 Identification Of All Process and
Fugitive Sources Regulated Under
The Permit 6-5
6.3.2 Emission Standards to be Met for Each
Source 6-8
6.3.3 Compliance Monitoring Requirements for
Each Source 6-9
6.3.4 Recordkeeping and Reporting
Requirements for Each Source .... 6-12
vi
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TABLE OF CONTENTS (continued)
Page
6.3.5 Operation and Maintenance Requirements
for Each Source 6-13
6.3.6 Requirement for Submittal of a
Source Emission Minimization Program
(SEMP) 6-14
6.4 PARAMETER MONITORING PERMIT CONDITIONS .... 6-26
6.4.1 Fabric Filters 6-27
6.4.2 Venturi Scrubbers 6-30
6.4.3 Control Equipment/Parameter Monitoring
Permit Review Checklist 6-33
6.5 PERMIT FOLLOWUP AND RENEWAL 6-33
6.5.1 Introduction 6-33
6.5.2 Role of the Agency Inspection in the
Permit Process . 6-36
6.5.3 Permit Followup Inspection Tools .... 6-38
6.5.4 Onsite Inspection to Verify Permit
Conditions 6-43
6.5.5 Summary 6-44
7.0 LEAD EMISSION CONTROL INSPECTION EVALUATION
CHECKLIST 7-1
7.1 INTRODUCTION 7-1
7.2 LEVELS OF INSPECTION 7-1
7.3 CHECKLIST FOR EVALUATING SPECIFIC CONTROL
DEVICES 7-4
APPENDICES
A. Bibliography A-l
B. Federal Reference Method 9 B-l
c. Federal Reference Method 22 c-l
vii
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LIST OF TABLES
TABLE 1-1.
TABLE 1-2.
TABLE 1-3.
TABLE 1-4.
TABLE 1-5.
TABLE 3-1.
TABLE 3-2.
TABLE 3-3.
TABLE 3-4.
TABLE 4-1.
TABLE 4-2.
TABLE 4-3.
TABLE 4-4.
TABLE 4-5._
TABLE 4-6.
TABLE 5-1.
TABLE 5-2.
TABLE 5-3.
PRIMARY LEAD SMELTING FACILITIES
SECONDARY LEAD SMELTING FACILITIES ....
LEAD-ACID BATTERY MANUFACTURING FACILITIES
NUMBER AND PERCENTAGE OF PRIMARY, SECONDARY
AND LEAD-ACID BATTERY MANUFACTURING
FACILITIES IN EPA REGIONS
NEW SOURCE PERFORMANCE STANDARDS (NSPS) . .
NONINDUSTRIAL PAVED ROAD DUST SOURCES AND
PREVENTIVE CONTROLS
MEASURED EFFICIENCY VALUES FOR PAVED ROAD
CONTROLS
CONTROL TECHNIQUES FOR UNPAVED TRAVEL
SURFACES
CONTROL TECHNIQUES FOR STORAGE PILES . . ,
TYPICAL MAINTENANCE SCHEDULE FOR A FABRIC
FILTER SYSTEM ,
TYPICAL MAINTENANCE SCHEDULE FOR A VENTURI
SCRUBBER SYSTEM .
TYPICAL MAINTENANCE SCHEDULE FOR A
CYCLONE/MULTICYCLONE SYSTEM . . . .
RANGE OF CAPTURE VELOCITIES
SOURCE EMISSION MINIMIZATION MAINTENANCE
TIMETABLE FOR VENTILATION SYSTEMS . . . ,
SOURCE EMISSION MINIMIZATION MAINTENANCE
TIMETABLE FOR OPEN DUST FUGITIVE EMISSIONS
MANAGEMENT PLAN PROGRAM PARTICIPANTS AND
RESPONSIBILITIES
RESPONSIBILITIES OF TIER I, II, III IN A
SOURCE MANAGEMENT PROGRAM
CONTROL MONITOR LOGBOOK
Page
1-2
1-3
1-4
1-5
1-10
3-12
3-13
3-15
3-17
4-3
4-4
4-5
4-8
4-9
4-11
5-3
5-S
5-14
viii
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LIST OF TABLES (continued)
TABLE 5-4. PROBLEM COMMUNICATION MEMO
TABLE 5-5. ACTIVITIES ASSOCIATED WITH LEVELS OF
INSPECTION
TABLE 6-1. POTENTIAL EMISSION SOURCES AT PRIMARY LEAD
SMELTERS AND THEIR CONTROL PROGRAMS . . . .
TABLE 6-2. POTENTIAL EMISSION SOURCES AT SECONDARY
LEAD SMELTERS AND THEIR CONTROL PROGRAMS ,
TABLE 6-3. SOURCE PERMIT REVIEW CHECKLIST
PAGE
5-15
5-22
6-6
6-7
6-34
ix
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LIST OF FIGURES
Page
Figure 1-1. National trends in lead emissions 1-6
Figure 1-2. National trend in the composite average of
the maximum quarterly average lead
concentration at 118 sites with 95 percent
confidence intervals, 1978-1987 1-8
Figure 2-1. Fugitive emission sources 2-2
Figure 2-2. Typical primary lead processing scheme . . . 2-3
Figure 2-3. Sintering process 2-4
Figure 2-4. Typical secondary lead smelting and
refining scheme • 2-7
Figure 2-5. Process flow diagram for storage battery
production 2-10
Figure 3-1. Typical baghouse configuration 3-3
Figure 3-2. Venturi scrubber system 3-6
Figure 3-3. Typical components of a cyclone 3-8
Figure 3-4. Process diagram for primary lead smelting
shoving emission points 3-11
Figure 3-5. Enclosed hood for lead-tapping system ... 3-21
Figure 3-6. Rotary furnace changing and tapping hood
controls , 3-22
Figure 3-7. Overview of modified local exhaust
ventilation system .... 3-23
Figure 3-8. Swing design finishing metal ladle cooling
hood 3-25
Figure 5-1. Baseline data for unit No. 1 of baghouse . . 5-11
Figure 5-2. Baseline data within control limits .... 5-12
Source equipment maintenance and work
order 5-16
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1.0 INTRODUCTION
1.1 SOURCES AND CONCENTRATION
Lead and its compounds enter the atmosphere from industrial
activities and combustion of fuels, especially leaded gasoline.
Lead emission sources can be categorized into three groups:
1. Combustion sources, which emit lead by volatilization of
fuels and refuse;
2. Metallurgical sources through volatilization or
mechanical action from smelting and processing of metallic ores
and materials; and
3. Manufacturing sources to produce a lead containing
product.
By far, the major sources of lead emissions have been
associated with production of lead ackyl and storage batteries
and primary and secondary lead smelting operations. Tables 1-1,
1-2, and 1-3 document the locations of primary, secondary and
lead-acid battery manufacturing facilities in the United States,
respectively. Table 1-4 documents the location of the facilities
with EPA regions.
Whether the lead emissions are volatiles or particles
depends upon their origin and mechanism of formation. Smelting
operations usually provide submicron particles, while material
handling and mechanical attrition, as in battery manufacturing,
consist of larger dust particles. The main chemical forms of
lead emission include elemental lead (Pb), oxide of lead (PbO,
Pb02, PBjOj, etc.), lead sulfates and sulfides (PbSO4, PbS) alkyl
lead [Pb(CH3)4, Pb(C2H5)4], and lead halides. Some or all of
these forms of lead emissions occur at primary, secondary and
lead-acid battery manufacturing facilities.
Recent EPA data has shown a substantial decrease in lead
emissions, from both point source and transportation, as recorded
in Figure 1-1. A major drop in lead emissions occurred between
1978 and 1981, as the effects of increased use of unleaded
gasoline in catalyst-equipped cars and the reduction of lead
content in leaded gasoline was observed. From 1983 to 1987,
1-1
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TABLE 1-1. PRIMARY LEAD SMELTING FACILITIES
Facility
St . Joe
AMAX - Homestake
ASARCO
Location
Herculaneum,
MO
Boss, MO
East Helena,
Glover, MO
Omaha , NE
MT
1-2
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TABLE 1-2. SECONDARY LEAD SMELTING FACILITIES
Facility
Location
Region II
RSR
Roth Brothers
Middletown, NY
Syracuse, NY
Region III
East Perm
Exide (General Battery)
Master Metals
Lyons Station, PA
Reading, PA
Cleveland, OH
Region IV
Chloride Metals
General Smelting and Refining
Interstate Lead Co. (ILCo)
Pacific Chloride Metals
Refined Metals
Ross Metals
Sanders Lead
Schuylkill Metals
Tampa, PL
College Grove, TN
Leeds, AL
Columbus, GA
Rossville, TN
Rossville, TN
Troy, AL
Baton Rouge, LA
Region V
Gopher
RSR-QuemetCO
Eagan, MN
Indianapolis, IN
Region VI
Exide (Dixie Metals)
GNB
RSR
Dallas, TX
Frisco, TX
Dallas, TX
Region VII
Schuvlkill Metals
Mound City, MD
Region IX
Alco Pacific
GNB
RSR-Quemetco
Gardena, CA
Los Angeles, CA
City of Industry, CA
1-3
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TABLE 1-3. LEAD-ACID BATTERY MANUFACTURING FACILITIES
Facility
Battery Builders, Incorporated
C&D Power Systems,
Incorporated
Douglas Battery Manufacturing
Company
East Perm Manufacturing
Company
Exide Corporation
Gates Energy Products,
Incorporated
GNB Incorporated
Johnson Controls, Incorporated
Trojan Battery Company
U. S. Battery
Manufacturing Company
West Kentucky Battery
Incorporated
Location
Naperville, IL
Conyers , GA
Hugeunot , NY
Leola, PA
Wins ton -Sal em, NC
Lyon Station, PA
City of Industry, CA
Visalia, CA
Logansport , IN
Burlington, IA
Manchester, IA
Salina, KS
Al lent own, PA
Muhlenberg/Laureldable, PA
Greer, SC
Sumter, SC
Warrensburg, MO
Fort Smith, AR
Columbus , GA
Middletown, DE
Tampa, FL
St. Joseph, MO
Winston- Salem, NC
Holland, OH
Milwaukee, WI
Santa Fe Springs, CA
Lithonia, GA
Evans, GA
Bent oh, KY
1-4
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TABLE 1-4. NUMBER AND PERCENTAGE OF PRIMARY, SECONDARY AND LEAD-
ACID BATTERY MANUFACTURING FACILITIES IN EPA REGIONS
EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Process
Primary lead
smelters,
#
4
1
5
%
80
20
Secondary lead
smelters,
#
2
2
7
4
4
1
3
23
%
8.7
8.7
30.4
17.4
17.4
4.3
13.0
Lead- acid
battery,
#
1
8
10
3
1
5
3
31
%
3.2
25.8
32.2
9.7
3.2
16.1
9.7
1-5
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200
LEAD EMISSIONS, 10* METRIC TONS/YEAR
150-
SOURCE CATEGORY
B MOUSTmAL PROCESSES
• SOLJO WASTE
ana.
COMMOTION
100-1
1978 19791980 1981 1982 1983 1984 1985 1986 1987
Figure 1-1. National trend in lead emissions, 1978-1987,
1-6
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there was a 71 percent decrease of total lead emissions during
this 5-year period. As expected, ambient concentrations of lead
decreased during this same time period, as illustrated in
Figure 1-2. For example, during the period 1980 to 1986, the
maximum quarterly averages for ambient lead for all monitoring
stations dropped from 0.91 to 0.26 Mg/m3, and annual averages for
ambient lead concentrations fell from 0.64 to 0.17 pg/m3. Much
of this reduction was due to the decrease in the use of leaded
gasolines. To achieve further reductions in lead emissions,
other sources must be targeted.
Although total nationwide lead emissions have been reduced,
exceedances of the lead NAAQS often occur. In 1989, 18 of
530 lead monitors included in the Aerometric Information
Retrieval System (AIRS) data base recorded at least one
exceedance of the 1.5 Mg/m3 standard. However, this fraction of
exceedances is likely to be an underestimation of the magnitude
of the problem. Many of the major lead-emitting industries do
not have fenceline monitors to record NAAQS exceedances. For
example, of the 26 operating primary and secondary lead smelters,
only 12 have fenceline monitors for which data are recorded in
the AIRS database. Of these 12 lead smelters, 11 reported at
least one exceedance during the period 1987 to 1989.
In order to attain the lead NAAQS at the fencelines of a
number of facilities, further emission reductions may be possibly
only through the control of fugitive emissions with continued
control of source emissions. Furthermore, because fugitive
emissions "are typically emitted closer to ground level than stack
emissions, fugitives can have a much greater impact on ambient
concentrations at the fenceline. In many cases, however, the
magnitude of fugitive emissions is unknown.
1.2 REGULATORY MANDATE FOR STRENGTHENING SOURCE PERMIT
The Clean Air Act Amendments of 1977 specified lead as a
criteria pollutant, for which a primary and secondary NAAQS was
established at 1.5 micrograms per cubic meter (jug/m3) averaged
over a calendar quarter at the industry fenceline. During that
regulatory period, major lead emissions were from automobiles
1-7
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2.2
2
1.8
1.6
t.4
1.2
1
0.8
0.6
0.4
0.2
0
CONCENTRATION,
NAAQS
o ALLJCTES{97}
1978 1979 1980 1981 1982 1983 1984 1985 1986 1987
Figure 1-2. National trend in the composite average of the
maximum quarterly average lead concentration at 118 sites
with 95 percent confidence intervals, 1978-1987.
1-3
-------
using leaded gasoline and point sources. However, a review of
the AIRS data base indicates that the automobile is no longer the
primary source of lead in the urban air. Major lead-emitting
industries, involving both point and fugitive sources, have
recorded exceedances of the NAAQS at the fenceline within the
last 3 years.
A principal feature of the nonattainment provisions enacted
in the Amendments of 1977 was a requirement that existing sources
must install reasonably available control technology (RACT) in an
effort to minimize emissions to maintain the NAAQS. That
requirement is generally applicable to "major sources," i.e.,
those with potential to emit 100 tons per year (tons/yr) or more.
The four source categories with significant nationwide emissions
of lead are secondary lead smelters, gray iron foundries, primary
lead smelters, and lead-acid storage battery manufacturers. As
part of the Amendments of 1977, EPA controlled point sources
emissions from secondary, primary and lead-acid battery
manufacturing facilities through NSPS, as outlined in Table 1-5.
While lead was not specified as a part of the regulations, it was
believed that controlling mass emissions would reduce lead
emissions.
Historically, control of lead emissions from point sources
have been achieved through the use of high-efficiency fine
particulate controls such as electrostatic precipitators (ESP's),
fabric filters, and wet scrubbers. Few processes incorporate
control devices specifically for lead control, but to comply with
State or Federal particulate emission limits. For fugitive
emissions control, the Agency has required source specific
fugitive emission control program involving vacuuming, watering
and surface improvements, enclosures of storage piles, and
ventilation engineering, to name only a few control options.
Another objective of the 1977 Amendments to the CAA was to
improve air quality standards through "best available control
technology (BACT)" and "lowest achievable emission rates (LAER)."
A major purpose of these amendments was to provide additional and
stronger thrust in the direction of the prevention of significant
1-9
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TABLE 1-5. NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Subpart
L
R
KK
Source category
Secc ndary lead
sme-(ers
Pot furnace
Primary lead
smelters
manufacturing plants
Year of
promulgation
1974
1
i
1976
19*2
Affected unit
Blast or recovery furnace
Pot furnace
Blast/dross furnace or
sintering machine
Sintering machine, electric
smeking furnace or
converter gases
Grid cast inc
Pasternak inff
Three processes
Lead oxide manufacturing
Lead reclaiming
Other
-
Pollutant
Particulate matter
Opacity
Opacity
Particulate matter
Opaeky
Sulfur dioxide
Opaeky
Qatet containing lead
Opaeky
Opaeky
Gases containing lead
Opaeky
Gam <«n»«tninf (cad
Opaeky
GIMS conUiintnc Inui
Opaeky
Emission units
50 mg/dscm (0.022 gr/dscf)
20%
10%
50 mg/dscm (0 022 gr dscf)
20%
0.065% by volume
0 4O me/dicm (O 000176
gr/dsef)
0%
1.00 mg/dscm (0 00044 gr
dscf)
0%
1 00 mg/dscm (0 00044 gr
dscf)
0%
5.00 mg/kg lead feed (0.010 •>
ton)
0%
4 50 mg/dscm (0 00198
gr/dscf)
5%
1 00 mg/dscm (0 00044
gr/dscf)
0%
Compliance federal
reference methods (RM)
RMS
RM9
RM9
RM 5
RM9
Continuous emission
monitor (CEM)
RM 11
RM9
RM 12
RM9
RM 12
RM9
RM 12
RM9
RM 12
RM9
RM 12
RM9
I
H
O
-------
deterioration (PSD) for area which had attained the standards,
and to improve the air quality in nohattairunent areas where the
pollutant concentrations exceeded the standards. There was a
general shift from implementation to planning. Under the prior
legislation the major emphasis was on controlling obvious and
major sources of air pollution. The newer philosophy was that a
broader attack on the problem was needed. More importantly,
change were introduced into the SIP procedures, and all SIP's
require revision to accommodate these changes. For example, an
acceptable SIP must now include a permit program for enforcement
of the new PSD and nonattainment provisions, now part of the Act
itself rather than part of the regulatory framework.
As part of the 1977 CAA Amendments, the Federal government
was given the added responsibility of reviewing all permits for
major sources constructing in PSD and nonattainment areas.
Federal review applied to:
1. The PSD areas for any source have a potential emission
greater than 250 tons per year or 100 tons per year for
28 specified sources; and
2. Nonattainment areas for any source which has a greater
potential emission than 100 tons/yr.
The permit, therefore, became an integral part of an Agency
enforcement program. It provided the vehicle by which Agency
emission control objectives were implemented and enforced. The
permit provided:
1. Engineering review prior to construction so any
necessary changes in emission control systems could be
incorporated;
2. Notification if proposed facility could not comply with
emission limitations, then agency could prevent construction;
3. Mechanism for requiring implementation of a source
emission minimization program (SEMP) to insure continued
p^rfcrz^r.ca of emission control (point and fugitive) program;
4. Deny operating permit if source does not meet compliance
limitations;
5. A format for notification of source modification; and
1-11
-------
6. Provided a "document" in which all conditions/
specifications to operate under a emission reduction program are
stated.
The Clean Air Act Amendments of 1990 further strengthened
the permit system by incorporating the RACT requirements of 1977
and implementation of BACT standards through emission control
programs for both point and fugitive sources.
1-12
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2.0 LEAD EMISSION SOURCES
2.1 INTRODUCTION
Lead emission sources can be divided into two broad
categories—process (point/equipment) fugitive emission sources
and nonprocess, or open, fugitive dust emission sources, as
illustrated in Figure 2-1. Process fugitive emissions sources
include emissions from mechanical and metallurgical operations
that alter the physical or chemical characteristics of the feed
materials. Open fugitive dust emission sources relate to the
transfer, storage, and handling of materials and include those
sources from which particles are entrained by the forces of wind
or machinery acting on exposed materials. Following is a general
discussion of the various types of fugitive emission sources at
lead manufacturing facilities.
2.2 INDUSTRY SPECIFIC POINT EMISSION SOURCES
2.2.1 Primary Lead Smelting
Lead is usually found naturally as a sulfide ore (Galena-
PBS) containing small amounts of copper, iron, zinc and other
trace elements. At the mine, the naturally occurring Galena
containing 3 to 8 percent lead is concentrated to 55 to
70 percent lead, also containing 13 to 19 percent by weight of
free and uncombined sulfur. The main objective of the primary
lead smelting process is to separate the lead from its impurities
to produce lead pigs and ingots. The smelting process involves
four distinct operations, as outlined in Figure 2-2. They are:
sintering, reduction, dressing, and refining. Point source
emissions are associated with each phase of the primary lead
smelting process, as indicated in Figure 2-2.
The primary purpose of the-sintering process is to prepare
the lead ore for the reduction process in the blast furnace. In
the sintering process the ore is roasted (see Figure 2-3) to
remove the sulfur and form a strong porous mass (clinker) that is
suitable for the blast furnace smelting. Chemically, the lead
sulfide is converted to lead oxide and sulfur oxide.
Additionally, sintering converts metallic sulfides to oxides,
2-1
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Fugitive Emission Sources
Open
Dust
i
to
Industrial
Paved
Roads
Process
Sources
Unpaved
Roads
Storage
Piles
Metal
Casting
Solid
Materials
Handling
Materials
Processing
Furnaces
Hot
Metal
Transfer
Figure 2-1. Fugitive emission sources.
-------
Simtrtng
faction »l« Drotttng •+• tottnlng
Figure 2-2. Typical primary lead processing scheme,
-------
STRONG GAS
TO DEDUCTING
IGNITION
FURNACE
RECIRCULATING STREAM
FRESH AW FRESH AH
SINTER-
Figure 2-3. Sintering process,
2-4
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removing contaminants such as arsenic and antimony. In
operation, the lead ore concentrate, recycled sinter and smelting
residues are combined with adequate sulfide-free flukes to
maintain a sulfur content of 5 to 7 percent by weight. The
charged materials are fed in controlled amounts onto a common
belt conveyor where they are crushed, moistened and pelletized.
These materials are then split into an ignition portion
(10 percent of total) and a main feed portion (the remaining
90 percent) and fed into the sinter machine. As the feed
material moves through the machine, it burns, fuses and cools
before dropping off as a cake at the discharge end of the
machine. The sinter then drops through a grating and is crushed
and screened. The large fraction is conveyed to bins prior to
the reduction process.
In the reduction process, the blast furnace reduces the lead
oxide to metallic lead utilizing high pressure combustion air,
introduced near the bottom of the water-jacketed shaft furnace.
The charge to the blast furnace consists of coke (8 to 14 percent
of the charge), sinter (80 to 90 percent of the charge), and
other materials such as limestone, silica and recycled materials
to maintain the temperature below 1400°F in preventing
volatilization of the metals. The charge is introduced to the
top of the furnace by means of either conveyors or dumping from
charge cars. During the melting process, the charge may separate
into as many as four layers in the blast furnace. From lightest
to heaviest, the layers are: slag, speiss, matte and lead metal.
Impurities are partitioned between the matte (copper sulfide and
other metal sulfides), speiss (arsenic and antimony), and the
slag (silicatejs). The slag is removed periodically and conveyed
hot to a fuming furnace for recovery of lead and zinc. Some slag
may be granulated and recycled to sintering. The lead bullion
(heaviest) is tapped and goes to the refining process. The matte
and speiss go to the dross furnace for further lead recovery.
The tapped lead bullion is transferred by overhead crane in
a 10- to 20-Mg ladle to the dressing process, where the molten
lead is cooled to 370°F. At this temperature, additional
2-5
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impurities of copper, sulfur, arsenic, antimony and nickel
collect at the surface as a dross, which is removed for further
refinement and recovery of lead.
Finally, the purified lead bullion is refined in a series of
iron casting kettles that, typically, are heated with gas-fired
burners. Final removal of impurities (antimony, tin, arsenic,
zinc, and bismuth) provides a final product of refined lead,
commonly 99.990 to 99.999 percent pure, that is casted and
readied for shipment.
2.2.2 Secondary Lead Smelting
Secondary lead smelting begins with lead-bearing materials
including scrap batteries, battery plant scrap, lead sheathes
cast and high lead content scrap. The principal function of the
secondary lead industry is reclamation of the lead from lead-
bearing scrap metal. The product of secondary smelting include
semisoft lead (few impurities), hard or antimonial lead, and soft
lead bullion. These products are used to make battery plates,
lead oxide, and a variety of miscellaneous items (solder,
pigment, etc.).
Typical secondary lead smelting and refining scheme involves
four distinct processes, as illustrated in Figure 2-4. They are:
scrap receiving and preparation, smelting, refining and casting.
Similar to the primary lead smelting process, point source
emissions are associated with each distinct area, as illustrated
in Figure 2-4. Because the final product from each secondary
lead smelter may vary, there are differences within each of the
distinct processes between facilities. Major factors that affect
the plant's specific configuration include scrap sources,
intermediate and final products, and type of smelting furnace.
Since batteries constitute nearly 84 percent by weight of
starting materials in the secondary lead smelting operation, the
description of the process will involve lead batteries as the
starting material.
Batteries are received at the facility either by truck or
rail, unloaded and stored temporarily in a receiving area. Prior
to smelting, the acid in the batteries is drained. Most plants
2-6
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Son?
DTOMM, _
fVailni flrrap
K>
I
Oto Scrap.
Rotoiy/Tub*
©
ConMISaap
nwnnmtary
An Scrap
ntcfMno.
•/Mining
Figure 2-4. Typical secondary lead smelting and refining scheme.
-------
break or saw scrap batteries to remove the battery covers for
recycling and retrieve the battery acid. This operation is
usually accomplished through an automatic feed conveyor systems
and a slow-speed saw. To separate the plastic covers from the
lead terminals, lead oxide paste and ribbon, a float/sink
separation system is usually employed. The crushed plastic is
recovered for recycling and the rubber cases are landfilled.
The lead content of the batteries consisting of the lead
oxide paste (60 percent) and lead alloy plates (40 percent) is
transferred to the charge storing and preparation area where it
is combined with other materials prior to the smelting operation.
Other lead-bearing materials charged to the smelting furnace are
slags from the smelting furnace, drosses from the refining
kettles, and flue dust collected by the facilities' air pollution
control systems. Other charge materials include coke, which is
used as a heat source and reducing agent, and limestone, sand,
and scrap iron which are used as fluxing agents.
Secondary lead smelters employ one of four types of smelting
furnaces for refining the lead. The four types of configuration
are blast furnace, blast furnace/reverberatory furnace
combination, reverberatory furnace and a rotary furnace. The
source of lead in the scrap and the purity of lead to be produced
determine the smelting operation. For the production of hard
lead (containing 12 percent antimony and 3 percent arsenic), the
blast furnace is utilized in the smelting process. For the
production of semisoft lead (0.3 percent antimony and
0.05 percent arsenic), the reverberatory or rotary furnace is
utilized. In the reverberatory furnace, the charge material is
heated by radiation from the flame and from the furnace walls to
temperatures up to 1260°C (2300°F); consequently, reverberatory
furnaces provide purer lead than blast furnaces. As the molten
metal rises in the furnace, it is tapped into molds for
distribution or for further refinement.
Refining and alloying are done in pot furnaces (refining
kettles). The process is a batch operation and may take from a
few hours to 2 to 3 days, depending upon the degree of purity or
2-8
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alloy type required. Refining kettles are gas- or oil-fired with
typical capacities of 23 to 136 Mg (25 to 150 tons) lead.
Refining and alloying activities are conducted at temperatures
ranging from 320° to 700°C (600e to 1300°F).
Following the final refining step, a sample of the refined
metal is collected and the alloying specifications are verified
by chemical analysis. When the desired composition is reached,
the molten metal is pumped from the kettle into the casting
machine and cast into lead ingots, rectangular bars that weigh
approximately 25 kg (56 Ib) each.
2.2.3 Lead-Acid Battery Manufacturing
The production of lead-acid batteries consists of four main
steps, as illustrated in Figure 2-5. The four main steps are:
grid casting, paste mixing, three-process operation and
formation. Point sources lead emissions are associated with each
of these steps. As part of the grid casting process, lead alloy
ingots are melting in an electric or gas-fired pot and then
poured into molds. Grids can be cast in pairs or on a continuous
casting machine. Once the grids have solidified they are ejected
from the molds, trimmed and stacked.
The paste that is applied to the grids is composed of lead
oxide, water and sulfuric acid mixed in a batch process. To make
a negatively charged paste, expander is added. For positive
paste, no expander is used and the paste contains slightly more
sulfuric acid and less water. After mixing , the paste is
applied to the grids, flash dried, stacked and cured. Lead oxide
is received at the manufacturers in ingots. The ingots are
tumbled in a ball mill process to produce metallic lead
particles. Lead oxide dust and unoxidized lead particles are
drawn off by a circulating air stream from the ball mill and are
further ground in a hammermill. The lead oxide and metallic lead
particles are then stored in bins.
Formation of the lead battery in the three-process operation
consists of plate stacking, burning and assembling of elements in
the battery case. Plates are first stacked in alternating
positive and negative order, and separated by insulators.
2-9
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to
I
i
LeedOxkto
ProducHon
Mbdng
FUTMO*
Pnctu Opontton'
AnamUylnto
BadwyCaM
Figure 2-5. Process flow diagram for storage battery production.
-------
Burning consists of connecting the plates by welding leads to the
tabs of each positive and negative plate. The completed elements
are then assembled in the battery cases either before formation
("wet" formation) or after formation ("dry" formation). An
alternative to this operation is the "cast-on-strap" process in
which molten lead is poured around the plates and tabs to form
the connection.
The formation process chemically converts the inactive lead
oxide-sulfate paste into an active electrode. The unformed
plates are placed in a dilute sulfuric acid solution, the
positive plates are connected to the positive pole of a direct
current (dc) source, and the negative plates are connected to the
negative pole of the dc source. The formation process may be wet
or dry. In the wet formation process, the elements are assembled
in the case before forming. In the dry process, the elements are
formed in a tank of sulfuric acid and then assembled in the case.
2.3 OPEN DUST FUGITIVE EMISSIONS
Open dust fugitive sources include paved and unpaved traffic
areas and storage piles. Particulate emissions are released from
these sources when previously deposited material is reentrained
by vehicle traffic, by the loading and unloading equipment, or by
the action of the wind. For most industrial plants, paved and
unpaved roads are the primary sources of open dust fugitive
emissions. Fugitive dust emissions from storage pile materials
handling operations are usually insignificant in comparison to
road sources, unless the moisture content of the storage pile
materials fif extremely low. Emissions from wind erosion of
storage piles are likewise insignificant unless wind speeds are
unusually high.
2.3.1 Industrial Paved Roads
Open dust fugitive emissions from paved roads depend upon
the loose surface material and traffic characteristics of the
road. These emissions have been determined to vary directly in
.proportion to the surface material loading and silt content of
the road. The surface material loading is the amount of loose
dust on the road surface and is measured in units of mass of
2-11
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material per unit area. (Surface material loading for a specific
road is typically expressed in units of mass per unit length of
road, however.) The silt content is the percentage of silt
(i.e., particles less than or equal to 75 microns in diameter) in
the loose surface dust. Other factors that affect industrial
paved road fugitive emissions include the volume of traffic,
number of traffic lanes, average vehicle weight, and the degree
to which vehicles travel in nearby unpaved areas (thereby
allowing more dust to be deposited on the paved road). This last
factor is known as the industrial augmentation factor and ranges
in value from 1.0 to 7.0. Higher values indicate greater
fugitive dust emissions. The magnitude of fugitive lead
emissions is directly proportional to the percentage by weight of
lead in the silt fraction.
2.3.2 Unpaved Roads
Particulate emissions occur whenever a vehicle travels over
an unpaved surface. Unlike paved roads, however, the road
surface itself is the source of the emissions rather than any
"surface loading." Unpaved roads and travel surfaces
historically have accounted for the greatest share of particulate
emissions at a number of industries. In addition to roadways,
many industries often contain other unpaved travel areas. These
areas may often account for a substantial fraction of traffic-
generated emissions from individual plants.
Fugitive dust emissions from unpaved roads also are directly
proportional to the silt content of the surface material, and
fugitive lead emissions are direct proportional to the lead
content in the silt fraction. Unpaved road fugitive dust
emissions are also proportional to the mean vehicle speed, mean
vehicle weight, and mean number of wheels. Fugitive emissions
from unpaved roads are also affected by the rainfall frequency.
2.3.3 Storage Piles
in most industrial settings, materials are stored uncovered
in outside locations. Although this practice facilitates
transfer of materials into and out of storage, it also subjects
the storage to several forces that can introduce dust into the
2-12
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air. In general, there are three mechanisms by which storage
piles can act as sources of fugitive dust emissions:
1. Equipment traffic in the storage area;
2. Materials handling operations; and
3. Wind erosion of pile surfaces and surrounding areas.
Open dust fugitive emissions from storage piles are
generally insignificant in comparison to fugitive emissions from
paved and unpaved traffic areas. However, under worst case
conditions, storage pile emissions can be significant and
therefore should be taken into consideration as a source of
fugitive emissions. On the other hand, fugitive emissions from
partially or fully enclosed storage piles generally will be much
less than the emissions that would originate from the same
storage pile without the protection of the enclosure.
Equipment traffic between, in the vicinity of, or on storage
piles is a source of fugitive emissions. Similar to the
unpaved/paved road, the lead emissions associated with this
source are directly proportional to the silt content of the
storage pile.
Material handling is another fugitive emission source of
lead emissions. Material handling involves either adding to or
extracting material from the storage pile. Transfer operations
involving storage piles can be classified as either continuous or
batch operation. An example of a continuous operation is adding
material to a pile by conveyor; an example of a batch transfer
operation J.s the dumping of a load of material onto a pile by a
truck.
Dust emissions may be generated by wind erosion of open
aggregate storage piles and exposed areas within an industrial
facility. Once again, lead emissions from both active and
inactive storage piles are proportional to the silt content of
*he material stored, along with wind speed and rainfall
frequency.
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2.4 PROCESS FUGITIVE EMISSIONS
Process fugitive emissions are released from industrial
operations to the atmosphere either directly from the process or
through building openings such as windows, doors, or roof
monitors rather than through well-defined stacks or vents.
Sources of process fugitive emissions include both processing
operations, such as furnaces and crushing and screening
operations, as well as intermediate material handling operations,
such as hot metal transport and solids conveying.
As a class of sources, it's difficult to generalize about
process fugitive emission sources as compared to open fugitive
dust sources. The process operations that lead to fugitive
emissions vary substantially for the different industries and for
different plants with the same industry. Further,
characteristics of the emissions that affect control vary much
more from source to source for process fugitive emissions than
they do for fugitive dust sources. In particular, process
fugitive emissions vary widely with respect to configuration of
the release point, plume geometry and temperature, and particle
size distribution of particulate matter.
Although process fugitive emission sources vary greatly,
they can be grouped into five general categories of sources that
have comparable characteristics. These five categories are solid
materials handling operations, materials processing operations,
furnaces, hot metal transfer and processing, and metal casting.
2.4.1 Solid Materials Handling Operations
Solid'materials handling operations, as associated with
process fugitive emissions, includes handling and transfer of
solid materials as intermediate steps in a process. Examples of
materials handled within these industries include coke and coal,
limestone fluxing materials, sinter, slag and air pollution
control device dust. Each of these materials contains fines that
are emitted during handling and transfer operations. These
handling and transfer operations differ from the fugitive dust
sources in that they occur after the material leaves the raw
material storage areas and often are enclosed within process
2-14
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buildings. The handling operations themselves and the
characteristics of the emissions are comparable to those
described in the section on fugitive dust.
Within these industries, the handling of solid materials can
be accomplished either mechanically with a conveyor system or
manually using front-end loaders. In either case most emissions
are generated at points where material undergoes some type of
drop, such as a conveyor transfer point or a front-end loader
dump station. Generally the emissions are at ambient temperature
and comprise relatively large size particulate matter. The plume
configuration and flow properties generally are controlled by
ventilation airflows in the vicinity of the transfer point.
2.4.2 Materials Processing Operations
Many of the raw materials used must undergo further
processing before they can be used in the primary manufacturing
process. Typical materials processing operations include
crushers and hammermills, which are used to reduce the size of
feedstock such as coke ore, sinter, and batteries; screening
operations, which are used for both sizing (e.g., sinter in lead
smelters) and cleaning; and mixers, which are used to blend
materials (particularly core and mold materials in foundries).
Each of these processes modifies the material being processed by
applying mechanical energy to the material. This mechanical
energy exacerbates fugitive emissions via two mechanisms. First,
these processes increase the amount of fines in the material
through fracturing and abrasion. Second, the mechanical energy
imparts high* velocities directly to the fine materials and
generates high-velocity air streams within the process equipment
and, in doing so, increases the potential for emissions.
These processes all have similar emission characteristics
and, in general, each of the processes is enclosed. However,
because of the high energy involved in the processes, significant
quantities of fugitive emissions can be generated from process
leaks. Fugitive particulate matter is also emitted during
charging and discharging of the processes. Typically these
emissions are discharged at ambient temperatures (with sinter
2-15
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crushing and screening as the exceptions). As with materials
handling operations, the particle size distribution is relatively
coarse, and the plume behavior is strongly influenced by
ventilation patterns in the vicinity of the process equipment.
2.4.3 Furnaces
High-temperature metallurgical furnaces are used for
melting, reducing, and refining metallic compounds in the lead
industries. In addition, sinter machines are used in the primary
lead industry to transform lead sulfide to lead oxide and to
produce a feed material with suitable physical properties for
charging to the blast furnace. Both of these processes are major
sources of fugitive lead emissions. However, due to the
configuration of the furnace in the secondary lead industry
(reverberatory vs. blast), fugitive emission quantities and
emission release characteristics differ widely. The size,
material processed, operating temperature and cycle all affect
fugitive emissions. During the operation of the metallurgical
furnaces, fugitive emissions are generated during charging of raw
materials and discharging (tapping) of product and slag.
Fugitive emissions are also generated via process leaks during
normal operations and from process upsets such as blast furnace
slips.
The magnitude of fugitive emissions from the charging
operation depends upon type of material charged, size of the
charge, configuration of the charge opening, and characteristics
of the material remaining in the furnace when changing is
initiated."
The material charged to the furnace can be raw material
feedstock (e.g., blast furnaces in primary lead smelters), scrap
(e.g., blast furnaces or cupolas in secondary lead smelters), or
a combination of molten metal and scrap. Emissions are affected
bv cleanliness and temperature of the material. For example, if
a scrap load to an electric furnace contains high concentrations
of lead, fugitive lead emissions will increase when this Iqad
hits the molten bath in the furnace. Also, fugitive emissions
generally are high when molten metal is charged.
2-16
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Generally, fugitive furnace emissions have two common
characteristics. First, emissions are released in a high-
temperature, buoyant plume, which complicates capture and
emission reduction. Second, the emissions tend to be fine
particles, increasing opacity and difficulty of control.
Finally, routine tapping of the furnace is another source of
fugitive emissions. In stationary-type furnaces such as
reverberatory furnaces, cupolas, and blast furnaces, tapping is
accomplished through a "tap hole" located at the bottom of the
furnace where the molten metal (or slag) is routed through a
series of runners to a ladle. In nonstationary furnaces, the
furnace is tilted and molten metal is poured directly into a
ladle. In either case, as soon as the molten metal is exposed to
the air, volatile metal oxides are released from the surface of
the stream. As these volatilized metals move away from the
surface in a high-temperature buoyant plume, they cool and
condense to form a very fine fugitive metal fume. Again, the
buoyant plume, the fine particle size, and the complex geometry
of the release complicates control.
2.4.4 Hot Metal Transfer and Processing
In the metallurgical operations under study, molten metal is
transported between furnaces or from the furnace to a casting
operation to ladles. These ladles are typically moved by rail or
overhead crane. In some cases, final refining is also
accomplished in these ladles.
Both the transport and refining operations are conducted
with the metal still in a high-temperature, molten state. Metals
volatilize from the surface of this molten metal and subsequently
condense to form a fine fugitive metal fume. As with furnace
charging and tapping, the buoyancy of the plume, the fine
particulate matter, and the source mobility complicate control.
2.4.5 Metal Casting
Metal casting can be one of the more significant sources of
fugitive emissions in metallurgical process. Casting processes
vary significantly in different plants. In nonmechanized
facilities, the molds are generally placed in a large, open area.
2-17
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The hot metal ladle is then moved by an overhead pulley system to
the mold, and the casting is poured and cooled in place. In more
mechanized facilities, the mold is placed on a conveyor and moved
to the pouring station and then moved to a cooling area.
Emissions problems are comparable for both mechanized and
nonmechanized processes: the emissions are contained in a
relatively high-temperature, buoyant, moist stream. The
constituents of concern are fine metal oxides that volatize from
the hot metal surface. The damp buoyant stream adds to the
difficulty of controlling these sources.
2-18
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3.0 LEAD EMISSION CONTROLS
3.1 INTRODUCTION
Lead emissions can be minimized through proper control of
fugitive and point sources at industrial facilities. The
objective of this chapter is to discuss the traditional control
strategies for open dust emissions from paved/unpaved roads and
storage piles. Additionally, specific control devices for
reducing point source emissions will be discussed. Review of
this technology will enable the permit written to better
incorporate required lead emission control programs as part of
the source permitting process.
While not all fugitive dust contains appreciable quantities
of lead, our discussion will cover fugitive dust with the
assumption that at a lead facility, the concentration of lead in
the fugitive dust will be above traditional ambient
concentrations. Therefore, by controlling fugitive dust
emissions, we likewise control lead emissions.
3.2 INDUSTRY-SPECIFIC CONTROLS FOR POINT SOURCES AND PROCESS
3.2.1 Baahouses
Fabric filtration is one of the most common control
techniques utilized in the primary and secondary lead smelting
industry. In the fabric filter system, particulate is collected
within a dust cake supported on either a woven or felted fabric.
The five basic mechanisms by which particulate matter can be
collected on the fabric are: (1) inertial impaction;
(2) Brownian diffusion; (3) direct interception; (4) electro-
static attraction; and (5) gravitational settling. By far the
most common is inertial impaction. Impaction of a dust particle
occurs when the gas stream goes around the fabric, but the
particle is so large that it cannot follow the gas streamlines,
therefore impacting into the stationary fabric. Particles
entering a new fabric initially contact the individual fibers and
are collected by the filtration mechanism. The particles are
lodged within the fabric structure, thus promoting the capture of
additional particles. As these particles build up, particle
3-1
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aggregates form, bridging of the interweave and interstitial
spaces occurs, thus developing a continuous deposit. Finally, as
more particles build up, a surface dust cake is developed.
Periodically, the dust cake must be removed either by
shaking or utilizing compressed air (reverse air on pulse jet).
Once cleaned, the bag is once again subjected to the dirty gas
stream. After a few cleaning cycles, a steady-state dust cake
forms on the bag, thus increasing its efficiency. ' The dust cake
remains with the bag until it is damaged, replaced or washed.
A typical baghouse consists of the following components:
1. Filter medium and support;
2. Filter cleaning device;
3. Collection hopper;
4. Shell; and
5. Fan.
The heart of the baghouse, as illustrated in Figure 3-1, is
the bag or fabric material that usually represents the highest
maintenance component in the filter system. The effective
selection of the fabric in a baghouse can substantially reduce
maintenance and replacement cost. When selecting a fabric, the
user must consider fabric characteristics as percent dust
penetration, power requirements associated with operation
pressure losses, fabric cleaning procedures, capital replacement
cost, corrosivity and reactivity of the gas stream and gas
temperature. Bag life, which varies greatly with operating
conditions, is on the order of 1 to 3 years.
Operational problems with fabric filters include
fluctuations in gas flow and dust loading, high temperature and
humidity, condensation, and reactivity of gas and/or dust
particles with system components. These problems affect pressure
drop, efficiency, and bag life. Maintenance includes regular
inspection, greasing of mechanical parts, disposal of solid waste
and replacement of worn bags. Fabrics are available that permit
operation at temperatures of up to 290°C (550°F) and provide
chemical resistance against constituents in the gas stream.
3-2
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Dirty ga.^.l
Figure 3-1. Typical baghouse configuration,
3-3
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The gas flow rate and dust concentration, in conjunction
with specific flow-resistance properties of the dust deposited on
the fabric, determine the required cloth area for operation at a
specified pressure drop. Pressure drop is generally selected in'
the range of 0.75 to 1.0 KPa (3 to 4 in. H2O), although some
systems operate well in excess of 2.5 kPa (10 in. H2O).
Superficial filter velocity, m3/s-m~2 cloth (acfm/ft2 cloth),
commonly called the air-to-cloth ratio, generally ranges from 5.0
to 7.5 x 10~3 m3/S'm~2 cloth (1 to 15 acfm/ft2 cloth) depending
on gas stream and particle characteristics and on the cleaning
mechanism.
A variety of cleaning mechanisms are used to remove dust
from the filter media: (1) mechanical shaking; (2) air shaking;
(3) air bubbling; (4) jet-pulse; (5) reverse air flexing;
(6) reverse jet; and (7) repressurihg. Very small baghouses,
less than 93 m2 (1,000 ft2) of cloth, are frequently cleaned by
manual rapping. This method is unreliable to the extent that it
depends on the operator's work habits. Manometers are
recommended to indicate pressure drop when cleaning is done
manually. Mechanical shakers, which are most common, are driven
by electric motors that provide a gentle but effective cleaning
action. In the jet-pulse method, a jet of compressed air
released through a venturi section at the top of the bag cause
the bags to pulse outward; jet pulse cleaning provides for
automatic, continuous cleaning with uniform pressure drop and
permits higher air-to-cloth ratios. Reverse air flexing is
achieved by'a double or triple cycle deflation of the bags
followed by gentle inflating through low-pressure reverse flow.
Reverse jet cleaning is done with a traveling ring of compressed
air, which moves up and down the outside of the tubular bag.
Repressuring cleaning is accomplished a low-pressure, high-
voluae, reverse flow of air through the bags.
3.2.2 Venturi Scrubbers (Low/High Energy)
Venturi scrubbers and other types of wet collectors are
available in a wide range of cost and performance
characteristics. Scrubbers gain much of their popularity because
3-4
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they are able to remove both solid and gaseous components from
effluent gases with high temperatures, high moisture content, and
high corrosivity.
Particulate matter is collected by making the particles
larger through combining them with liquid droplets and then
trapping them in a liquid film. Collection efficiency is related
to particle size, particle density, turbulence, and liquid-to-gas
ratio. Collection efficiency is also related to pressure drop
for a given particle size.
A venturi scrubber forces flue gases through a venturi
throat where water is injected, as illustrated in Figure 3-2.
Gas velocities through the throat can range from 75 to 100 meters
per second (m/sec) (15,000 to 20,000 ft/min). Pressure drops can
range from 2.5 kPa (10 in. H2O) to over 20 kPa (80 in. H20). The
venturi provides the necessary solid-liquid contact for high
collection efficiencies. Liquid to gas ratios range from 0.4 to
2 litre/m3 (3 to 15 gal/min/103 acfm). The wetted particles and
droplets are collected by a cyclone spray separator after they
exit the venturi.
High-energy venturi scrubbers are made of 316-stainless
steel. These high energy scrubbers also collect and remove
particles by injecting water, but the gas stream is accelerated
to much higher velocity while water is injected to create more
turbulence and solid-liquid contact. Pressure drops of 15 kPa
(60 in. H2O) can produce collection efficiencies up to
99.5 percent.
Though wet scrubbers have attained collection efficiencies
of 95 to 98 percent when treating lead fumes with particles
smaller than 9.5 /aa, their efficiencies for smaller particles are
lower. Achieving a high-efficiency collection of submicron
particles requires a much higher energy input. For good cleanup
results, pressure differences from 7.5 to 24.9 kPa (30 to 100 in.
H2O) are required.
Water scrubbing may also bring about corrosion problems.
The scrubbing water will absorb SO2 in the gas stream, forming a
3-5
-------
throat
Figure 3-2. Venturi scrubber system.
3-6
-------
dilute sulfurous acid. Adding lime,vcaustic soda, or similar
chemical to the water may be necessary to minimize corrosion.
Further, the dust is recovered as a dilute slurry. In order
to recover the lead oxide in the dust, some type of separator is
required. The dry collection of the lead oxide in a fabric
filter allows simple recycling of the dust, as opposed to the
more complicated process of recovering the lead dust from the
scrubber catch.
When the sulfur content of the initial charge is relatively
high (as in secondary lead smelters where the primary source of
scrap fed into the furnace is old battery plates contaminated
with suIfuric acid), the scrubber has an advantage over a fabric
filter because it can be designed strictly for the absorption of
SO2. Sulfur will be released from the furnace fuel charge and
from the lead sulfate as sulfuric acid from the lead storage
batteries.
3.2.3 Cyclones/Multicyclones
Cyclones have been utilized for years as a relatively
low-cost method for removing particulate matter from exhaust gas
streams. While they provide a simplistic approach to gas
cleaning, they are not as efficient as baghouses, wet scrubbers
or electrostatic precipitators. They are traditionally used as
precleaners before the more efficient devices.
The common cyclone, as illustrated in Figure 3-3, consists
of four major components: inlet, cyclone body, dust discharge
system, and outlet. The inlet helps to direct the gas into the
cyclone body, forming the vortex circular pattern. It is
important that the gas enters the body of the cyclone with
minimum disturbance and pressure drop. . It takes more power to
move the gas through the system with increased pressure drop. If
the inlet is poorly designed, turbulence can occur and more
*»n»*i7y i«? needed to incorporate the incoming gas with the vortex
gas already in the body, thus decreasing its efficiency and
increasing pressure drop across system.
The cyclone body design is very important to the overall
efficiency of the system. The overall length of the cyclone
3-7
-------
Inlet
Outlet
Vortex
finder
Cylinder
Cone
Cyclone
body
Figure 3-3. Typical components of a cyclone.
3-3
-------
determines the number of turns of the vortex, thus the efficiency
of the system. As the vortex flows through the cyclone body,
particulate matter is thrown too the sides of the walls of the
cyclone and moves down to the dust discharge hopper.
Consequently, by varying the length and width of the cyclone,
different efficiencies can be achieved. High efficiency cyclones
generally have smaller inlet and exit areas with a smaller body
diameter and longer overall length. A conventional cyclone will
be from 4 to 12 feet in diameter, having a pressure drop from 2
to 5 inches. A high efficiency cyclone will be less than 3 feet
in diameter with a pressure drop of from 4 to 6 inches of water.
The dust discharge system collects the entrained particles
from the walls of the cyclone body. To prevent reentrainment of
particulate matter back into the vortex stream, straightening
vanes, rotary vanes and flaps have been utilized successfully.
Finally, the cyclone gas outlet serves to move the gas
stream away from the collected particles. The exit tube must be
long enough to extend beyond the inlet so the eddies do not mix
particles up in the exit tube.
Consequently, smaller cyclones are more efficient than
larger cyclones. Small cyclones, however, have two major
limitations: higher pressure drop and limited volumetric flow
rates. Smaller cyclones can be arranged either in series or
parallel to increase efficiency at lower pressure drops.
Multicyclone arrangements tend to plug more easily and have
reentrainment problems. However, for the cost and considerably
lower maintenance, the multicyclone and cyclone have been
utilized in the smelter industry as either precleaners or as the
primary pollution control device.
3.3 GENERAL OPEN DUST FUGITIVE CONTROL
3.3.1 Introduction
The control of open dust fugitive emissions fall within
three general categories:
1. Preventive measures;
2. Removal of surface dust; and
3. Dust suppressant measures.
3-9
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Emissions of fugitive dust occur from paved roads, unpaved
roads and storage piles associated with primary and secondary
lead smelting operations, as illustrated in Figure 3-4. This
section discusses the control techniques applied to these sources
of open dust fugitive emissions.
3.3.2 paved Roads
Paved roads do not present as great of a source of fugitive
emissions as do unpaved roads. The level of emissions depend
upon the surface loading. The control technology associated with
the surface loading involves either preventing material from
being deposited on the surface or to remove the material from the
surface once deposited. The control techniques include:
Deposition
Preventive measures
Removal
1. Broom sweeping;
2. Vacuum sweeping; and
3. Water flushing.
Under preventive measures, the control approach involves
preventing the deposit of additional materials on a paved
surface. Historically, sources of deposition on paved roads are
influx from unpaved roads, storage piles, parking lots and
vehicle entrainment and carryover. The source specific fugitive
emission control program would involve preventive measures to
limit outside influence. As outlined in Table 3-1, measures
include covering trucks or washing to prevent carryover when
going from-an unpaved surface to a paved surface, limited traffic
or road use, and the use of wind breaks/vegetation stabilization
to minimize erosion. Preventive measures can have a significant
impact on deposition of fugitive lead dust emissions on paved
roads.
Of the three removal methods, water flushing has been
documented as the most effective technique for controlling
fugitive emissions from paved roads, as illustrated in Table 3-2.
Broom sweeping, involving a rotary boom, removes only
approximately 30 percent of the surface loading. Indeed, a
3-10
-------
Bast
Furnace
CharoB
Praparato
i
Lead
CMing
LBadPto ^
•ndln0oli
Rdcw
\-S \S
To Copper
Zinc
Furnace
LEGEND
•*• Op«n Dust Fugilhw Emissions
-•*• Process Fugitive Emissions
Figure 3-4. Process diagram for primary lead smelting showing potential industrial
fugitive and process particulate emission points.
-------
TABLE 3-1. NONINDUSTRIAL PAVED ROAD
DUST SOURCES AND PREVENTIVE CONTROLS
Source of deposit on road
Recommended controls
• Spills from haul trucks
Require trucks to be covered
Require freeboard between load and top of
hopper
Wet material being hauled
• Construction canyout and entrainment
• Clean vehicles before entering road
• Pave access road near site exit
• SemicontittuoQs cleanup of exit
• Limit number of access points to/from the area
• Vehicle entrainment from unpaved adjacent
areas
• Pave/stabilize portion of unpaved areas nearest
to paved road
• Entrainment from stormwater washing eroded
soils onto streets
• Improve storm water control
• Vegetative stabilization
• Rapid cleanup after event
• Wind erosion from adjacent areas
ation or chemical sealing of
Windbreak*
Vegetative
ground
Pave/treat parking areas, driveways, shoulders
Limit traffic or other use that disturbs soil
surface
3-12
-------
TABLE 3-2. MEASURED EFFICIENCY VALUES FOR PAVED ROAD CONTROLS
Methods
Broom sweeping
Vacuum sweeping
Water flushing
Water flushing
Cited efficiency
0-30 percent
0-58 percent
69-0.231 Va'b
96-0.263 Va'b
aWater applied at 0.48 gal/yd2.
bEquation yields efficiency in percent, V
passes since application.
number of vehicle
3-13
-------
substantial fraction of the original surface loading is emitted
during operation, thus broom sweeping may not be very effective
as a removal technique. Vacuum sweeping, however, provides a
more effective technique in the removal category. Vacuum
sweeping removes material from paved surfaces by entraining
particles in a moving air stream. Traditionally, a hood moves
over the surface, removing the material to a hopper while the air
is exhausted through a filter system. As illustrated in
Table 3-2, the reported efficiency of this system is up to
60 percent for total particulate matter.
The most effective removal technique is water flushing
and/or water flushing followed by sweeping. Water flushing
involves high-pressure water sprays directed to the paved
surfaces to remove deposits. Some systems supplement the
cleaning with broom sweeping after flushing. Unlike the two
sweeping methods, flushing faces some obvious drawbacks. The
most serious drawback to water flushing in this industry is the
potential to create ground water and soil lead contamination
problems if the water is not contained and treated.
1. Unpaved Roads
The reduction of fugitive emissions from unpaved roads fall
within three general categories. They are:
1. Source activity;
2. Source improvement; and
3. Source treatment
a. Watering
-b. Chemical treatment.
The specific control measures associated with each of the
categories are outlined in Table 3-3.
For unpaved roads, reduction of fugitive emissions
associated with source activity involves limiting the amount of
traffic on the road or lowering speeds to minimize emissions
because emissions are proportional to vehicle speed. The
reduction may be obtained by banning certain vehicles or strictly
enforcing speed limits.
3-14
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TABLE 3-3. CONTROL TECHNIQUES FOR UNPAVED TRAVEL SURFACES
Type of control
Source extent reduction
Source improvement
Source treatment
Specific control measures
Speed reduction
Traffic reduction
Paving gravel surface
Watering
Chemical stabilization
-- Asphalt emulsions
-- Petroleum resins
-- Acrylic cements
-- Other
3-15
-------
Surface.improvement control measures consist of paving or
replacing aggregate with one of lower silt (consequently lower
lead) content. Paving should be considered for those roads which
have the highest traffic volume. Aggregate improvement reduces
total suspended particulate emissions by reducing the silt
content of the road surface. However, lead emissions may not be
reduced due to infiltration from other sources.
Surface treatment involves application of water or chemical
treatment. Watering is a temporary measure, and periodic
reapplications are necessary to achieve any substantial level of
control efficiency. The control efficiency of unpaved road
watering depends upon (a) the amount of water applied per unit
area of road surface; (b) the time between reapplications;
(c) traffic volume during that period; and (d) prevailing
meteorological conditions during the period. Wetting agents,
such as surfactants that reduce surface tension, may be added to
increase the control efficiency of watering.
Chemical treatments for unpaved roads fall into two general
categories: (1) chemicals that simulate wet suppression by
attracting and retaining moisture on the road surface; and
(2) chemical dust suppressants that form a hard cemented surface.
Treatments of the first type, typically salts, are usually
supplemented by watering. Included in the second category are
petroleum resins, asphalt emulsions, acrylics, and adhesives.
These are the treatments most commonly used.
3.3.4 Storage Pile
The.reduction of fugitive dust emissions from storage piles
are related to controlling material handling operations and wind
erosion. Control can be achieved through the following available
activities, -as outlined in Table 3-4:
1. Minimizing activity at source;
2. Source improvement; and
3. Surface treatment.
Work practices play a major role in minimizing fugitive
emissions from storage piles. Reducing the frequency of
disturbing the pile, cleaning up spills during material
3-16
-------
TABLE 3-4. CONTROL TECHNIQUES FOR STORAGE PILES
Type of control
Specific control measures
Material handling
• Source activity
• Source improvement
• Surface treatment
• Minimize activity at source
• Reduction in storage pile
• Wind sheltering (enclosures)
• Moisture retention
• Wet suppression
:?::. :^&^..:&&;--;~:'--::£\. /,-.•: • Wind erosion . .. :..,:. . .-•'•'
• Source activity
• Source improvement
• Surface treatment
• Area reduction
• Cleanup
• Spillage reduction
• Area reduction
• Wet suppression
• Chemical stabilization
3-17
-------
extraction and reducing the exposed ->area of the pile can all
reduce fugitive emissions. These "good operating" practices
should be part of a source specific control program with minimum
investment.
Source improvement activities involve reduction in storage
pile area, moisture retention and enclosure. By far the most
effective activity is enclosure. Enclosure can either be fully
or partially designed. Enclosures traditionally used for open
dust control include three-sided bunkers for storing bulk
materials, storage silos for various types of aggregate
materials, open-ended buildings, and similar structures.
Practically any means that reduces wind entrainment of particles
produced either by erosion of a dust-producing surface (e.g.,
storage silos) or by dispersion of a dust plume generated
directly be a source (e.g., front-end loader in a three-sided
enclosure) is generally effective in controlling fugitive
particulate emissions.
Partial enclosures used to reduce windblown dust from large
exposed areas and storage piles include porous wind fences and
similar types of physical barriers (e.g., trees).
Wet suppression systems have also been employed to minimize
fugitive emissions. These systems use liquid sprays or foam to
suppress the formation of airborne dust. The primary control
mechanisms are those that prevent emissions through agglomerate
formation by combining small dust particles with larger aggregate
or with liquid droplets.
Liquid-spray wet suppression systems can be used to control
dust emissions from materials handling at conveyor transfer
points and storage piles. The wetting agent can be water or a
combination of water and a chemical surfactant. The surfactant,
or surface active agent, reduces the surface tension of the
water. As a result, the quantity of liquid needed to achieve
good control is reduced. For systems using water only, adding
surfactant can reduce the quantity of water necessary to achieve
a good control by a ratio of 4:1 or more. Petroleum resins have
3-18
-------
also been used to control dust emissions from storage piles in
similar fashion to application of wetting agents.
3.4 INDUSTRY SPECIFIC PROCESS FUGITIVE EMISSIONS
As discussed in Chapter 2, the primary and secondary lead
smelting operations provide numerous sources of fugitive lead
particulate emissions, both inside and outside the facility, as
previously illustrated in Figure 3-4. Specifically, process
source fugitive emissions are associated with the pulverizing,
smelting and refining operations. Process hooding and
ventilation of these process points are required to capture and
transport the emissions to a control device to meet regulatory
emission limits and to eliminate potential industrial hygiene
problems to employees associated with the process.
There are three basic components of a ventilation system.
The first component, the air intake, serves to capture the
emissions. The second component, the ductwork, serves to
transport the gas stream to the vent or control device, while the
last component, the fan, serves to move the gas stream through
the system. Ventilation systems must be uniquely designed to
specific process conditions to allow access, yet conform with
facility configuration. The design of the hood should allow for
maximum enclosure while allowing the natural buoyancy or
mechanical forces of the plume into the hood. Finally, the hood
design must be sufficient to allow exhaust ventilation to
maintain recommended face velocities at all hood contacts.
Inadequate design of a ventilation system can compromise overall
performance. In all cases, the hood must be sized and oriented
to capture the maximum quantity of emissions without requiring
excessive gas volumes. The hood should be as close as possible
to the emission point without interfering with equipment movement
and process operation. It should be optimized, to take advantage
of thermal drafts and minimize cross-drafts.
Within the nonferrous smelting industry, there are three
major hood designs utilized to capture fugitive emissions from
process points: (1) enclosure; (2) receiver; and (3) exterior
hood design.
3-19
-------
As the name implies, the enclosure hood envelops the
process, insuring maximum control of fugitive emissions. Example
location and application of enclosure hoods in the nonferrous
smelting industry include lead tapping, pulverizing and smelting
operations. These applications serve to contain the fugitive
emissions and remove them from within the enclosure rather than
to capture the emissions. Consequently, the enclosure hood
requires the least air flow, utilizing the natural buoyancy of
the plume. Figure 3-5 demonstrates an example of an enclosure
hood version of a lead-tapping hood system. Figure 3-6
illustrates a successful application of an enclosure hood on a
rotary furnace. In this configuration, hot flue gases from the
furnace are exhausted through the brick flue. The connection
between the furnace body and the brick flue is totally enclosed.
Additionally, an arched hood is utilized to capture fugitive
emissions produced during charging and tapping operations.
Exhaust draft to this hood is controlled by an electrically
controlled damper. The damper is opened automatically during
charging and tapping.
Receiving hoods operate from the principle of receiving
emissions into the hood by inertial force. These hoods are
usually associated with small processes that impart a velocity to
the stream, such as grinding, blasting and pulverizing
operations. This type of hood has also been applied to capture
fugitive emissions during blast furnace tapping and emission
leaks at access doors at the top of blast furnaces. Figure 3-7
illustrates several applications of enclosure and receiving hoods
as part of a local exhaust ventilation system.
The external hood (canopy) is mounted some distance (up to
100 feet) from the emission source and can be used in conjunction
with receiving and enclosure hoods. This type of hood is usually
associated with hot processes. Similar to the receiving hood,
the canopy hood depends upon the buoyancy of the plume to carry
emission into the hood. Particular application of the external
hood involves a swing design configuration where the hood is
3-20
-------
Exhaust to Baghouse
Butterfly Damper
Furnace
Hinged Launder
Access Door
Rolling Front Top
Access Doors
Crucible
Rolling
Side
Access
Doors
Hinged Metal Access Doors
to Provide Full Access
to Front of Enclosure
Lead Mold -
May Be
Water .
Cooled
Figure 3-5. Enclosed hood for lead-tapping system.
3-21
-------
Electrically-
operated
damper
Retractable arch
hood enclosures
Brick
flue
Hood
enclosing
furnace to flue
connection
Finished
metal
ladte
Wide slot exhaust pickups
Figure 3-6. Rotary furnace charging and tapping hood controls.
3-22
-------
I
To
Baghouse
Skip
Hoist
Hood
Slot Hood Over Access Doors
to Furnace
Skip Hoist Furnace
Charging Hood
To Baghouse
Refining Kettle
Hoods
Mold
Filling
Hood
Figure 3-7. Overview of modified local exhaust
ventilation system.
3-23
-------
placed over metal ladles or slag pots during cooling to capture
the buoyant plumes, as illustrated in Figure 3-8. Typically,
these containers are left at the hood for a short time and then
moved to a holding area for further cooling. The hood can be
positioned over the ladle, then removed. Lead fumes and other
relatively volatile metals which are emitted during cooling are
captured by the external hood.
3-24
-------
Finished
metal ladle
Swing
Design
Figure 3-8. Swing design finishing metal ladle cooling hood.
3-25
-------
4.0 RECOMMENDED OPERATION/MAINTENANCE AND RECORDKEEPING
PRACTICES FOR LEAD EMISSION CONTROL
4.1 INTRODUCTION
A successful source emission minimization program (SEMP)
associated with pollution control ultimately depends upon an
effective design, operation and maintenance (O&M), and
recordkeeping program. Regardless of how well an air pollution
control system is designed, poor O&M will lead to the
deterioration of its various components and a resulting decrease
in its efficiency.
Effective O&M affects equipment reliability, on-line
availability, continuing regulatory compliance, and regulatory
agency/source relations. Lack of timely and proper O&M leads to
a gradual deterioration in equipment, which in turn increases the
probability of equipment failure and decreases both the
reliability and on-line availability of the equipment.
Maintenance of the pollution control and emission
minimization program is a vital component of a source continuous
compliance program. Maintenance at industrial facilities can be
divided into two basic categories? (1) preventive maintenance
and (2) breakdown maintenance. The objective of preventive
maintenance is to minimize future failure of the emission
minimization program through a scheduled source program. The
source preventive maintenance program can be driven by a-
schedule, where distinct activities, observations and records are
acquired for a particular piece of equipment. Source emission
minimization maintenance program activities range from simple
observations to actual measurements performed to evaluate status
of pollution'control equipment. The evaluator records his
findings on an inspection data form, which becomes part of the
source recordkeeping program. The inspection form serves to
lueuciry problem areas that may be imminent for which maintenance
will become necessary. This provides lead time for the source to
assemble the necessary spare parts and for scheduling personnel
so maintenance will be quickly and effectively performed during
4-1
-------
routine plant shutdowns. The records, therefore, help to
determine what action is needed and when.
Breakdown maintenance occurs when the equipment fails,
demanding an immediate response. Recordkeeping performed during
the preventive maintenance program may serve to identify key
parameters which would indicate proximity to a component
breakdown. Records of breakdown maintenance may reduce downtime
during subsequent breakdowns of the same equipment.
Recordkeeping, however, is normally associated with the source
preventative maintenance program rather than the breakdown
maintenance program.
4.2 SPECIFIC CONTROL DEVICES
An O&M program should be part of a larger preventive
maintenance program that enhances the long-term performance of
the associated equipment (process and/or control).
Unfortunately, most preventive maintenance programs must be site-
specific and consider a number of factors such as adequacy of the
design (redundancy), instrumentation, access for maintenance, and
personnel requirements and availability.
Tables 4-1, 4-2, and 4-3 outline general maintenance
schedules for baghouses, venturi scrubbers, and cyclone/
multicyclone systems, respectively. As mentioned earlier,
preventive maintenance schedules must be site-specific, and as
such, the tables which follow are meant to serve only as a basis
from which the maintenance schedules for specific sites.can be
developed. Each source should develop their own maintenance
schedule -based on their combination of processes and control
devices.
4.3 PROCESS FUGITIVE EMISSIONS
Recommended O&M and recordkeeping practices for documenting
process fugitive emissions involve visual observations and
equipment inspection of the ventilation system. As discussed in
cnapter 3, the ventilation system involves chree basic
components. The air intake incorporates the hood which serves to
capture process fugitive emissions. In all cases, the hood must
be sized and oriented to capture the maximum quantity of systems '
4-2
-------
TABLE 4-1. TYPICAL MAINTENANCE SCHEDULE
FOR A FABRIC FILTER SYSTEM
Inspection frequency
Daily
Weekly
Monthly
Quarterly
Senri-annually
Annually
Component
Stack and opacity meter
Manometer
Compressed air system
Collector
Damper valves
Rotating equipment and
drive*
Filter bags
Cleaning system
Hoppers
Shaker mechanism
Pan(s)
Motntor(s)
Tni«t plenum
Shatter niocoJUBSfli
Motors, fans, etc.
Collector
Procedure
Check exhaust for visible dust.
Check and record fabric pressure loss and fan static pressure.
Watch for trends.
Check for air leakage (low pressure). Check valves.
Observe all dials, meters, charts, and gauges, etc. on control
panel and listen to system for properly operating subsystems.
Check all isolation, bypass, and cleaning damper valves for
guidelines.
Check for signs of jamming, leakage, broken parts, wear, etc.
Check for tears, holes, abrasion, proper fastening, bag tension,
dust accumulation on surface or in creases and folds.
Check cleaning sequence and cycle times for proper valve and
tuner operation. Check compressed air lines including oilers and
filers. Inspect Bhalfff mechuisdu for proper operation.
Check for bridging or plugging. Inspect screw conveyor
uignong lot proper upersnon ana luoncaoon.
Inspect for loose bete.
Check for corrosion and material buildup and check V-belt drives
and chains for tension and wear.
Check accuracy of aO indicating equipment.
Check baffle plate for wear; if appreciable wear is evident,
replace. Check for dust iVyoaiu.
Tube type (tube hooks suspended from a tubular assembly):
inspect nylon '""hmf in shaker bars and clevis (hanger)
assembly for wear.
o»fmf>| ffhf Vers (tube hooks suspended from • channel bar
assembly): inspect drill bushings in tie bars, shaker bars, and
connecting rods for wear.
Lubricate all electric motors, speed reducers, exhaust and reverse
air fiuu, mn^ «imjt«r equipment.
Check all bolts and welds. Inspect entire collector thoroughly,
clean, and touch up paint where necessary.
4-3
-------
TABLE 4-2. TYPICAL MAINTENANCE SCHEDULE
FOR A VENTURI SCRUBBER SYSTEM
Inspection frequency
Daily
Weekly
Monthly
$ffln*annuaUy
-
Annuity
Component
Air flow system
Collector
Fan(s), pumps and drives
Fan(s)andpump(i)
Damper valves
Fan and motor bearings
Drive itiggh'TiiT"1*
Ductwork
Dampen
Clarifier pipeline
Spray ban
Pipes and manifolds
Gauges
Scrubber body
ttmmnmnm
DCsVU^v
FW*o flHM« h*m*iM mmA
gear nduccn
Damper seals
Damper drive
mo tnowcn
Collector
Procedure
Check for air leakage (low pressure). Check valves.
Check inlet and outlet gas temperature, pressure drop, liquor
recirculation rate and pH, makeup rate, nozzle pressure, purge
rale, chemical addition rate and liquor turbidity.
Check for signs of jamming, leakage, broken parts, wear, etc.
Check fan motor current.
Check for vibration, oil levels and bearing lubrication.
Check all isolation, bypass and cleaning damper valves for
guidelines.
Check for leaks, cracks or loose finings.
Check chain tension, oil level, sprocket wear and sprocket
•ill OVHVWmf
Check for leakage and excessive flexing.
Check ease of operation and leakage.
Check for plugging.
Check for nozzle plugging and wear.
Check for plugging and leaking.
Check all gauges for accuracy.
Check for material buildup, abrasion, corrosion, leakage.
Check for clearances, wear, pitting, scoring and leakage.
Lubricate.
Check for hrtyrK-atHTft wear fritting scoring clearances,
teao, cracKs or loose nnngs. ,
Check for wear.
Check operation and alignment.
Check all bohs and welds. Inspect entire collector thoroughly,
clean and touch up paint where necessary.
4-4
-------
TABLE 4-3. TYPICAL MAINTENANCE SCHEDULE
FOR A CYCLONE/MULTICYCLONE SYSTEM
Inspection frequency
Daily
Weekly
Monthly
Senri-annuaUy
Annually
Component
Stack and opacity meter
Air flow system
Collector
Fan(s)
Hopper
Fan
Damper valve*
Fan and motor bearings
Ductwork
Dampen
Gauge*
Collector
Fan and motor bearings
Damper seals
Dinner drive
»*- §.-__;_.__ lilad**
i/amper Dealings, Diane*
and Mower*
Collector
Procedure
Check exhaust for visible dust.
Check for air flow leakage (low pressure).
Check inlet and outlet gas temperature, and pressure drop.
Check for signs of jamming, broken parts, wear, etc.
Check fan motor current.
Check for plugging. Inspect sealing device and conveying
system for proper operation and lubrication.
Check for vibration, oil level and bearing lubrication.
Check all isolation, bypass and cleaning damper valves for
synchromian'on and proper operation based upon
manufacturer guideline*!
Check for leaks, crack* or loose fittings.
Check for leakage and excessive flexing.
Check for ease of operation and leakage.
Check all gauges for accuracy.
Check for material buildup, abrasion, corrosion and
leakage. Check for tube wear and pluggage.
Check for clearance*, wear, pitting, scoring and leakage.
Lubricate.
Check for wear.
n. «.«_ _j i t_ i_:
Check for wear and leakage. Lubricate bearing*.
Check an boh* and weld*. Inspect entire collector
thoroughly, clean and touch up paint where necessary.
4-5
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emissions without requiring excess gas volumes. The second
component, the ductwork, serves to transport the gas stream to
the vent or control device, while the last component, the fan,
serves to move the gas stream through the system.
Two of the most important factors affecting the performance
of a ventilation system is hood design and capture velocity. For
hood design, the basic design principles involve:
1. Whenever possible, an enclosure hood should be employed.
2. . If an enclosure hood cannot be used, the hood should be
placed as close to the source as possible and aligned with normal
contaminant flow.
3. To improve hood performance, duct take-offs should also
be placed in-line with normal contaminant flow.
Adherence to these basic principles will result in a hood
system that gives high capture efficiency while utilizing the
minimum air flow necessary.
Effective capture of contaminants by a hood system relies on
velocity toward the hood face. This velocity must be sufficient
to maintain control of the contaminants until they reach the
hood. Of particular concern is external air motion that may
disturb this flow and cause loss of the contaminant or require
higher than normal air velocities to maintain control. Sources
of air motion that must be considered when designing and placing
hoods include:
1. Room air currents associated with the workspace*
ventilation system. These can become quite large when windows
and doors~are opened. Currents of as little as 50 feet/min may
be enough to affect the performance of some hoods.
2. Thermal air currents from heat generating equipment and
processes. Even low heat releases, such as those from an
electric motor, may be enough to disturb hood performance.
3. Machinery motion. Rotating or reciprocating machinery
can be a source of significant air currents.
4. Material motion. Downward motion of material, for
example, will create a downward air current that will make the
upward motion of contaminants more difficult to achieve.
4-6
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5. Operator movements. Rapid movements of an operator can
create air currents of 50 TO 100 feet/min.
Capture velocity is defined as that air velocity at a point
in front of a hood or at the hood face that is necessary to
overcome existing air currents and cause the contaminated air to
move into the hood. The needed capture velocity will depend on
both the direction and velocity of the contaminants at the
desired point of capture, as well as the level of disturbing air
currents that must be overcome. An overhead canopy that relies
primarily on plume buoyancy to convey the contaminants to the
hood will require little capture velocity, generally just enough
to match the plume velocity at the hood face. Contaminants
generated by a high energy process that results in rapid and
random contaminant motion will require quite high capture rates.
A general guide for appropriate capture velocities is provided in
Table 4-4. Values at the low end of the range would be
appropriate when disturbing air currents are low, the toxicity of
the contaminants is low, or the hood is large, resulting in a
large air mass in motion. The higher end of the range would be
more appropriate when air currents are high, the toxicity of the
contaminants is high, or the hood is small.
Both the ventilation system and the hood design involve
activities prior to operation. The O&N activities after
installation centers around visual inspection and minimum
physical measurements. Table 4-5 outlines specific source
emission minimization maintenance timetable for process fugitive
ventilation system.
4.4 OPEN DUST FUGITIVE EMISSIONS
As discussed in Chapter 2, open dust fugitive sources
include paved and unpaved traffic areas and storage piles.
Fugitive dust emissions occur from those sources. When
previously deposited material is reentrained by vehicle traffic,
_y tht loading and unloading equipment, or by the wind.
Historically, roadways are the primary source of open dust
fugitive emissions, while emissions from storage piles are
insignificant.
4-7 .
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TABLE 4-4. RANGE OF CAPTURE VELOCITIES
Type of material release
With no velocity into quiet air
At low velocity into moderately still air
Active generation into zone of rapid air
motion
With high velocity into zone of very rapid
air motion
Capture
velocity, ft/min
50-100
100-200
200-500
500-2,000
4-8
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TABLE 4-5.
SOURCE EMISSION MINIMIZATION MAINTENANCE TIMETABLE FOR
VENTILATION SYSTEMS
Activity/Checks
Description
Ventilation ayntem '
Visible emissions at hood
Physical inspection of hood for
corrosion/damage
Evaluate gap distance from hood to source
Hood capture efficiency to specifications
Balancing dampers positioned properly
Static pressure to maintain proper
conveying velocities to dust collector
Sized properly to maintain proper
conveying velocities to dust collector
System balanced according to pressure
drop
Frequency
Daily
X
Heekly
X
X
X
Monthly^
X
Quarterly
X
Semi-annual ly
X
X
Annually
X
•-.-
-------
Operation and maintenance practices associated with open
dust fugitive emissions involves evaluation of wet suppression
system for storage piles and vehicle control pattern for
paved/unpaved roads. Table 4-6 outlines the suggested
maintenance timetable for open dust fugitive emissions.
4-10
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TA 1LE 4-6. SOURCE EMISSION
MINIMIZATION MAINTENANCE TIMETABLE FOR OPEN DUST
FUGITIVE EMISSIONS
Activity /Checks
Description
Fugitive Dust Piles— Wateh: and
Surfactant Wet Suppression System
Check operation of level control
valve
Check operation of surfactant pump
Check level of surfactant in drum
Check operation of inlet water filter
Visually check spray pattern and
direction of spray jets
Clean stainer basket in each flow
controller
Clean strainer basket in the
proport loner
check operation of all automatic
spray controls
Clean all spray nozzles
Check heating equipment
Lubricate all equipment
Level III inspection evaluation
Meteorological log updated
Equipment maintenance log updated
Storage piles location evaluated
Hind breaks effective
Frequency
Daily
X
X
X
X
X
X
Weekly
X
X
X
Monthly
X
X
X
Quarterly
X
X
Semi-annually
X
Annually
."•'. •'•':' V'
X
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TABLE 4-6. SOURCE EMISSION MINIMIZATION MAINTENANCE TIMETABLE
FOR OPEN DUST FUGITIVE EMISSIONS (continued)
Activity/Check*
Description
Payed roads '
\
Number of vehicles limited to program
levels
Speed of vehicles limited to program
levels
Broom/vacuum sweeping concur with road
activity
Truck washing implemented
Meteorological log updated
Evaluate daily maintenance activities
and adjust accordingly
Localized prevention controls effective
Vegetation stabilisation program
effective
Wind breaks effective
Equipment maintenance log updated
Storm water control evaluated
Preventive control program review
updated
Emergency cleanup program review updated
Unpaved . 'Roads . /:,; $* . ' -: .' / '.- ": • ' -:;- : • •. > :- "•' "' :?' / ;• •
Number of vehicles limited to program
levels
Speed of vehicles limited to program
levels
Frequency
Dally
X
X
X
X
X
X
X
Weekly
X
X
X
Monthly
X
X
Quarterly
1
X
Semi-annual ly
Annually
X
X
*»
I
H
M
-------
TABLE 4-6. SOURCE EMISSION MINIMIZATION MAINTENANCE TIMETABLE
FOR OPEN DUST FUGITIVE EMISSIONS (continued)
Activity/Check*
Description
Broom/vacuum sweeping concur1 with road
activity ,
Truck washing implemented
Meteorological log updated
Evaluate daily maintenance activities
and adjust accordingly
Localized prevention controls effective
Vegetation stabilization program
effective
Wind breaks effective
Equipment maintenance log updated
Storm water control evaluation
Preventive control program review
Emergency cleanup program review updated
Watering and chemical stabilisation
concur with program levels
Surface improvement evaluated
Traffic patterns evaluated
Spray patter uniform
Frequency
Daily
X
X
X
X
X
Weekly
X
X
X
X
Monthly
X
X
Quarterly
X
Semi-annual ly
X
Annually
•
X
X
I
h»
CJ
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5.0 INDUSTRY CONTINUOUS COMPLIANCE PROGRAM
5.1 INTRODUCTION
To attain and subsequently maintain the National Ambient Air
Quality Standards (NAAQS), the Agency and many State governments
have required industrial sources to develop a continuous
compliance strategy for.both source and fugitive emissions. The
objective of the continuous compliance strategy is for sources to
maintain compliance of sources and fugitive emission standards
after initial compliance. Initial compliance is achieved through
strict adherence to permit conditions outlined by Agency
directives. The facilities permit, therefore, is the major
vehicle for translating Agency requirements into specific
enforceable measures at the facility. Through the permit,
emission standards for both source and fugitive emissions are
identified along with requirements of implementation of a source
emission minimization program (SEMP) to insure compliance with
the emission standards on a continuous basis.
At a minimum, the SEMP should contain three major categories
addressing minimization of emissions from point and fugitive
sources within the facility. They are:
1. Source Management Plan fSMPl. The source management
plan outlines management commitment to minimizing point and
fugitive emissions within the facility. The SMP identifies lines
of communication and chain of authority through a tier structure.
2. Source Recordkeepino Plan fSRPl. The SRP plan outlines
the sources performance on meeting RACT/BACT standards and what
control measures will be implemented ensuring continuous
compliance. The SRP plan outlines parameters to be monitored as
part of the sources O&M plan. As part of this plan, the source
provides to the regulatory agency guidelines, documentation,
checklist, control charts and reporting forms used in it's
rcrvtir.u-us compliance program. The plan outlines daily
documentation requirements and proper O&M documentation through
mandatory evaluation. The checklist/documentation insures that
the SMP is operational and that proper measurements are acquired
5-1
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and reported as ventilation of an active source continuous
compliance program.
3. Source Measurement Plan. The source measurement plan
identifies those measurement activities which establishes
"baseline" conditions and verifies continued compliance.
Through the levels of inspection, the plan utilizes such
measurement tools as visible emission (VE) observations, portable
instrumentation and scrubber parameter monitoring as a means of
verifying compliance with RACT/BACT emission standards.
The following section discusses each of these topics as part
of a SEMP.
5.2 SOURCE MANAGEMENT PLAN (SMP)
A major category of the SEMP is the SMP. The management
plan outlines administrative procedures applicable to all
management system and assigns responsibility for all phases of
the SEMP.. Management commitment is one of the keys to developing
and implementing a successful SEMP program. In addition to
typical management considerations such as performance and
personnel requirements, management must be supportive and
understanding of the program. Corporate management should be
apprised of all program activities, from the identification of
the need to monitor emissions to receiving daily emission
reports. Monitoring activities, such as those described in the
QA Plan, should not be committed to without first being reviewed
and approved by corporate management. The management plan must
make the necessary corporate commitments as well as provide the
necessary departmental staff to implement a comprehensive SEMP.
Furthermore, the commitment made up by the source management plan
provides the chain of custody that is necessary to ensure
complete and' responsive implementation of all activities
specified in the QA Plan.
A source management plan involves a three-tier structure, as
outlined in Table 5-1. Tier I involves management of the
source's environmental engineering programs. The Director of
Tier I, Manager of Environmental Engineering, has the overall
responsibility for the development and incorporation of the plan.
5-2
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TABLE 5-1. MANAGEMENT PLAN PROGRAM PARTICIPANTS AND RESPONSIBILITIES3
Tier
Level
CEM program participant
Name, title, address, telephone
number
Responsibility
Plant
iger
Mr. Bob Timson
Primary Lead Smelter Plant
Pine Bluff, North Carolina
(919) 877-3611 (eit. 923)
Responsible for total plant operation
Plant operations supervisor
Mr. Jim Limb
Primary Lead Smelter Plant
Pine Bluff, North Carolina
(919) 877-3611 (en. 813)
Data review and verification
Maintain compliance status (modify operations if necessary)
Environmental engineering
Mr. Jerry Figure
Primary Lead Smelter Plant
Pine Bluff, North Carolina
(919) 877-361I (ext. 714)
Ensures compliance with environmental regulations
Directs activities over engineering department, including
implementation of quality assurance (QA) program
ui
l
II
QA coordinator
Mr. Tom Electron
Primary Lead Smelter Plant
Pine Bluff, North Carolina
(919) 877-3611 (ext. 622)
Responsible for all operation and maintenance activities for
emission reduction and control
Responsible for implementation of the QA Program
May also be responsible for QA activities
Responsible for all QA source activities associated with the
pollution control and CEM program
Implements and performs weekly, monthly and quarterly
QA checks
HI
O&M supervisor
Mr. Scott Work
Primary Lead Smelter Plant
Pine Bluff, North Carolina
(919)877-3611 (ext. 400)
Maintenance and calibration
Maintain instrument logs
Report instrument problems
"The program includes an activities associated with each major element of the SEMP (O&M, QA/QC, data validation) shall be prepared. Included
with this description, each activity shall have corresponding documentation and communication responsibilities defining what information is to be
recorded, where it will be filed, and the individual whom must verbally or in writing be informed of the activity results. The frequency of
scheduled activities such as preventive maintenance and QA audits shall be included. Malfunction initiated activities such as repair maintenance,
QA audits following maintenance, and operating alternative measurement methods shall be ordered or requested. The requesting person or party
shall be specified within the description.
-------
The Environmental Engineering Manager is responsible for ensuring
that the source is in compliance with all applicable rules and
regulations.
The efficient and effective implementation of a management
plan rests with the individuals assigned to the program. The
Environmental Engineering Manager supervises a department of
trained and equipped technical specialists who monitor all plant
facilities and surrounding areas, and who conduct tests necessary
to obtain sufficient data for assessing continuous compliance
with all environmental requirements.
Their qualifications and capabilities are indispensable in
carrying out a successful plan. Thus, the program is supported
by an adequately sized staff such that individuals are not
overcommitted; and the staff has training and experience that are
commensurate with assigned duties and responsibilities. Staffing
details are reviewed and revised, as necessary, by the
Environmental Engineering Manager. The following briefly
describes the position and the responsibilities of the
Environmental Engineer necessary for the day-to-day
implementation of the source continuous compliance program.
The Environmental Engineering Manager is responsible for the
following general duties: (1) ensuring that the source complies
with all environmental regulations, (2) directing the overall
activities of the Environmental Engineering Department, including
implementation of the SEMP to meet regulatory continuous*
compliance initiatives, and (3) providing corporate and
regulatory agencies with all required reports and documentation
of activities. This position also entails more detail functions
such as corporate local assistance, strategy development, system
study, promulgation of permit requirements and liaison between
source and regulatory agencies.
Tier II of the management plan involves coordination of the
source quality assurance program. The quality assurance (QA)
Coordinator is responsible for developing and carrying out all
QA/QC activities and for keeping the Environmental Engineering
Manager (Tier I Director) informed of all pertinent QA/QC
5-4
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results. The QA Coordinator directs all statistical procedures
and techniques, that will enable the source to comply with permit
requirements, in addition, the QA Coordinator plans and performs
periodic and quarterly audits of the monitoring system and
control equipment, evaluates data quality, and documents this
information in the form of reports and quality control charts.
It is the responsibility of the QA Coordinator to respond to
quality control problems and coordinate those activities with
Tier I Director. The QA Coordinator should prepare monthly and
quarterly reports summarizing the following information:
1. Emission data (reduced and validated);
2. QA audit results (periodic and quarterly);
3. CEM performance history, after last report (e.g., CEM
malfunctions, corrective action, preventative maintenance);
4. Quarterly reports; and
5. Process and open-dust VE occurrences.
This information is submitted to the Environmental
Engineering Manager for approval and distribution.
Tier III of the management plan involves daily operation and
maintenance of all monitoring and control systems. The Director
of Tier III, O&N Supervisor, is responsible for implementing QA
activities (e.g., alignment checks, daily zero/span of the
instruments, maintenance of necessary spare parts inventory,
etc.) specified in the permit and in source SEMP. In addition,
the O&M Supervisor is responsible for all manual sampling (e.g.,
source sampling, performance specification testing, accuracy
audits, etc.). Table 5-2 summarizes the quality assurance
responsibilities associated with each tier of the management
plan. The Environmental Engineering Manager (Tier I Director)
should develop a table which establishes program participants,
name, title, and responsibilities.
Organization of participants and activities is one of the
most important functions of a properly operated system.
Personnel should be delegated duties which they can proficiently
complete. The SOP manual should define all QA/QC, maintenance,
data validation and reduction, documentation and communication
5-5
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TABLE 5-2. RESPONSIBILITIES OF TIER I, II, III
IN A SOURCE MANAGEMENT PROGRAM
Tier I and H
Manager, Environmental
Engineering and QA Coordinator
Document source control
performance corrective action
QA plan and purpose
Control management system
Quality planning
Training
Emission control monitoring
system budget and cost
Audit procedures
Data validation and verification
Quality report to corporate
management and regulatory
agency
Tier II and m
QA Coordinator and O&M
Supervisor
Corrective action
Control equipment and CEM
quality control
Monthly and quarterly reports to
Tier I coordinator
Periodic and quarterly audits of
emission control program
Tierm
O&M Supervisor
Preventative and schedule
maintenance
Data reporting
Calibration of pollution control
equipment
Document control for fugitive
cuntiol program
Sample collection
Fugitive control coordination
5-6
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activity responsibilities and personnel assigned (job category
and by name) each of these responsibilities.
5.3 SOURCE RECORDKEEPING PLAN
A plant specific recordkeeping program should be designed to
provide the level of useful information with a minimum amount of
personnel resources to complete the necessary checks and
paperwork. A plant recordkeeping program should contain five
basic items. They are:
1. . Equipment record;
2. Inspection checklist;
3. Baseline logbook;
4. Control system logbook; and
5. Equipment maintenance/work order.
5.3.1 Equipment Record
Equipment record involves the cataloging of all equipment
used in the control of both point and fugitive lead emissions
from the source, thus enabling periodic review of information
when needed to compare design specifications to permit
conditions.
In general, a centralized filing and retrieving system is
preferred. However, in small operations, an office, with a
bookshelf of the operating manuals, accompanied by drawings and
blueprints is satisfactory. As plants get larger, however, the
number of manuals and specifications that need to be maintained
becomes very large and a more sophisticated storage and retrieval
system is needed. In these situations, a "catalog" system works
well where"documents are given a file number for later retrieval.
The catalog can consist of cards kept in a filing system
according to process or control equipment grouping. The catalog
may be further subdivided into major subassembly groups. To
locate the necessary data, one must locate the major grouping and
subgroup, obtain the file number, and then go to that file
location to obtain the necessary data.
A variation in this procedure is to list all major
components and subassemblies under a category either on paper or
by computer. Again, all that is necessary is to look up the
5-7
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major heading and then the subcategory to find the appropriate
file number. In fact, either system allows the addition of basic
design information in the catalog that might save time and effort
in finding the appropriate file.
The equipment record should be kept up-to-date. If
modifications to a system are made (e.g., changing the number and
size of tubes in a multicyclone) this information should be
reflected in the equipment record. Old or out-of-date
information should be removed from the system and either placed
in a dead file or discarded.
5.3.2 Inspection Checklist
Inspection checklist provides a record of specific
inspection points to be performed by the source operator. These
inspection points have been selected as primary indicators as to
the overall performance of the control equipment and program to
ensure compliance with emission limitations. The inspection
check list provides numerical information along with a narrative
of the findings, so a corrective course of action can be
selected.
Outlined below are basic inspection parameters which must be
evaluated for each control equipment as part of a source specific
operation and maintenance program for the permit condition.
5.3.2.1 Multicvclones. The multicyclones are the least
complicated control device. There are two limiting factors:
l. Plugging; and
2. Gas volume through control device. •
The .performance of a multicyclone is closely tied to the
volume of gas passing through it. The following parameters
provide information on the performance of multicyclones:
1. Pressure drop;
2. Temperature;
3. Fan motor current; and
4. Dust discharge operation.
5.3.2.2 Baghouses. All baghouses rely on the same method
of operation to remove particulate matter from the gas stream.
The fabric filter of the baghouse provides the support material
5-8
-------
for the establishment of a dust layer or dust cake that performs
most of the filtration. During operation, this dust layer
increases in thickness and, thus, increases pressure drop across
the fabric filter. Periodically the dust cake must be removed by
the cleaning system, which may be categorized as either pulse
cleaning, reverse air, or shaker. The low energy systems (shaker
and reverse-air) require low air-to-cloth ratios (4 to
12 acfm/ft2). All fabric filters are sensitive to the process
operation and dust characteristics. As such, the records
obtained must be coordinated with appropriate process data.
The list of operating and maintenance related data and
records that may be used is limited. Although the data are
limited, the information provided is very useful in evaluating
performance and maintenance considerations. These data include:
1. Pressure drop;
2. Temperature;
3. Opacity;
4. Fan motor current;
5. Bag replacement location.
5.3.2.3 Venturi Scrubbers. The most commonly employed
scrubber for the control of particulate matter emissions is the
venturi scrubber. Even within the classification of venturi
scrubber there are several different design types: circular
throats, rectangular throats, and fixed and variable throat
designs. Although there are a number of different designs, the
basic operating principles remain the same.
A number of parameters are available to monitor scrubber
performance and some even used to control scrubber operation.
The records associated with these operating and maintenance
parameters include:
1. Pressure drop;
2. Water flow rates (recirculation, makeup and blowdovm);
**, pH of scrubber liquid;
4. Temperature;
5. Solids content of recirculated scrubber water;
6. Solids removal from settling tanks or ponds;
5-9
-------
7. Fan motor current;
Maintenance
1. Nozzle replacement;
2. Throat replacement or adjustments; and
3. Pump impeller wear.
5.3.3 Baseline Logbook
The baseline log is a set of records of pertinent operating
parameters of the equipment. The fundamental principle of this
log requires the source operator to document the comparison of
observed values of the control equipment with site-specific
baseline data. Operators record these values at specified
intervals and chart them to document performance. By comparing
the present value with the baseline value obtained during
compliance, the operator can evaluate the effectiveness of the
system. As illustrated in Figure 5-1, the observed value is
plotted against the baseline data. By developing the graph, the
user is able to document performance, therefore enabling the
observer to develop possible reasons for deviation from the
baseline value.
The principle of baselining is that control device
performance diagnosis is most accurate when observed operating
conditions are compared with site-specific baseline data. The
specific "historical" data implicitly take into account the
numerous subtle factors which can influence emissions (see
Figure 5-2). Baseline assessments avoid the errors potentially
introduced by extrapolation of published literature values to a
given facility.
Control device instruments and field measurements are
sometimes subject to error; therefore, baseline diagnosis is
based on sets of data comparisons rather than reliance on just
one parameter. Even when some of the data is unavailable or
suspect in quality, it is still possible to reach meaningful and
accurate conclusions using the remainder of the data.
The purpose of baselining is to rapidly identify significant
changes in performance and the possible reasons for the changes.
The technique does not necessarily provide definite evidence of
5-10
-------
en
l
1
CO
0>
t
o
2
to
CD
3
2
1
9/1
Baseline Values
i* Observed
> Values
9/2
9/3
ft-
9/4
T
Acceptable
Range
i
*
Figure 5-1. Baseline data for Unit No* 1 of baseline
-------
o
a*
S
oc
70
60
50
40
30
20
10
May
Lower Umfc 21,9
June
July
August September
Figure 5-2. Baseline data within control limits
5-12
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noncompliance with regulations, nor does it necessarily provide a
specific list of the repairs required.
5.3.4 Control Monitor Logbook
A control monitor logbook should be maintained for each
piece of lead emission control equipment used at the facility.
All activities related to the control system (maintenance,
calibration, etc.) should be recorded on the logbook form, as
illustrated in Table 5-3. Each entry in the logbook should
include the date, a brief description of the activity performed,
as outlined in Chapter 4, and the individual's initials.
If corrective action is needed, then a problem communication
memo is completed, as illustrated in Table 5-4. This, then, is
submitted to the operation and maintenance (O&M) supervisor for
corrective action. The O&M supervisor should maintain these
records chronologically in a three-ring binder. This provides
documentation on when a problem was first detected and the need
for corrective action to resolve the problem.
5.3.5 Equipment Maintenance/Work Order
Once the pollution control equipment has been inspected, it
may require additional adjustments or maintenance to return it to
baseline conditions. To assist sources with their operation and
maintenance programs, the work order has been established as a
tracking system. As illustrated in Figure 5-3, the work order is
divided into three parts. Part I addresses the initiation of the
activity, indicating that maintenance has been requested*
Part II assists the plant in the scheduling of maintenance
personnel-to address the deficiencies of the control system.
Finally, Part III provides space for reporting the activities
performed, if any action was taken to correct the problem, or
whether further action is required (and scheduled).
For example, in a baghouse, if a broken bag was suspected of
causing increase in opacity, a work order might specify that the
cause ot the increase opacity should be found and removed. Then
during a short outage, maintenance personnel would be scheduled
to repair the unit. If they found the cause was a broken bag,
they would remove the bag, possibly replace it, note its
5-13
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TABLE 5-3. CONTROL MONITOR LOGBOOK
DATE
ACTIVITIES OR MAINTENANCE
BY
5-14
-------
TABLE 5-4. PROBLEM COMMUNICATION MEMO
From:
To:. •__
Date:
Problem Definition &
Recommendat ion
Signed
Corrective Action Taken
Completion Date
Signed
5-15
-------
TMOUILI MfPORT/WOftX KfQUIST
Figure 5-3. Source equipment maintenance and work order.
5-16
-------
location, and document on the work order. If some other cause
was found (e.g., overload of hoppers, improper cleaning of bags),
these would be recorded as well as any additional maintenance
performed or scheduled for a later date. Lastly, work orders can
be sorted several ways for accounting purposes. They can be
sorted by labor craft, equipment type, process, and by type of
problem. Whether done by hand or computer, the work orders can
summarize the results of a preventive maintenance plan by showing
if failures are occurring "randomly" or if the maintenance and
corrective maintenance are not addressing the proper causes of
problems. The cost of such problems would also be available to
estimate the cost of changing the preventive maintenance program.
5.4 SOURCE MEASUREMENT PLAN
Source measurement plan involving baseline inspection
techniques have been developed to assist both Agency and source
operators with the periodic and systematic inspection of a source
emission control program to determine its effectiveness to
achieve continuous compliance regulatory objectives. The
fundamental principle of source measurement plan involves the
comparison of observed values with site-specific baseline data in
the source emission control program. This enables the subtle
changes of control program elements to be average over a period
of performance, thus avoiding the error of extrapolation of data
from a single observation to a compliance determination.
Baseline diagnosis involves a set of data comparisons rather than
comparison of single observations. This approach enables
determination of control program effectiveness to be based upon
many parameters, even when a single important observation cannot
be acquired. By observing many parameters, changes in control
equipment performance and possible reasons for these changes can
possibly be identified.
Baseline inspection involves characterization and
nb«50T-vatJon of both process and control equipment. Visible
emission observations of ventilation systems, auxiliary equipment
inspection, process equipment evaluation, storage pile
maintenance and records review are all part of the baseline
5-17
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inspection program. The operation characteristics and
performance of each of these systems is unique unto itself. As
process variables and control devices change over time, the
performance decreases. Baseline inspection involves comparison
of present operating conditions against historical baseline
levels for that visit. Consequently, these changes can be
identified, enabling the source to implement control measures to
insure continuous compliance. Each variable which has shifted
may signify a symptom of possible operation problems.
5.4.1 Levels of Inspection
The levels of inspection are designated at 1 through 4 with
Level 4 being the most intense.
5.4.1.1 Level 1. Level 1 inspection is usually limited to
records review and visible emission evaluation. It is a field
surveillance tool intended to provide incomplete indication of
compliance status. The source personnel makes visible emissions
observations on all stacks, ventilation equipment, storage piles
and outside facilities which can be properly observed. Level 1
inspection requires a minimum of time and manpower. Utilizing
Federal Reference Method 9 and 22, proper observations are made.
5.4.1.2 Level 2. Level 2 inspection by plant personnel
involves determination of compliance by inspection of current
control device and process operating conditions utilizing
installed meters and charts in addition to visible emission
observations taken during Level 1. This level of inspection
includes the observation of operating conditions by plant
personnel~and comparing to unit specific baseline data. It also
includes a review of existing records and logbooks on source
operations, particularly for the intervening period following the
last inspection.
5.4.1.3 Level 3. Level 3, a thorough and time-consuming
inspection, is designed to provide a detailed engineering
analysis of source compliance using actual measured operating
parameters by the source operator such as pressure drop, fan
static pressure and current, gas stream temperature, pH of
scrubber, flue gas conditions, oxygen level, and water flow
5-18
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rates. The measured data are reduced and used to calculate flue
gas volume, superficial velocity, specific collection area, inlet
velocity, air-to-cloth ratio, hood inlet volume and velocity,
liquid-to-gas ratio, throat velocity, etc. Because many of these
are control device and source specific, they must be adjusted to
the individual source being inspected.
There are two major purposes for this type of inspection:
1. To establish baseline operating conditions; and
2. To verify whether the source is experiencing O&M
problems that result in less than continuing compliance with the
emission standards.
The inspection may also include an internal inspection of
the control device. For fabric filters, an internal inspection
is required to determine bag condition or integrity of the
baghouse. For scrubbers, an inspection of the condition of the
nozzles is required if the water flow rate or pressure data
indicate the possibility of pluggage. A periodic internal
inspection of mechanical collectors is required where the
collection of abrasive dust is likely to cause abrasion-induced
failure.
Because this level of inspection requires the monitoring of
equipment conditions and, in some cases, an internal inspection,
the plant coordinator must be sure that all safety requirements
are met prior to entry. In all cases, lockout procedures should
be used and applicable safety equipment employed.
In a typical application, the source inspector may record
such process items as feed rates, temperatures, raw material
compositions, process rates, and such control equipment
performance parameters as water flow rates, water pressure, and
static pressure drop across baghouse. The source inspector could
then use these values to determine any significant change since
the last observation or any process operations outside normal or
permitted conditions, particularly when coupled with the
aforementioned records check.
5-19
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A significant change in operating conditions could require
that the source upgrade the inspection to a Level 4 involving a
stack test or other methods to verify compliance.
The basic type of equipment necessary to perform a Level 3
baseline inspection is listed below.
Fugitive Emissions
Stopwatch
Method 22 field observation data sheet
Control Equipment
Method 9 field observation data sheet
Tape measure
Stopwatch
Differential pressure gauge
Pilot tubes
Velometer
Thermocouples
pH paper/meter
Combustion gas analyzer (O2/CO2/CO)
Process
Flow chart
Production schedule
5.4.1.4 Level 4. The Level 4 inspection prepares an actual
emissions baseline for the source through the use of a stack test
or visible emission evaluation. This inspection requires that
the source inspector monitor all process and control device
operating parameters during a stack test for use during future
inspections. The Level 4 inspection is typically applied to
sources with baghouses or wet scrubbers needing compliance
emission data. The inspection may require documentation of
control equipment conditions through the use of an internal
inspection before the stack test.
5.4.2 Activity Associated with Levels of Inspection
The purpose of the increasing level of inspection is to
concentrate the resources on those sources that have the greatest
potential to exceed the emission limits. For instance, initial
results of the Level 1 inspection may indicate that specific
5-20
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sources are not experiencing deficiencies in performance and,
therefore, do not warrant a higher level of inspection. In these
cases, the frequency or level of inspection may be adjusted
downward consistent with the results of the Level 1 inspection, •
as illustrated in Table 5-5.
5-21
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TABLE 5-5. ACTIVITIES ASSOCIATED WITH LEVELS OF INSPECTION
Comfooeal
Lmll
Level 2
UvelJ
Uvel4
Bagbouaea
Method 9 obwrvetktt
Visible etitaion spikes
Structural corroayv
High wttkMe aoRds in discharge UM
Racorda review of bag failure and
Obwrve pressure drop acroes bagbouw
uiing installed meters
Ot>ierv« inlet/outlet gas temperatures
Obwrve tolid discharge area
Preuure drop acroes lw(bou«e
lolei/ortlrt |M teoopentniM.
Conodoa of fabric filler and Aea
Inlet/outlet oiyfeo cixf^nlrnioa
Fedenl Reference
Method Ste« .
Wettcrubben
Ptamg color and din
Dropku •djaceatto *uck
Stnidunu cotitMHM
Obaerva acnibber liqu'id turbidity and pH
Obwrve pietaun drop acron acrubbcr
Obanva Kquid diacliafte area
Obauv* phm» color and dinMntioa*
Method 9 obauvatioa
Scrubber liquid turbidity and pH
Structural corrnaioai
Pkot travena of tnlrt/onrtrt
Liquid flowrate
Fedenl Reference
Method 5 tea
Ventilation
Method 22 obtervatk*
PMHwaofventilatioatyatMi
lodiacharfe
Corroaion problema
AirbiUacintproMemi
Obwrva poakioai of intake to difchaife
Obwrve visible emiuion* around doon,
hatchet, enclowrei, etc.
Ul
I
to
M
Method 22 obwrvatioa
Stalk prenure check
Oap diManet betweea hood and
duel ayatera neaaored/verified
Temperature of faa atreaai at duct
Flow rate cakulatioa
Method 22 obwrvation
Cyclonea/inuliicjrclonea
Method 9 obwrvation
AccumulatkMofdMlui
vicioiry of stack
Sttttdnral corroaion
Obwrve presaure drop acroaa cyclone
Obwrve vuibk embsioaa
Obwrve aofid diachaif* area
Stalk preuure acroaa eyclona
Intel faa flowrate
Inlet/outlet oxygen cooceatntion
Federal Reference
Method 5 teat
Storafepilet
Method 22 obwrvation
Records review of OAM
praeticaa
Obwrve viaMa emissions
Revkw fugitive dust
program
Method 22 obwrvation
Review of ftif itive dual
nimmization profimm
Samptiiuj of pilea for awiatun and
tilt content
Method 22 obwrvation
Sampling of pikt for moiMure,
aih and lead content
Paved/uapaved roada
Method 22 obaervalion
Review of AifiUve dual
ninhniyation program
Traffic panema
Obaerva traffic pattern
Obwrve viaible«
Method 22 obwrvatio*
Sample of roada for chemical
analyaia
Method 22 obwrvation
Sampk of road for chemkal
analytii
-------
6.0 AGENCY CONTINUOUS COMPLIANCE PROGRAM
6.1 INTRODUCTION
Implementation of an effective continuous compliance program
requires a concerted effort on the part of both the regulatory
agency and the major lead emitting sources. Section 5.0 provided
guidance on the development of source a SEMP. This chapter
describes steps that can be taken by an air pollution regulatory
agency to ensure that these measures are implemented and
maintained.
In general terms, the regulatory agency's role in a
continuous compliance program is first to define in clear and
enforceable terms the requirements that must be followed at each
facility and, once these requirements are put into place, to
conduct a compliance oversight program that ensures that these
requirements are met. Section 6.2 below describes the general
framework for such a program.
Although the definition of requirements is based on the
agency's regulations, the facility's permit is the major vehicle
for translating agency requirements into specific enforceable
measures to be taken at each facility. Development of
enforceable terms and conditions in the permit is therefore
critical to a successful program. In addition to defining the
emission standards to be met, the permit must also spell out the
measures that must be taken by the permittee to ensure compliance
with these standards on a continuous basis. Section 6.3 suggests
an approach for incorporating operational and maintenance and
associated recordkeeping requirements into the facility's permit.
An important aspect of this approach is the use of parameter
monitoring as a tool for continuous compliance monitoring of flue
gas emissions and fugitive emissions. Section 6.4 provides
guidance on parameter monitoring requirements to be included in
facility permits.
6-1
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6.2 PHASED APPROACH TO COKTINUOUS COMPLIANCE IMPLEMENTATION AND
OVERSIGHT
The main objective of an agency continuous compliance
program is to ensure that all sources come into compliance with
applicable requirements and maintain compliance. The major tools
available to the agency include:
1. Enforceable regulations and permits;
2. Compliance inspection authorities;
3. Authorities to require continuous emission monitors
(CEM's) and visible emission (VE) observations;
4. Recordkeeping and reporting authorities; and
5. Enforcement authorities.
Effective use of these tools to achieve implementation of
continuous compliance programs at lead smelting and lead-acid
battery recycling facilities can often be best accomplished by
initiated a multiphase compliance approach, consisting of the
following:
Phase I. Definition of the facility's continuous compliance
requirements in the terms and conditions in the facility's
permit, including requirements for performance specification
testing of continuous emission monitors (CEM's) and control
equipment evaluation. Additionally, preparation of a source
emission minimization program describing the specific steps
proposed by the permittee to maintain continuous compliance (as
explained in Section 6.3) from point and fugitive source
emissions;
Phase II. Observation of performance specification testing
of the installed control monitoring systems and control systems
baselining;
Phase |II. Review of the baselining testing report, with
final approval or disapproval. If approved, information from the
testing will be incorporated in the facility's SEMP; and
IV. Review of the source emission minimization
program submitted by the permittee, with final approval or
disapproval.
6-2
-------
Phase I involves the preparation of a permit that clearly
states all of the enforceable requirements applicable to the
facility. The permit is the foundation for the facility's
continuous compliance program. It provides requirements for the
facility in specific, enforceable terms and conditions. It is
therefore extremely important that enforceable technical
standards and monitoring, operation and maintenance, and
recordkeeping and reporting requirements be provided in the
facility's permit. It should be recognized, however, that it is
not always possible or desirable for the permit writer to include
specific requirements for all of the necessary components of a
comprehensive continuing compliance management program into the
permit, particularly for compliance measures that rely heavily on
management practices at the facility, such as may be needed to
ensure continuing compliance with fugitive emission standards.
As an alternative to numerous specific requirements, it is
recommended that the permit writer require that the permittee
develop and submit for agency approval a source emission
minimization control program that defines the specific measures
that comprise the facility's continuous compliance program.
Under this approach, the permit includes a compliance schedule
for development, submittal, and implementation of a SEMP that
provides a clear plan for achieving and maintaining continuous
compliance with the permit terms and conditions. The lack of an
approved SEMP would not provide a "shield" for the permittee from
enforcement actions over the failure to comply with all of the
terms and conditions in the permit.
The permit should also identify the emission points where
continuous emission monitors are to be employed, and require that
specification performance testing be performed (Phase II).
Agency staff should observe the testing. The performance test is
then submitted to the agency for review and approval (Phase III),
under a schedule provided in the permit. In addition, all
emission control programs are performance tested to verify their
effectiveness in lead emission reduction. Once approved, the
measurement parameters provide the "baseline" against which
6-3
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compliance will be measured and therefore should be included in
the facility's SEMP.
In Phase IV, the agency reviews the source emission
minimization program submitted by the permittee to determine
whether it meets the requirements spelled out in the permit. The
plan should incorporate the results of the Performance
Specification Test, and demonstrate that the proposed compliance
measures are adequate to maintain all emission sources, control
equipment, and monitors within acceptable ranges identified
during the test. When approved, the SEMP provides a "blueprint"
for compliance at the facility. The plan will greatly facilitate
subsequent compliance oversight activities conducted by the
agency, including review of reports, records reviews at the
facility, and inspections.
6.3 INCLUSION OF PLANT SPECIFIC OPERATION AND MAINTENANCE AND
RECORDKEEPING PRACTICES IN A SOURCE PERMIT
Given the wide range of point sources and fugitive emissions
at lead emitting facilities, the preparation of terms and
conditions governing each facility's continuous compliance
program poses a major challenge to the permit writer. Permits
should identify all regulated emission sources and the emission
standards to be met for each source. However, continuous
compliance with the emission standards requires that the
permittee conduct a range of activities requisite to meeting
these standards on a continuing basis, such as proper operation
and maintenance of control and monitoring equipment, good
housekeeping practices, sound recordkeeping and reporting
practices and implementation of clear management controls at the
facility. Therefore, the scope of an effective permitting
strategy must extend well beyond simply specifying the emission
standards' to ensure that all necessary components of a continuous
compliance system are implemented by the permittee. An
rffc^tivc permitting strategy calls for a permit that includes
the following components, at a minimum:
1. Identification of every emission source at the facility
that is regulated under the permit;
6-4
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2. Specification of the emission standards to be net by
each source;
3. Compliance monitoring requirements for each source;
4. Recordkeeping and reporting requirements for each
source;
5. Operation and maintenance requirements for each source;
and
6. A requirement for submittal of a SEMP.
6.3.1 Identification Of All Process and Fugitive Sources
Regulated Under The Permit
The permit should identify unambiguously all emission
sources that are to be regulated as outlined in Chapter 3.
Examples of such sources at primary and secondary lead smelters
are summarized in Tables 6-1 and 6-2 respectively. While the
numbers and types of sources requiring regulation must be
determined on a facility-specific basis, it is important that
every potential source be carefully evaluated prior to the final
permitting decision. Each regulated source should be identified
as specifically as possible in the permit, including identifying
all emission streams of concern 'and ancillary equipment and
operations associated with these sources. For example, a blast
furnace at a primary lead smelting facility which has a known
emission control system installed may be identified in the permit
as:
Blast Furnace with Maximum Charge Rate of One Hundred Tons
Per Day. Primary (Smelt) Emissions Capture and Control
System consists of Hooding, a Gases Incinerator, Serpentine
Cooling Loops, Ductwork, Fan and 12,000 Square Foot Cloth
Area Four-Compartment Baghouse. Secondary (Sanitary)
Emissions Capture and Control System consists of a Charging
Hood, Slag Tapping Hood, Ductwork, Fan and 4,000 Square Foot
Cloth Area Single Compartment Baghouse. Metal Tapping
Emissions Capture and Control System consists of a Tapping
Hood, Ductwork and 4,000 Square Foot Cloth Area Single
Compartment Baghouse (shared with the Reverberatory
Secondary (Sanitary) Emissions Capture and Control System).
rtonprocess fugitive emission sources at the facility,
including materials storage piles and roadways, should also be
identified as specifically as possible. If the permitting
strategy calls for requiring that materials handling be limited
6-5
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TABLE 6-1.
POTENTIAL EMISSION SOURCES AT PRIMARY LEAD
AND THEIR CONTROL PROGRAMS
SMELTERS
Source
On-site transportation
of feedstocks
Storage of feedstocks
Sinter machine
Blast furnace
Settler
Dross kettle
a^6ftO CftSUfiC
-
Specific Activity
Movement of feedstocks by truck or rail car
Unloading/handling operations
Storage
MUing/pelletizing
Sinter machine loading/unloading
Sintering operation
Sinter breaker, crushers, screening
Sinter product storage
Blast furnace charge preparation
Blast furnace charging
Blast furnace operation
Blast furnace discharging
Settler discharging •
Slag cooling
Slag granulating
Slag storage
Kettle operation
Dross reverberatory furnace
Slag and dust storage
Casting operation
Type(s) of
emissions
Open dust fugitive
Open dust fugitive
Open dust fugitive
Process fugitive
Process fugitive
Flue gas
Process fugitive
Open dust fugitive
Open dust fugitive
Process fugitive
Flue gas
Process fugitive
Process fugitive
Process fugitive
Process fugitive
Process fugitive
Open dust fugitive
process fugitive
Flue gas
Process fugitive
Open dust fugitive
Flue gas
Process fugitive
Type{s) of
controls^)
1
1
1,2
1,2
1,2
3
1
1
1
1,2
3
2
1,2
1.2
1.2
1.2
1
1.2
3
1.2
1
3
1.2
(1) Key: 1 - Management controls
2 «• Fugitive emission capture and control devices
?. •« Flue gas emission control devices
6-6
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TABLE 6-2. POTENTIAL EMISSION SOURCES AT SECONDARY LEAD
AND THEIR CONTROL PROGRAMS
SMELTERS
Source
Scrap receiving and
preparation
Reverberator? smelting
Refining
Specific activity
Battery breaking
Dross/residue crushing
Rotary /tube sweating
Reverbermtory sweating
Charging
Smelting operation
Discharging
Smelting furnace
Type(s) of
emission
Open dust fugitive
Open dust fugitive
Process fugitive
Flue gas
Process fugitive
Flue gas
Process fugitive
Process fugitive
Flue gas
Process fugitive
Process fugitive
Flue gas
Type(s) of
controls
1
1
1.2
3
1,2
3
1,2
1.2
3
1,2
1.2
3
(1) Key: 1 - Management controls
2 - Fugitive emission capture and control devices
3 «• Flue gas emission control.devices
6-7
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to designated areas, the areas should be specifically named
(e.g., "Lead Ore Concentrate Storage Bin," or "Railroad Car
Unloading Area"). As discussed below, for new facilities or
facilities where the permitting strategy calls for the permittee'
to develop a fugitive dust control plan as part of a facility
SEMP, the permit may use more general terms such as "Areas
Designated in SEMP for Storing Lead Ore Concentrate" or "Roadways
at the Facility Designated in the SEMP for Hauling Lead-Bearing
Materials".
6.3.2 Emission Standards to be Met for Each Source
The permit should very precisely state the emission
standards applicable to each source. For process sources, the
standards may be stated in terms of mass rates and/or visible
emission standards and should address both flue gas emissions and
fugitive emissions. The standards should be as specific as
possible in terms of the types of emissions regulated and the
stages in the production process to which the standards apply.
For example, for the blast furnace used in the example above,
emission standards might be stated as:
1. The exhaust from the blast furnace primary (smelt)
baghouse shall meet the following requirements:
a. Particulate matter emissions shall be emitted at a
concentration not to exceed grains per dry
standard cubic foot of exhaust, as measured by
Method 5 of Appendix A of 40 CFR 60, or any
equivalent method approved by the Director;
b. Opacity shall be less than percent, as
determined by Method 9 or Method 22 of Appendix A
— of 40 CFR 60;
c. A continuous opacity monitor shall be operated and
maintained consistent with the requirements
contained in Parts 60.7, 60.11, and 60.13. and in
Table 1-1 of 40 CFR 60.
2. The exhaust from the blast furnace secondary (sanitary)
baghouse shall meet the following requirements:
a. Particulate matter emissions shall be emitted at a
concentration not to exceed grains per dry
standard cubic foot of exhaust, as measured by
Method 5 of Appendix A of 40 CFR 60, or any
equivalent method approved by the Director; and
6-8
-------
b. Opacity shall be less than percent, as
determined by Method 9 of Appendix A of 40 CFR 60.
3. Dust collected by each baghouse and underneath cooling
loops shall be handled so that the dust will be
completely enclosed during removal and transfer.
Emissions escaping from dust handling equipment shall
not exceed percent opacity, as determined by Method
9 of Appendix A of 40 CFR 60, excluding Section 2.5
therein.
4. Visible emissions escaping from the blast furnace and
blast furnace primary (smelt) capture system equipment
shall have an opacity less than percent, as
determined by Method 9 of Appendix A of 40 CFR 60.
5. Visible emissions escaping the capture system for blast
furnace charging shall not exceed percent opacity
when charging the furnace, nor percent when the
furnace is not being charged, as determined by
Method 22 of Appendix A of 40 CFR 60, excluding Section
2.5 therein.
6. Visible emissions escaping the capture system for blast
furnace slag tapping shall not exceed percent, as
determined by Method 22 of Appendix A of 40 CFR 60.
7. Visible emissions escaping the capture system for blast
furnace metal tapping shall not exceed percent, as
determined by Method 22 of Appendix A of 40 CFR 60.
It is generally not feasible to state emission standards for
fugitive emissions from material storage and handling areas, and
from roadways at the facility, in mass rate terms. Therefore,
the standards must usually be stated in terms of visible
emissions citing either Method 9 or 23. For certain sources, it
may be appropriate to provide an operational standard as well,
such as a requirement that the material be kept wet at all times
or that it never be stored in areas exposed to the atmosphere.
For example, for fugitive emission standards from material
storage piles the emission standards might be stated as:
Roadways at the facility designated in the facility's source
emission minimization program shall be kept wet at all times
r? that no visible emissions emanate from the roadway.
6.3.3 Compliance Monitoring Requirements for Each Source
The permit should include specific requirements for measures
to be taken by the permittee to monitor compliance. The term
6-9
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"compliance monitoring" in this context refers to monitoring both
direct compliance with the applicable emission standards for the
source and monitoring the range of O&M activities that must be
conducted to ensure that emissions are kept within allowable
limits. This comprehensive definition of compliance monitoring
applies to both point sources and fugitive emission sources.
For point sources controlled by scrubbers or baghouses,
compliance monitoring should involve the use of continuous
emission monitors in the outlet stack, where feasible, as well as
control equipment (and process) parameter monitoring to ensure
proper operation of the control equipment. Performance
specification testing is necessary to determine the baseline set
of parameter values that will result in compliance with emission
standards applicable to the source. The permit conditions
should be written in a manner such that operation of the
equipment outside of the acceptable range above and below the
baseline value, as determined by the performance specification
test and approved by the regulatory authority, constitutes
noncompliance. Section 6.4 provides additional guidance
regarding performance parameters for control equipment used at
primary and secondary lead smelters.
If data from performance specification testing of CEMS and
emission control systems through parameter monitoring acceptable
to the regulatory agency are provided in the permit application,
specific operating parameters may be designated in the permit.
In many cases, however, acceptable performance testing will not
be completed prior to permit issuance. In these cases, the
permit should include requirements for conducting the test and
submitting the results to the regulatory agency for review and
approval. Based on these results, the agency can establish
enforceable performance standards and include them in the
facility's requirements through modifying the permit or by
requiring them to be included in the facility's SEMP. For
example, the permit might state:
6-10
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For the 4,000 square foot cloth area single compartment
baghouse, the Permittee shall submit to the Director, within
days of the effective date of this permit, the results
of performance specification testing, sufficient to develop
a performance baseline of the baghouse compared with the
following operating parameters:
1. pressure drop;
2. temperature;
3. opacity; and
4. fan motor current.
The Permittee shall notify the Director at least seven days
prior to conducting the performance specification test.
Based upon the results of the test, the Director will
determine the acceptable range of each parameter and will
notify the Permittee in writing of this finding. The
Permittee shall record each parameter on a daily basis and
shall include in the facility's source emission minimization
program measures to be taken in the event that any parameter
that is outside the acceptable range determined by the
Director.
For sources where compliance will be monitored with
continuous emission monitors (OEM's), the permit should include
at least the following CEM requirements:
1. Maintenance, calibration, and operation in accordance
with State agency requirements, 40 CFR 51 and (where applicable)
40 CFR 60;
2. Excess emission reports (EER's) submitted to the
Director every quarter;
3. Certification of the CEM's;
4. Emission measurement data tabulated and recorded daily;
5. Tabulation of 30 day rolling averages;
6. Maintenance of quality assurance/quality control
requirements;
7. Continuous operation of 90 percent operating time;
8. Reporting of percentage down time to the Director; and
9. Daily zero/span drifts checks and corrective action
program if exceeds acceptable ranges.
For fugitive sources, major control options are dependent on
maintaining good housekeeping practices as discussed in
Chapter 3.0. As explained in Chapter 3, there are two generic
approaches for monitoring compliance for these types of sources:
6-11
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(1) recordkeeping; and (2) indirect performance measurement based
on sampling and analysis of the source materials. Under the
first approach, compliance is confirmed by maintaining records
documenting that management measures, such as spraying roadways
in accordance with schedules approved by the regulatory agency,
are being maintained. Under the second approach, performance
measurements, such as analyzing roadway materials to determine
whether they have sufficient moisture content, is used. Under
either approach, the permit should state the requirements for
compliance monitoring. If the permitting strategy calls for
requiring the submittal of a Monitoring Plan as part of the
facility's SEMP, the permit can state this requirement by
reference to the Plan, such as:
For roadways designated in the permittee's approved SEMP,
the permittee shall maintain a compliance monitoring program
in accordance with that Plan.
6.3.4 Recordkeeping and Reporting Requirements for Each Source
Accurate and timely recordkeeping and reporting is critical
to an effective continuous compliance program. For every
regulated source, the permit should specify recordkeeping
requirements, including the types of records to be maintained and
the frequency of recording. For example, for air pollution
control devices, the results of parameter monitoring should be
recorded on at least a daily basis and should include the
following types of data, at a minimum:
1. Malfunctions/exceedances;
2. Preventative or corrective maintenance performed;
3. Zero/span calibration results, including the recording
of zero/span check values versus time; and
4. Recorder review.
For fugitive emission sources, the permit should include
requirements that recordkeeping be conducted to verify that
tnawarrpTnamt practices that are necessary to meet the technical
standards of the permit (e.g., keeping roadways wet at all times,
daily sweeping, etc.) are conducted under the schedule that is
stipulated in the permit an as discussed in Chapter 3. If
6-12
-------
sampling and analysis of source materials for lead content is the
method used to verify compliance (see below) the sampling
records, analytical results, and QA/QC records should be
maintained to a level of detail enabling a compliance inspector
to trace the samples from point of origin through analysis.
Reporting requirements should also be stipulated in the
permit. As a minimum, these requirements should include
submitting EER's to the regulatory agency every quarter and
reporting noncompliance that could endanger public health within
24 hours of discovery.
The permit should clearly describe the recordkeeping and
reporting standards applicable to each source at the facility, to
a level of specificity that ensures their enforceability. The
specific content and format of records and reports can be
described in the facility's SEMP. It is particularly important
that the permittee conducts an aggressive quality
assurance/quality control (QA/QC) program to ensure the accuracy
of results and documentation. In a well-written permit,
inaccurate recording or reporting constitute noncompliance,
therefore providing the basis of an enforcement action by the
regulatory agency. The implementation of an effective QA/QC
program, as detailed in the permittee's SEMP, greatly reduces the
likelihood of noncompliance.
6.3.5 Operation and Maintenance Requirements for Each Source
The permit should specify O&M requirements for each'source,
including requirements on source operations, air pollution
control devices and parameter monitoring equipment. The permit
should establish the standards to be met in the O&M program, and
should specify the types of O&M measures to be taken, frequency
of these activities, and recordkeeping requirements to confirm
that O&M is being conducted as required. Specific O&M measures
can be established in the facility's SEMP, the permit should
establish the standards to be met for the O&M program. The
following example illustrates the definition of such standards:
The Permittee shall maintain and operate the 4,000 square
foot cloth area single compartment baghouse to prevent any
6-13
-------
malfunction or breakdown of the system. A daily inspection
of the unit shall be conducted to check overall operating
performance to ensure continuous compliance, to inspect all
parameter monitoring devices, to record parameters as
measured by these devices, and to perform routine
maintenance to prevent any malfunction or breakdown of the
system. The daily inspection shall be conducted in
accordance with the Permittee's approved SEMP.
6.3.6 A Requirement for Submittal of a Source Emission
Minimization Plan fSEMPl
It is extremely important that enforceable technical
standards, management practices, operation and maintenance
procedures, and recordkeeping and reporting requirements be
specified in the facility's permit. It is not always possible or
desirable for the permit writer to include all of the specific
components of a comprehensive continuing compliance management
program in permit terms and conditions. Compliance measures that
rely heavily on management practices at the facility, such as may
be needed to ensure continuing compliance with fugitive emission
standards are particularly difficult to address generally.
To the extent that a compliance management plan can be put
into place that is both compatible with existing practices at the
facility and sufficient to ensure compliance on a continuous
basis with the terms and conditions in the permit, it may be
advantageous to both the permittee and to the permit writer for
the facility manager to prepare such a plan. Under this
approach, the facility's permit includes requirements for the
development and submittal for agency approval of a SEMP under a
schedule provided in the permit. During the interim period prior
to approval of SEMP, the facility would be obligated to meet all
of the terms and conditions in the permit. The permit would
provide detailed specifications of the SEMP, which should include
at least five components:
1. Management Plan;
2. Engineering Plan;
3. Measurement Plan;
4. Reporting Plan; and
5. Implementation Plan.
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The details of each of these SEMP components are facility-
specific. However, the requirements should be spelled out in the
permit in sufficient detail to ensure the development and
implementation of an effective plan. These requirements are
described in the following sections.
6.3.6.1 Management Plan. The purpose of the Management
Plan is to define staff.member's roles and responsibilities in
the facility's proposed continuous compliance program, the chain
of command under the program, and management procedures to be
followed to the extent that these procedures are not provided in
other sections of the SEMP. The Plan should be very specific in
describing responsibilities that each person has in the program
and their authority in carrying out these responsibilities, as
illustrated in Chapter 5.0.
The Management Plan should include all facility personnel
whose jobs and responsibilities can impact compliance. This
clearly includes those who have direct responsibility for
compliance management, such as persons designated to inspect
pollution control and management equipment. It is equally as
important, however, to include other facility personnel whose
responsibilities include activities that can indirectly affect
compliance of the facility with the permit, such as production
personnel who need to know their responsibilities in the event of
an upset that could degrade emission control equipment and
materials handlers who need to understand their obligations in
minimizing fugitive emissions. While every facility's Management
Plan will-be unique, the following types of information should,
at a minimum, be provided in the Management Plan:
1. A description of the organization of the facility's
continuous compliance program, describing the specific
responsibilities and authorities of each person participating in
the program, should be provided. The chain of command should be
aescnoed, including an organization chart.
2. The Manager, Environmental Engineering, responsible for
ensuring continuing compliance with the facility's permit should
be designated, and a description of duties and authorities
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provided. All alternate Managers, Environmental Engineering that
may be designated for each production shift and/or as substitutes
for the designated facility Manager during his/her absence should
also be identified.
3. The facility's Quality Assurance (QA) Coordinator should
be designated, and a description of duties and authorities
provided. The Management Plan should demonstrate that the QA
Coordinator has the responsibility and authority to report QA
audit findings directly to the corporate or company management.
4. Job descriptions for every position at the facility
related directly to compliance activities (e.g., inspectors,
pollution control maintenance personnel, etc.) should be included
in the plan. The descriptions should provide a clear delineation
of duties, and include by reference those sections of the SEMP
for which individuals in these positions are responsible. For
example, one of the duties of personnel in the position of O&M
supervisor might be spelled out in the job description as
"Responsible for inspecting, recordkeeping, and reporting on all
parameter monitoring devices as prescribed in the Measurement
Plan;"
5. For every other position involving responsibilities that
are relevant to maintaining facility compliance (production
staff, materials handlers, security staff, etc.), a description
of obligations under the SEMP should be provided. This component
of the Management Plan is particularly important, because it
clearly delineates the relationship between the facility's
environmental obligations and the production and environmental
control activities. For example, production staff may be
responsible for reporting malfunctions of fan motors for fugitive
emission hoods immediately to the O&M supervisor, or security
staff may be responsible for ensuring that haul trucks drive only
on designated roadways at the facility. A delineation of these
responsibilities will help reduce the potential for
misunderstanding.
6. Procedures for reporting the results of inspections and
operation and maintenance activities to the Manager,
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Environmental Engineer, should be described. The Plan should
provide for immediate notification of appropriate facility
personnel in the event of malfunctions or breakdowns of process,
monitoring, or air pollution control equipment that could affect
compliance.
6.3.6.2 Engineering Plan. The engineering plan describes
all of the emission sources regulated under the permit;
identifies specific technical, operational, and management
controls that the facility proposes to put into place to meet the
emission standards prescribed in the permit; and demonstrates the
effectiveness of these controls under the range of conditions
under which they are to be used.
For the agency, the plan provides the information required
to make a determination regarding the appropriateness of proposed
emission controls, their capability to achieve the applicable
standards. It also provides the agency with a clear
understanding of the technical parameters and management measures
that are critical to continuing compliance, thus providing a
basis for the implementation of an effective compliance oversight
program.
For the permittee, the plan provides in unambiguous terms
the specific technical measures that must be taken under the
facility's permit, thus reducing the potential for
misunderstanding in negotiations between the regulatory agency
and facility personnel. It can also be a valuable tool 'for
training compliance personnel and for providing them with a clear
understanding of the necessary procedures for maintaining
compliance.
The plan should address every emission source regulated
under the facility's permit, including point sources and fugitive
emission sources. The specific types of information to be
included will vary for each facility and for each specific
emission source at the facility. In general, the information
must be sufficiently detailed to demonstrate that the proposed
control measures for each source are technically sufficient to
ensure that the standards in the permit applicable to each source
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will be met, can be implemented on continuing basis, and are
specific enough that compliance can be monitored effectively by
the agency.
The types of information that should be provided include, at
a minimum:
1. General facility information. The engineering plan
should provide a clear overview of the operations at the facility
that are important to the facility's continuing compliance
program, including a general description of the materials flow at
the facility, an identification of the location and size of every
source regulated under the permit, and the production history of
the facility. The types of information should include, at a
minimum:
a. A process flowchart as illustrated in Chapter 3, showing
schematically the flow of lead-bearing materials at the plant.
The flowchart should trace the movement, handling, storage, and
processing of these materials from initial transportation to the
facility through final processing and offsite transportation of
products and residuals. This should include materials flow in
flue gases, indicating the volumes of materials expected to be
captured by emission control devices and indicate how the
captured residuals are to be managed. The flowchart should
indicate the average and maximum design capacity of each storage,
process unit and emission control unit.
b. A facility map that clearly indicates the location of
every point and fugitive emission source that is proposed to be
included in the Engineering Plan.
c. A summary of the production history of the facility,
including a summary of the volumes and types of feedstocks and
products managed annually.
d.. Operating schedule for the facility (daily and weekly).
2. Proposed controls for every regulated process source.
I"w*. ««cl* process source, the plan should address both flue gas
emissions and fugitive emissions in sufficient detail to .
demonstrate that employment of the proposed controls under the
conditions described in the plan will attain compliance with all '
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applicable standards. For each process source, the plan should
include, as a minimum:
a. A complete description, including engineering drawings,
of each process unit (e.g., blast furnace, sinter machine, etc.),
including associated ductwork and ancillary equipment (e.g.,
hoods for fugitive emission capture, etc.) and access ports for
maintenance and performance monitoring.
b. For each process unit, relevant operating parameters
obtained from manufacturers, that could effect emission rates
(e.g., for blast furnaces—maximum and average production
capacity, frequency and size of charging, operating temperature
range, etc.)*
c. A detailed characterization of emissions from each unit,
and results of any studies to quantify and characterize flue gas
and fugitive process emissions.
d. Specific control measures to be taken for each process
emission source, including the control of flue gases and process
fugitive emissions. For flue gas sources, this would include
providing the results of the Performance Specifications Test
report and a description of the procedures that will be taken to
ensure that the process unit and associated control device will
be operated within the boundaries established during the test.
The air pollution control device should be fully described in the
plan, including: manufacturer, age, design operating temperature,
model, and capacity.
e. For fugitive emissions, the Plan should describe the
equipment-and procedures that will be used to maintain compliance
at all times. For example, the control strategy for fugitive
emissions during charging of the blast furnace as outlined in
Chapter 3 at- the facility might involve the capture of emissions
with hoods and control of capture emissions with a baghouse.
The Plan should describe in detail the proposed procedures that
»r* *:~ be followed by production personnel during the charging
operation to ensure that the charging of feed materials and
operation of capture devices are operated within the same range
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of operating conditions as those used during the Performance
Specifications Testing and documented through baseline
evaluation.
3. Proposed controls for every regulated nonprocess source.
For nonprocess fugitive dust sources, including product and waste
storage piles, roadways and transfer areas, the plan should
provide for each source.a description of emissions, and a
detailed description of the emission controls that the facility
proposes to meet the emission standards prescribed in the permit.
For each source, the plan should include at a minimum:
a. A source description should be provided. For storage
units, this should include engineering drawings of the unit,
including emission control devices if applicable, the maximum
storage capacity of the unit, and a description of materials
handling operations. For roadways, a description of the roadway
materials, the types of vehicles that use the roadways, and
average and maximum traffic (e.g., number of trucks per day).
b. For each source, a description of specific controls to
be employed should be provided. Control options for nonprocess
fugitive emission sources are generally more dependent on
housekeeping and operational practices than on the use of
emission control devices. The plan should clearly describe the
specific measures that will be taken, and include all data that
has been developed by the facility to demonstrate the
effectiveness of the proposed measures. Examples of the'types of
controls for these sources were fully described in Section 3.0 of
this document.
For roadways and transfer areas, one control option is to
designate roadways and materials handling areas that are to be
used for transporting and handling of charge or raw materials.
If this option is proposed, the plan should include the onsite
enforcement procedures that will be used to ensure that these
restrictions are followed. If surface cleaning is proposed as
discussed in Chapter 3 (e.g., vacuuming for paved roads; sweeping
and/or watering for unpaved roads), the Plan should specify the
frequency of these operations proposed to maintain compliance
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travelled areas designated for transportation or handling of
lead-bearing materials, this nay require that surfaces be kept
wet at all times. For undesignated roadways/areas, the frequency
proposed for cleaning and/or watering should also be specified,
although it does not necessarily have to be as frequent as for
designated roadways/areas (e.g., twice daily).
For storage areas, the Plan should describe management
controls to be maintained during materials handling. Examples
include performing all handling operations in fully enclosed
areas, or alternatively, applying stabilization agents to
materials while they are being handled and/or using physical
controls to minimize emissions to the ambient air during storage
(e.g., storing all materials in fully enclosed bins, using wind
screens at all times, or keeping open piles covered at all
times).
6.3.6.3 Measurement Plan. The measurement plan describes
the specific types of monitoring practices, including monitoring
devices, that will be used to measure the performance of each of
the emission controls proposed in the Engineering Plan and the
steps that will be taken at the facility to ensure that these
practices are effectively maintained on a continuing basis. For
flue gas emission control devices (i.e., baghouses or scrubbers),
the Measurement Plan should be based on parameter monitoring, as
described in Section 5.0 of this document. For fugitive emission
sources, the measurement approach may involve recordkeeping,
indirect performance measurement based on sampling and analysis
of source.materials or visible emission observations employing
Reference Method 9 or 22.
1. Flue era a emission control devices. Results of the
Performance Specification Test, provided in the Engineering Plan,
will provide a baseline for measuring the performance of
baghouses or scrubbers. The Measurement Plan should therefore
remonstrate that a parameter monitoring program will be
implemented that can effectively monitor the performance of the
control device against the baseline control limits on a
continuing basis. This includes a detailed description of each
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continuing basis. This includes a detailed description of each
monitoring device and data demonstrating the effectiveness of the
device, recordkeeping and internal reporting procedures, and
quality assurance/quality control (QA/QC) procedures to ensure
the integrity of the data. As a minimum, the plan should include
the following types of information for every regulated emission
source:
a. The complete Performance Specification Test report,
including descriptions, specifications, and locations of all
monitoring devices.
b. A description of the operation and maintenance program
to be implemented to ensure the integrity of monitoring
instruments on a continuing basis, including troubleshooting
procedures when malfunctions are found. The proposed schedule
for routine maintenance should be included that lists daily,
weekly and monthly checks of each maintenance item.
c. A description of all records to be kept and the
frequency with which they are to be recorded, as specified in the
permit. Copies of all standardized forms to be used should be
provided in the plan. The results of all zero and span checks of
instruments should be maintained on a control chart showing
zero/span check values versus time. Examples of the types of
recordkeeping to be performed include:
- Monitor logbooks that provide documentation of
inspections and maintenance performed for each monitor. _ Each
entry of the logbook should include the date, a brief activity
description, and the inspector's initials.
- Calibration forms that document when monitor calibrations
are performed and whether adjustments are made to correct the
monitor operation.
- Precision assessment forms that document the QA
Coordinator periodic calculations of the precision of the
TTi^.crlng system.
- Audit forms documenting the independent monitoring audits
conducted periodically by the QA Coordinator.
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- A description of the QA/QC procedures to be used.
Examples of the kinds of procedures that should be addressed in
the Measurement Plan include:
- Procedures to be used to determine the accuracy and
precision of all data.
- Data validation and reporting procedures to be used for
emission calculations, including permittee's proposed criteria
for validation.
- Data validation and reporting procedures to be used when
monitoring devices are in a state of breakdown or are
malfunctioning out of control (e.g., when excessive span drifts
and errors in relative accuracy are found). QA procedures in the
Measurement Plan should define criteria for determining when a
monitor is considered to be malfunctioning.
- Independent audit procedures to be carried out by the
designated QA Officer.
2. Process fugitive emission sources. The measurement
plan should describe in detail the procedures proposed for
monitoring the performance of systems for capturing and
controlling fugitive emissions from process sources. Since it is
generally not possible to measure the rate of emissions from
these sources, the basis for measurement will have to be
observation of visible emissions utilizing such methods as
Reference Method 22, parameters that indicate the performance of
capture and control devices (e.g., fan motor currents for capture
hoods), and/or recordkeeping to confirm that operation and
maintenance activities are performed in accordance with the
schedule in the plan (e.g., inspection and repair of sinter
machine doors). The specific activities to be monitored should
be in accordance with the standards prescribed in the permit
(e.g., visible emission standards, operation limitations,
maintenance requirements).
The plan should clearly describe the procedures to be used
for ensuring that plant operating procedures and equipment
prescribed in the Engineering Plan for minimizing process
fugitive emissions are maintained at all times. It should
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describe the schedules and types of inspections of process
operations and controls to be performed, and corrective actions
to be taken if problems are identified as identified in
Chapter 4.0. The plan should provide for documentation of
findings and any required corrective actions should be recorded
in an inspection logbook.
Operation and maintenance measures and schedules should also
be provided in the plan. All operation and maintenance
activities should be documented in a logbook that is maintained
for each process source.
3. Nonprocess fugitive emission sources. For nonprocess
fugitive dust sources, including product and waste storage piles,
roadways and transfer areas, the plan should describe the methods
to be used to monitor compliance. The plan shall demonstrate
that the proposed methods are sufficient to ensure maintenance of
compliance on a continuing basis. There are two generic
approaches for monitoring compliance for these types of sources:
(1) recordkeeping; and (2) indirect performance measurement based
on sampling and analysis of the source materials. Under the
first approach, compliance would be confirmed by maintaining
records documenting that management measures included in the
Engineering Plan are conducted in compliance with the schedule
and the technical conditions stated in the Engineering Plan. For
example, if the Engineering Plan calls for controlling roadway
emissions by daily sweeping and spraying as outlined in •
Chapter 3.0, the Measurement Plan may require that a recording be
made in a-logbook of the times and locations of each
sweeping/spraying operation and that each entry be initialled by
the operator. Any operational anomalies, such as a breakdown in
cleaning or watering equipment, should also be recorded, and
documentation of contingency measures taken should be made. In
accordance with the management plan, the designated Manager,
Siivliufuuental Engineering should inspect the logbook arid initial
it to confirm that compliance verification has been performed.
For sources where the proposed compliance monitoring
technique is sampling and analysis of source materials, the
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Measurement Plan should indicate the sampling locations,
frequency, and techniques, the analytical methods, QA/QC
measures, and records to be maintained. Sampling of road surface
material generally involves the collection of a composite sample
from each road segment being analyzed. For paved roads, samples
must be collected across the width of the travel lane using a
portable, stick-type vacuum cleaner with tared collection bags,
while for unpaved roads, a whisk broom and dust pan is used in a
similar fashion. For sampling of aggregate materials, samples
from storage piles should be collected from the top, middle, and
bottom of the piles.
If the Engineering Plan calls for control of fugitive
emissions from aggregate storage by maintaining a minimum
moisture content in materials prior to storage, an alternative
sampling approach would be to collect samples from the process
flow. In all cases, sampling should be documented in a logbook,
stating at a minimum the date, time, and locations of sampling,
volumes of material taken (if required in the Engineering Plan),
and confirmation that samples were handled in accordance with the
QA/QC requirements of the Measurement Plan. The person(s)
conducting the sampling should initial the logbook.
The Measurement Plan should include a method for tracking
the samples through completion of the analysis. Analytical
methods should be specified, and should include measures to
ensure the integrity of the samples, such as keeping samples in
sealed containers until analysis and ensuring that holding times
specified..in the plan are met. The analytical methods to be used
should be included in the Plan.
6.3.6.4 Reporting Plan. The facility's SEMP should include
procedures for meeting the reporting requirements specified in
the permit. The types of reports in this plan should include
both regularly scheduled reports and reports on unanticipated
aveni-ec. «v.ch as malfunctions. Examples of the types of reports
that may be required include:
1. Continuous emission monitor system upsets and
malfunctions;
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2. Control system malfunctions,;
3. Excess emission reports for process, fugitive and point
sources;
4. Visible emission reports from fugitive sources; and
5. Process equipment breakdowns or shutdowns that result in
noncompliance with emission standards;
If standardized reporting forms are to be used, the forms
should be included in the plan. For nonroutine reporting, such
as reporting of monitor or control system malfunctions as
outlined in Chapter 5.0, the criteria proposed by the permittee
for determining when to file such reports should be provided.
6.3.6.5 Implementation Plan. The SEMP should describe the
specific steps to be taken to implement each set of activities
laid out in the plan, including schedules for completion of each
significant milestone. Examples of items that may need to be
included are:
1. Hiring of personnel to fill positions proposed in the
Management Plan;
2. Training of personnel as required to assure
implementation of the SEMP, such as operation and maintenance
procedures for production and emission control equipment,
recordkeeping and reporting requirements, sampling and analysis
procedures, and QA procedures; and
3. Acquisition, testing, and deployment of equipment.
6.4 PARAMETER MONITORING PERMIT CONDITIONS
Parameter monitoring provides an important tool to source
operators.and agency personnel in the number of ways, including:
1. Ac a guide to arriving at an optimum maintenance
schedule;
2. As a diagnostic tool capable of detecting/preventing
malfunctions;
3. As a performance guideline;
i. As a process optimization guide;
5. As a way of assuring that appropriate corrective action
has been taken in the event of malfunction;
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6. As a means of assuring considerations in future designs;
and
7. As a tool for assessing compliance on a continuing
basis.
When properly managed, a parameter monitoring program can
provide a high degree of assurance that compliance with
applicable emission standards will be maintained on a continuous
operational basis. "Proper management11 means not only proper
operation and maintenance of monitoring equipment, but also the
employment of a management system that involves appropriate
recordkeeping, performance evaluation, and response in the event
of significant changes in monitoring results.
The preceding section provided guidance for including
requirements in the facility's permit for the development and
implementation of a SEMP to ensure proper management of
compliance-related activities for all regulated sources at the
facility. A critical component of such a plan is the
establishment of an effective parameter monitoring system for air
pollution control equipment. Given the importance of parameter
monitoring at lead smelting and lead-acid battery reclamation
facilities, additional attention to the factors that should be
considered in implementing and overseeing compliance with
requirements for a parameter monitoring system is warranted.
This section therefore provides a summary of parameters that
the facility should be required to include in its continuous
parameter monitoring program. The focus is on parameter
monitoring- systems for baghouses and scrubbers. More details on
the technical aspects of implementing a parameter monitoring
program have been previously discussed in Section 5.0 of this
document. A* brief review is provided here to emphasis the
importance of parameter monitoring as part of a facility's SEMP.
6.4.1 Fabric Filters
F~r fabric filters, the parameters that should be included
in the continuous monitoring requirements of the facility's
p&nnit should include, at a minimum:
1. Pressure drop;
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2. Temperature;
3. Opacity;
4. Fan motor current; and
5. .Dust removal system operating checklist.
In addition to these parameters, which should be monitored
on a continuous basis, the permit and/or the facility's SEMP
should call for the documentation of periodic inspection and
maintenance activities for each fabric filter unit, including bag
replacement records, a cleaning system operating checklist, and
maintenance records for the cleaning and dust removal system.
Pressure drop is one of the more useful parameters that can
be monitored on a fabric filter. When taps are provided for the
inlet and outlet static pressure, the pressure* drop across the
bags provides an indication of the resistance to gas flow and a
relative indication of bag cleanness. Therefore, permit
requirements calling for monitoring and recordkeeping of pressure
drop data are extremely important.
Larger, multicompartmented fabric filters equipped with
shaker, reverse air, or plenum pulse cleaning may be equipped
with continuous strip chart recorders for overall recording of
pressure drop. These charts are useful for diagnostic
confirmation that each compartment is isolated for cleaning. As
each compartment is isolated, the pressure drop should increase
and as it is returned to service the pressure drop should
decrease. The charts also provide a useful tool for compliance
inspectors to determine filter performance and compliance with
maintenance schedules.
Temperature limitation is one of the most important
characteristics of the fabric filter. The potential to operate
the fabric filter above the maximum allowable fabric temperature
can cause concern about fabric life. The loss of fabric
integrity may result in pinholes, tears, or destruction of part
or axl of the fabric in the bags.
Temperature indicator/recorders should be located to measure
gas temperature on the inlet of the fabric filter. Measurement
downstream of the collector may result in a false sense of
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security because bags nay be subjected to excessive temperature
although there nay be no indication of problens.
Opacity neasurenents are extrenely useful indicators of
fabric filter performance, and are a powerful continuous
conpliance nonitoring tool. As long as there are particles in
the 0.2 to 0.8 nicron range to scatter light, the gas strean will
be capable of exhibiting opacity if there are problens within the
fabric filter. The opacity neasurenent can be used to determine
the presence of bag leaks and, if analyzed carefully, the
neasurenents can also identify the rows or conpartnents where the
leaks nay be occurring.
Opacity nonitors should be used to record data on a "real-
tine" basis and not a 6-minute average for at least one conplete
cleaning cycle once per day. The presence of spikes should be
correlated with conpartnents or rows of bags if they are present
on the strip chart recorder.
Fan notor current provides an indication of the gas volume
being noved through the exhaust systen. Since there is a
relationship between fan notor current (and horsepower conputed
fron the fan notor conditions), where nore current neans nore
energy and (usually) nore gas volume through the systen, it is a
sinple procedure to obtain a relative indication of gas flow.
It is inportant to note that density changes in gases (e.g.,
changes due to gas tenperature variations) will influence the fan
notor horsepower use. Cooler gas strean density causes an
increase in the required fan notor horsepower to equivalent
volumes of'gas. Therefore, conparisons of fan notor current nust
be normalized to sone reference tenperature.
Fan notor paraneters provide confirming data when combined
with fabric filter pressure drop. The facility's paraneter
nonitoring plan should provide for data on fan notor current to
be obtained whenever pressure drop is recorded. Plant personnel
can men use the combined data to determine the degree of bag
blinding or the presence of pinhole leaks, tears, or excessive
gas flow that could lead to noncompliance with the emission
standards defined in the permit.
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Dust removal system operating checklists can be used to
check operation of the system. Fabric filter that do not return
captured dust directly to a bin or silo are usually equipped with
hoppers that need some method of removing the captured dust from •
the fabric filter. Unless equipped with manual dust removal, the
dust discharge system should be checked periodically. Because it
is generally recommended that dust discharge systems be operated
on a continuous basis, the finding of items such as stopped
conveyors or airlocks on the dust discharge will usually indicate
that there is some sort of a problem.
A periodic check of the quantity of dust being removed from
the fabric filter is helpful, since any gross variation from
normal quantities would indicate problems. Alternative methods
of evaluating performance include weighing material discharged or
measuring the conveyor drive motor current.
6.4.2 Venturi Scrubbers
Parameters that should be included in the facility's
continuous compliance monitoring requirements are:
1. Pressure drop;
2. Water flow rates (Recirculation, makeup, and blowdown);
3. pH;
4. Temperature;
5. Solids content of recirculated scrubber water; and
6. Solids removal from settling tanks or ponds.
Note that, unlike fabric filters, opacity is not an.
operating parameter to be monitored because wet plume
characteristics typically interfere with proper transmissometer
operation. In addition to these parameters, which should be
monitored on a continual basis, period inspection and maintenance
records, including nozzle replacement, throat replacement or
adjustments, or pump impeller wear should be documented.
Pressure drop is one of the most useful operating parameters
Lo L« iUwaitored. To be most useful, the pressure drop should be
monitored across the throat of the venturi scrubber and not
across the entire scrubber train (presaturater, scrubber, and
separator). Pressure drop is the parameter monitored and used to
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control the operation of variable throat scrubbers (opening and
closing the throat as needed with constant water flow rate). It
is also one of the first parameters available to indicate
problems in scrubber operation. Use of continuous chart
recorders is recommended.
Water flow rate is the second most useful parameter in
monitoring scrubber operation. Unfortunately, it is difficult to
monitor due to limitations in monitoring equipment. Orifice and
venturi meters are subject to wear and buildup from suspended
solids in the water that changes meter calibration. The same
problem can occur in rotameters; turbidity problems also make
reading of the meter very difficult. Ultrasonic meters are
usually noncontact devices and are not subject to the wear
problems associated with these other meters. However, they are
very expensive and generally do not handle shocks well. In
addition, special maintenance is required. A potential
alternative to these techniques is to monitor pump motor current
to monitor flow indirectly. However, on all but the largest
pumps the horsepower requirements are low and subtle differences
between power input may be difficult to distinguish.
In addition to scrubber water flow rate, the makeup to
and/or blowdown rates of water from the scrubber system should
also be monitored. This is important to the solids buildup rate
and amount of evaporative losses in the scrubber. Given the
problems of monitoring water flow rates, it is particularly
important that a QA program that includes routine calibration of
flow meters be required. Calibration should be conducted at
least once a month.
The pH monitoring is rarely needed in many of today's
scrubber applications. The use of pH monitoring is typically
limited to carbon steel scrubbers that are susceptible to acid
attack and to applications where gaseous emission control is part
oi en* scrubber's function. The pH monitor helps operators
maintain the proper pH to limit corrosion or to operate in the
most effective absorption range for the scrubber. Generally, pH
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monitors require a substantial amount of maintenance to remain
operational. Most successful applications of pH meters for
continuous monitoring employ sidestrearn monitors where only a
small portion of the flow is monitored rather than the total
water flow 'through the scrubber.
Gas temperature, including gas before and after the
scrubber, is an important indicator of scrubber operation. Water
loss by evaporative cooling may account for 5 to 10 percent of
the total water flow in high temperature application. This may
cause an increase in emission rate if the solids levels are high
in the scrubber water.
The inlet temperature is important since high temperature
gas streams may contain components that are gaseous until cooled
into the scrubber. These materials may form in particle size
ranges that are difficult to capture. The outlet temperature can
be used to determine if saturated conditions are being achieved.
Temperatures higher than saturation usually indicate
maldistribution of gas and/or water within the scrubber.
Solids content of scrubber water is an indicator of the
extent to which resuspension and regeneration of particulate
matter into the gas stream due to excessive solids levels is
occurring. Periodic samples of scrubber water should be
collected, particularly when little blowdown of scrubber water
occurs. Buildups of 5 to 10 percent dissolved solids can occur
•
and cause significant problems with opacity and, in some cases,
erosion of scrubber components. Weekly grab samples should be
considered, minimum for sampling from the scrubber sump return.
Solids removal from settling tanks or ponds should be
monitored by recordkeeping. Part of the operation of a scrubber
involves the-settling and removal of solids captured by the water
droplets. Although automatic clarifier systems exist, most
scrubbers use settling ponds that have to be emptied manually
Cvr-.:r.lly draining and removing sludge with a front-end loader).
Each time the pond is cleaned, it should be noted in the
operating records to establish representative operation. In this
way the representativeness of a stack test may be determined if
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the scrubber was operated with clean water and a clean setting
pond.
6.4.3 Control Equipment/Paramater Monitoring Permit Review
Checklist
Implementation of an effective continuous compliance program
requires a permit that provides clear and enforceable terms that
outline management and program source objectives. In addition to
defining the emission standards to be met, the permit must also
spell out the measures that must be taken by the permittee to
ensure compliance with the standards on a continuous basis.
Parameter monitoring plays a major role in the Agency continuous
compliance program. The main objective of the Agency's
continuous compliance program is to ensure that all sources come
into compliance with applicable requirements and maintain
compliance. To assist the permit writer/Table 6-3 provides a
permit review checklist to minimize noncompliance incidences as
part of the Agency's continuous compliance program.
6.5 PERMIT FOLLOWUP AND RENEWAL
6.5.1 Introduct ion
The basic goal of the permit writer is to provide a tool
that insures the long-term continued compliance and protection of
the environment. The permit does not guarantee compliance with
emission standards and may not provide the "real-time" picture of
a source's compliance status. As part of an agency's continuous
compliance program, the permit is the initial step to compliance.
For continued compliance, the agency must rely on other tools in
conjunction with the permit to help achieve continuing
compliance. These include source inspections, performance tests,
emission reporting and data tracking and handling systems. These
tools are part of an integral process of which permit review and
writing is only one part of the overall process.
A distinction must be made between whether the permit is a
"new" or modified permit. The distinction between the two is
that a new source will not have an operating history of a
baseline established, whereas an existing source will. For the
new source, performance testing and inspection provide a time to
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TABLE 6-3. SOURCE PERMIT REVIEW CHECKLIST
Component
Potential malfunction problem
Permit review check to minimize noncompliant incidence*
Baghouse
Leaking bags
Bag blinding
Dust buildup in hopper
Will the air to cloth ratio be lew than 15 to 1 ft/min?
Can the outside of the baghouse be reached via caged
ladder or, preferably, steps, for inspection and maintenance?
Is the baghouae equipped with a manometer or magnehelic
gauge to monitor pressure drop?
Can the baghouse be entered easily for bag inspection
and repair?
Is inlet air properly baffled from bags?
Will an opacity monitor be installed for continuous
compliance application?
Is the system equipped with a high pressure alarm?
For pulse or reverse air cleaning systems, is the air
line equipped with dryer and fitter?
Are outdoor baghouses properly insulated?
Is the system equipped with electrical interlock so that
one cleaning cycle is completed and hopper is cleared after the
process and blower is shut down?
Is the system accessible for bag inspection and repair?
Is the dust handling system sized to handle the maximum
expected load?
Do hopper walls have a 55 to 60 degree slope?
Fan
Insufficient air volume
due to fan wear
Can fan amperage, rpm, and static pressure be easily
monitored?
Are the fan blades accessible for inspection and
replacement?
(If the (an is on the dirty side of the control device, a
straight blade centrifugal fan should be used.)
Is fan meter accessible for routine inspection and
maintenance?
Ventilation
system
Deposition of dust and
duet plugging from
insufficient flow in
by
— Improper system balance
— Leakage through holes in
the duet
Is the system designed to maintain a velocity
of 3400 ft/min in all duett?
b the system design balanced with respect to
pressure drop?
Are the branch ducts equipped with ports to
check static pressure?
If blast gates are used to balance system, does
the design inhibit adjustment by untrained
personnel?
Do the ducts have provisions for access for
cleaning, especially at gates and entries?
Excessive wear of ducts and
control devices from high
transport velocities in some
branches
Is the system designed to keep duct flows
below 4400 ft/min?
Is the system design balanced with respect to
pressure drop?
Can "high wear" sections be easily replaced?
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TABLE 6-3. SOURCE PERMIT REVIEW CHECKLIST (continued)
Component
Cyclone
Weticnibber
r— _
Storage pile*
UnptveoVpaved
rofcds
Potential malfunction
problem
Reduced efficiency due to
insufficient flow
Updraft of air through
dust outlet causing
reduced flow through
cyclone and
raentrainment
Cyclone or hopper plugging
Corrosion and erosion of
scrubber shell
Nozzle damage
Heat exchange failure
Low scrubber efficiency
Fugitive dust
Fugitive dust
Permit review check to minimize noncompliant incidences
Is the cyclone equipped with ports to check pressure drop
and statis pressure between fan and cyclone?
Is the cyclone accessible via stairs or caged ladder?
Is the discharge valve accessible for inspection and
maintenance?
Is the cyclone physically accessible for periodic inspection
and maintenance?
Is access available to clean plugged cyclones and hoppers?
Is the dust removal system sized to handle the maximum
expected load?
Can the outside of the scrubber be reached by earge
ladder or, preferably, steps, for inspection and maintenance?
Will the liquid feed rate system equipped with flow meter?
Can the internal components of the system be evaluated
periodically
Will the scrubber be equipped with a manometer or
magnohelic gauget to monitor pressure drop?
Will the scrubber be equipped with high pressure gauges to
evaluate water pressure to nozzles?
Will the inside of the scrubber be accessible for nozzle
evaluation?
Will the scrubber be equipped with temperature gauges on
inlet/outlet of system?
Will pH be monitored continuously?
Will the turbidity of the liquor stream be monitored?
Has the source calculated the proper liquid-to-gas ratio and
is that comparable to design specifications?
Will the scrubber be equipped with a continuous QrlCQr
analyzers at outlet?
Will the source be required to submit a dust suppressant
management plan?
Has the source proposed a backup dust suppressant system?
Will the source be required to submit a dust suppressant
management plan?
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compare actual equipment and performance with that proposed in
the application. For modifying or renewal, however, these data
are used for refinement and adjustment of the permit conditions.
Although, the underlying purposes may differ, the tools available
to the agency are the same and so is the overall goal of
continuing compliance.
4.3.1 Role of the Agency Inspection in the Permit Process
One of the major weaknesses of the permitting system is that
often the permit writer is part of an agency permit section,
while the inspector, who has the ability to "baseline* the
source, is part of the source inspection section. These two
sections rarely compare notes. The source inspection is often
the individual with the most resource concerning the day-to-day
operation of the facility.
A good Agency inspector can provide a wealth of information
to the permit writing and review process with first-hand
knowledge of processes and control equipment, operation and
maintenance procedures, source line and management personnel, and
source history (including compliance strengths and deficiencies).
As indicated earlier, this valuable resource is often overlooked.
The Agency inspector can also verify that conditions outlined in
the permit have been implemented.
It is therefore vital that the first-hand knowledge and
experience of the inspector be used to improve the permit-writing
process and to help achieve continuing compliance goals..
Inspection of a new source or modification can verify that the
capital equipment and process conditions required in the permit
are the same as those actually occurring after startup.
Combining the regulatory knowledge and engineering skills of
the permit engineer with the first-hand observations and informed
conclusions of the inspector produces a more complete and
accurate assessment of actual conditions at the source and, it is
hrpcd. n better permit.
4.3.1.1 Agency Inspection Involving New Sources. The use
of the Agency inspector in the role of a source's permit
application is most evident between new and existing permit
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considerations. The overall goal of an agency permit program
remains the same (i.e., the determining of the permit
requirements are being achieved and to assess the compliance
status of the source), the type of information needed to be
gathered is different.
Prior to startup, inspection should occur of a new source to
verify that permit conditions have been met. In particular, the
inspection should include:
1. A check to see if installed control equipment is the
same as that proposed in the application and for which the permit
was issued;
2. Insure that drawings/specifications provided in the
permit application reflect "actual" situation;
3. Insure location of any required continuous emission
monitors is concurrent with permit conditions/specifications;
4. Check to see that all instrumentation for process or
control equipment parameters have been installed and operational;
and
5. Verify establishment of a source emission minimization
program (SEMP) involving source management and maintenance
activities, and quality assurance/quality control activities to
insure data collected is of highest quality.
The initial inspection serves to gather data to establish
both baseline and representative conditions for future
references.
6.5.2.2 Agency Inspection Involving Old Sources.
Inspection^ of existing source for permit renewal should provide
up-to-date operating characteristics and operating history of the
source. This information, when combined with previous
inspections, -excess emission reports, compliance test and
periodic audits of operating conditions of control equipment and
fugitive emission programs can help the inspector make
aDorooriate recommendations to the permit writer which can be
incorporated into the "new" permit to "fine tune" the source's
operating characteristics and source SEMP. The inspection of
existing sources, therefore, should include:
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1. Observation of changes in operation that have occurred
over time;
2. Changes in maintenance practices;
3. Changes in the source SEMP program associated with
regulated emission control activities;
4. Changes in reporting requirements; and
5. Clarification of state/federal regulations
The permit renewal process allows the agency to evaluate all
aspects of the source's emission control program and relying on
previous experience, to update areas of historical weakness.
This updating clarification process may also reflect changes
in Agency policy that have occurred since the permit was issued.
Information from previous inspections and the inspection results
should be a valuable resource for the permit review engineer. In
this way, data from actual operating experience are recycled
through the system to improve the permit writing process.
6.5.3 Permit Followup Inspection Tools
Whether the permit issued is a permit to construct /operate
or a renewal permit, the contractual agreement between the
issuing agency and the source is binding for the life of the
permit. Therefore, the source must comply with the conditions
set forth in the permit at all times and under all conditions
except for those expressly granted in the permit (malfunction,
startup, shutdown, etc.)- The performance test provides a
comparison of actual emissions and operating practices w.ith the
emission limitations contained in the permit and with the
conditions. (process and control equipment) under which the
emission occurred. Regardless of the purpose of the emission
test, the results must be representative of actual operating
practices and demonstrate the capability of the source to comply
with the emission limitations under these conditions.
6.5.3.1 Stack Testing/Continuous Emission Monitor
Historically, stack testing has been used as part
of the source's initial compliance determination. As NSPS
standards developed, continuous emission monitors became a part
of EPA's compliance program for those sources required to monitor1
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their emission on a continuous basis. Historically, continuous
emission monitors have played a limited role in the regional
Stationary Source Compliance Programs. With the passages of the
1975 regulations requiring CEM's as a means of monitoring a
source's "continuous compliance" status, it has taken 15 years to
identify GEM data as an enforcement tool and bring it to national
attention. Limited application may have been contributed to
early problems with monitor reliability, accuracy, and long-term
performance. However, many of these earlier problems have been
resolved and OEM data now provides valuable information for
enforcement decisions. Consequently, the agency is increasing
its reliance upon CEM data in its permit, compliance and
surveillance programs. Eventually, CEM's will become part of all
NSPS, NESHAP and State permits.
As a means of ensuring that emission test results are actual
indicators of compliance with the emission limits, the emission
units to be reported (pounds/ton, pounds/hour, etc.) from the
emission test should be expressly cited in the permit. The
enforcement agency should exercise care to see that the source
does not report test results in inappropriate values. Where more
than one emission limit exists, reported test results should be
compared with the permit limits value by value.
The goal of continuing compliance also dictates strict
adherence to quality assurance procedures, not only to laboratory
quality assurance procedures for periodic emission testing, but
also to continuous monitoring requirements. Particular care
should be-given to examining the source's quality assurance
procedures for continuous emission monitoring data. Factors such
as precision, accuracy, frequency, reliability, quarterly audits
and data omissions with and without justifiable cause (i.e.,
malfunction, lapses in data reporting, etc.) should be reviewed.
Specific test procedures, variations from accepted test
tue^uoua, and specific operating conditions of the process and
control equipment are important parts of the performance test
protocol. The emission test protocol is a step-by-step plan by
which the emission test is to be conducted. The Plan designates
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specific process and control equipment parameters to be followed
during the test as well as actual testing procedures. Because
new sources have no operating history on which to base
representative or typical operating conditions, such conditions
may have to be estimated in the test protocol. These conditions
should be confirmed as source history develops. In the case of
existing sources, however, previous operating conditions and test
results can be used to establish a case-by-case determination of
representative conditions for each performance test.
6.5.3.2 Control Equipment Monitoring Testing. One of the
most important considerations in determining whether a source
remains in compliance with permitted emission limits on a
continuous basis is the source's ability to maintain control
equipment efficiency and related process conditions. Initial
engineering analyses conducted to determine both potential
uncontrolled and controlled emissions will most likely not
represent actual contemporary conditions at the source because of
"normal1* variations in process conditions, control equipment,
age, maintenance, and modifications. As changes occur, the
issuing/enforcement agency must be aware of the influences these
changes will have on potential emissions. So that the necessary
flexibility will be retained to determine compliance under these
conditions, emission testing must be able to accommodate changes
in the process and in control equipment efficiency. Accurate
emission testing is very helpful in correlating process -and
control equipment variances with changes in actual point and
fugitive emissions and thereby establishing grounds for future
permit modifications or permit renewal conditions.
The role of emission testing may also change as the goals of
the issuing/enforcement agency change. The permit should enable
the agency to modify the test protocol and reporting requirements
of the source in order to reflect any such changes. Source
cpcrntir.^ history, for example, may require the agency to
redefine test goals for the following reasons: (1) to
reestablish representative conditions, (2) to establish the
uncontrolled emission rates of specific process units vented,
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(3) to establish baseline conditions for proposed modifications,
(4) to determine current control device efficiency, (5) to cross-
check continuous monitoring emission results, or (6) to correlate
actual emissions with surrogate emission indicators (mass vs.
opacity, etc.)*
Finally, any emission testing program is only as good as its
documentation. Whether the emission testing is performed by the
issuing/enforcement agency or by the source, legal enforcement of
permit emission limits and conditions depends on accurate,
adequate, and retrievable documentation. Because considerable
time may elapse between actual testing and any potential legal
action or redress, proper documentation is critical.
It is the responsibility of the permit writer to ensure that
the emission limits, general permit conditions, and specific
permit, conditions be constructed in such a way as to allow the
agency the flexibility to ensure continuing compliance and to
give the source to understand exactly what is expected in terms
of its responsibility with respect to the specific permit
conditions.
6.5.3.3 Excess E|roifrsion Report Monitoring. Sources subj ect
to the requirements of using continuous emission monitors as a
compliance determination are generally required to submit
quarterly excess emission reports (EER's). The EER contains
information on number of excess emission over a standard, time
and duration of those excess emissions, reason codes for.excess
emissions and corrective/preventive action taken to reduce those
emissions._ As personnel and money limits the feasibility of
onsite inspections, the EER becomes an important "feedback"
system for both the source and the regulatory agency. The EER
becomes a tracking tool by which agency personnel can evaluate
both the control equipment and continuous emission monitor
performance. The EER provides a useful function for both the
sources being regulated and the regulatory agency. For the
source, the benefits are:
1. To help ensure upper management attention through the
formal requirement for source submittal of a summary of
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excursions. This increases the likelihood of timely attention
and reduces the risk of sanctions; and
2. As a tool in preventive maintenance/risk management/cost
control programs, to flag deteriorating process or control
equipment performance. In cases such as fuel burning, GEM data
can be used to optimize the process and control system
performance, thus saving money and preventing pollution at the
same time.
For the regulatory agency, the benefits are:
1. As a screening tool, to identify sources experiencing
frequent or continual excursions. Such sources can be subjected
to additional attention in the form of phone calls, inspections,
etc., rather than allocating scarce inspection resources largely
at random;
2. To help pinpoint specific source components for special
attention during an inspection;
3. To document the severity (e.g., duration, magnitude, and
frequency) of a source's excess emissions. For example, EER data
can provide supporting evidence of the long-term nature of
violations, negating source claims of isolated problems;
4. To document that a compliance test was performed during
"nonrepresentative" operating conditions;
5. To support issuing a "Notice of Violation (NOV)";
6. To establish a data base in the development of Agency
policies and strategies;
7. To assess "good air pollution control practices";
8. To provide a less resource intense alternative to Agency
inspections of sources; and
9. To monitor the emission and performance of a source
subject to specific permit, consent decree, or administrative
order requirements.
Data from the excess emission report can be entered into the
'Agency's Automated Compliance Data System (CDS). The CDS system
forms the basis by which EPA tracks compliance status of
regulated sources.
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In recent years, the standardized EER report has not only
been used to report excess emissions, but also other information
associated with both control equipment and monitor performance.
Such information as:
Continuous Emission Monitors
1. "Out-of-control" situations;
2. Excess drift determination;
3. Quarterly audit results;
4. Relative accuracy test;
5. Appendix f, Procedure 1, QA/QC reporting requirements;
Control Equipment
1. Average control device parameters (pressure drop, flow
rates, etc.);
2. Control equipment "baseline" information;
Fugitive Emissions
1. Observation of visible emissions; and
2. Housekeeping and operational practices.
6.5.4 Onsite Inspection to Verify Permit Conditions
The primary objectives of a regulatory agency onsite
inspection and excess emission review is to minimize air
pollution through adherence to regulations and permit
stipulations. The inspection provides the determination of
compliance and helps identify causes of excess emissions.
Because of manpower and resource constraints, the EPA has
included onsite inspections and excess emission review procedures
as part of its "Level" inspection program. Levels of inspection
have been incorporated into the Agency's stationary source
compliance program to give regulatory agencies the opportunity to
allocate inspection resources to those facilities needing most
attention. The levels of inspection extend from source agency
records review (lowest level) to stack test compliance
determination (highest level). The intensity and thoroughness of
t±.c inspection increases numerically. The type of activity
associated with each level, as outlined in Section 5.4 and
abbreviated here, are:
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Level l. Records review involving excess emission reports,
previous inspection reports, source "working11 file and permit
review.
Level 2. Onsite inspection involving review of monitoring
recordkeeping (maintenance, monitor fugitive emission logs and
control equipment logs), control fault light indicator review,
strip chart review, and review of source SEMP.
Level 3. Evaluation of source emission reductions utilizing
field instrumentation through external audit techniques and
comparison to "baseline" data.
Level 4. Comparative evaluation of installed control
program monitor indicators through performance check utilizing
Federal Reference Methods or portable instrumentation.
The purpose of the increasing level of inspections is to
concentrate the resources of the Agency personnel on those
facilities that have the greatest potential to exceed the
emission limits.
To assist the Regions in identifying these sources with
potential to violate the emission limits, the Agency has
developed a "significant violator" program. The "significant
violator" program identifies the Agency's highest priority
sources for enforcement action, other than emergency actions. In
addition, the Agency has identified sources presently without
SEMP but for which the use of SEMP could be fruitful. This could
include long-term violators and large SEMP emitters. For these
sources, the Agency has broadened its use of SEMP in its permits,
consent degrees, administrative orders, and continuous compliance
activities.
6.5.5 gMTimary
Post-permitting efforts such as performance testing, onsite
inspections utilizing field instrumentation, excess emission
report, data management systems and SEMP's are necessary to the
achievement and maintenance of the Agency's continuous compliance
goals. Whereas such activities may occur independent of the
permit review process, their effectiveness may depend on how the
permit was originally written and the degree of specificity
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included in the permit conditions. The permit writer should rely
on the actual experiences of the Agency inspector and on
performance test data for the further refinements and upgrading
of individual permits and the permit-writing procedures.
The actual process of permit review and permit construction
is not simple. It requires a knowledge of the regulations and
the ability to interpret them. It also requires the ability to
review technical data, to locate available resources of
information when needed, to draw appropriate conclusions to make
recommendations, and to write a permit with conditions that are
enforceable and meaningful and represent a balanced approach to
continuous compliance. A good permit is an important tool for
meeting various program requirements and for maintaining source
compliance. As a tool, however, it can only be as effective as
the quality of its construction.
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7.0 LEAD EMISSION CONTROL INSPECTION EVALUATION CHECKLIST
7.1 INTRODUCTION
Lead emission control inspection evaluation checklists have
been developed to assist both Agency and source operators with
the periodic and systematic inspection of a source emission
control program to determine its effectiveness to achieve Agency
continuous compliance regulatory objectives. The objective of
the evaluation checklist is to provide evaluation procedures at
different levels of intensity. As was discussed in Section 5,
the field levels of inspection are designated as Levels 1 through
4, with Level 4 being the most intense.
Level 1. Records reviewed and visible emission evaluation;
Level 2. Field observation of source's process
instrumentation and source emission minimization program;
Level 3. Field measurements of process and control
parameters and visible emission observations; and
Level 4. Performance testing utilizing Federal reference
methods.
A brief review of the levels of inspection is provided here
to emphasis there importance to both an Agency and source
emission reduction program.
7.2 LEVELS OF INSPECTION
Level 1 inspection is usually limited to records review and
visible emission evaluation. It is a field surveillance tool
intended to provide incomplete indication of a source compliance
status. The source personnel makes visible emissions
observations on all stacks, ventilation equipment and outside
facilities which can be properly observed. Level 1 inspection
requires a minimum of time and manpower. Utilizing Federal
Reference Method 9 and 22, proper observations are made.
Although fugitive dust control measures are generally
implicit in federal air quality regulations, the regulations
-------
are enforceable by either state, local, or federal air pollution
control officials. Clearly, a portion of a general air
compliance inspection should be devoted to identifying potential
sources of fugitive dust emissions and the collection of data
indicative of a source's compliance status with regard to
applicable permit conditions and regulations.
As is the case for.other types of emission sources, the
inspector should be familiar with potential sources of both point
and fugitive emissions at the plant and applicable
State/local/Federal regulations and permit requirements. Pre-
entry evaluation from outside the plant (i.e., Level l
inspection) is particularly important in regard to fugitive
sources. During this evaluation, the inspector should identify
and note any visible fugitive emissions at or near plant
boundaries and their source(s); conditions around feed, product,
and/or waste storage piles; and any other obvious sources of
fugitive emissions. Notations of any visible emissions and
photographs should be taken at this time, as appropriate.
Level 2 inspection involves the Agency inspector observing
and documenting source measured operating parameters such as
pressure drop, fan static pressure and current, gas stream
temperature, water flow rate, traffic patterns on paved/unpaved
roads, storage pile orientation, gas stream temperature and flue
gas conditions. Visible emission evaluation, utilizing Federal
Reference Method 9 and 22 are performed. The observed evaluation
of both process monitors and fugitive emission indicators are
recorded and plotted against source specific baseline data.
During the Level 2 inspection, no actual field measurements are
acquired. The inspector is utilizing onsite instrumentation in
evaluating continuous compliance.
Level 3, a thorough and time-consuming inspection, is
designed to provide a detailed engineering analysis of source
compliance by the inspector performing onsite measurements with
his instruments for operating parameters such as pressure drop,
fan static pressure and current, gas stream temperature, ESP
power levels, flue gas conditions, oxygen level, and water flow
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rates. The measured data are reduced and used to calculate flue
gas volume, superficial velocity, specific collection area, inlet
velocity, air-to-cloth ratio, hood inlet volume and velocity,
liquid-to-gas ratio, throat velocity, etc. Because many of these
are control device and source specific, they must be adjusted to
the individual source being inspected.
There are two major purposes for this type of inspection:
1. To establish baseline operating conditions; and
2. To verify whether the source is experiencing O&M
problems that result in less than continuing compliance with the
emission standards.
The inspection may also include an internal inspection of
the control device. For fabric filters, an internal inspection
is required to determine bag condition or integrity of the
baghouse. For scrubbers, an inspection of the condition of the
nozzles is required if the water flow rate or pressure data
indicate the possibility of pluggage. An internal inspection of
ESPs may be required if power data indicate a problem with ash
buildup or plate alignment. A periodic internal inspection of
mechanical collectors is required where the collection of
abrasive dust is likely to cause abrasion-induced failure.
Because this level of inspection requires the monitoring of
equipment conditions and, in some cases, an internal inspection,
the inspector must be sure that all safety requirements are met
prior to entry. In all cases, lockout procedures should be used
and applicable safety equipment employed.
The portion of the fugitive emissions inspection which is
conducted within the plant boundaries (Level 2, 3 and 4
inspections) generally consist of four phases:
1. Visual inspection of the facility in order to observe
fugitive sources and controls (including photographs to
document).
? Examination of the source's control equipment.
3. Observations of any spraying or other dust control
operations undertaken by source during the inspector's visit.
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4. Examination of the source's records relating to the
controls used.
A general checklist should be used as a reminder of key
information to be collected by the inspector during evaluation. •
This list should be refined according to the specific goals of
the inspection during subsequent visits and can be arranged in
chart formats, if desired. Also, the compliance formats
described below should be incorporated into the inspection, as
applicable.
Finally, the Level 4 inspection prepares an actual emissions
baseline for the source through the use of a stack test of source
emissions and field measurements for fugitive emissions. This
inspection requires that the inspector monitor all process and
control device operating parameters during a stack test or field
measurement for use during future inspections. The Level 4
inspection is typically applied to sources with baghouses or
high-energy wet scrubbers. The inspection may require
documentation of control equipment conditions through the use of
an internal inspection before the stack test or a chemical
analysis of process material of fuel that is being burned fe.cr..
percent sulfur, percent ash, heat content, or percent moisture).
The purpose of the increasing level of inspection is to
concentrate the resources on those sources that have the greatest
potential to exceed the emission limits. For instance, initial
results of the Level 2 inspection may indicate that specific
sources are not experiencing deficiencies in performance and,
therefore, do not warrant a higher level of inspection. In these
cases, the frequency or level of inspection may be adjusted
downward consistent with the results of the Level 2 inspection.
7.3 CHECKLIST FOR EVALUATING SPECIFIC CONTROL DEVICES
Field evaluation checklists have been developed to assist
both Agency and source operators with the periodic and systematic
inspection of a source emission control program, both point and
fugitive sources, to determine its effectiveness to achieve
continuous compliance regulatory objectives. The fundamental
principle of these checklists involves the comparison of observed
7-4
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values with site-specific baseline data from the source emission
control program. This enables the subtle changes of control
program elements to be average over a period of performance, thus
avoiding the error or extrapolation of data from a single
observation to a compliance determination. Baseline diagnosis
involves a set of data comparisons rather than comparison of
single observations. This approach enables determination of
control program effectiveness to be based upon many parameters,
changes in control equipment performance and possible reasons for
these changes can possibly be identified.
Inspection involves characterization and observation of both
process and control equipment. Visible emission observations of
ventilation systems, auxiliary equipment inspection, process
equipment evaluation, storage pile maintenance and records review
are all part of the baseline inspection program. The operation
characteristics and performance of each of these systems is
unique unto itself. As process variables and control devices
change over time, the performance decreases. Baseline inspection
involves comparison of present operating conditions against
historical baseline levels for that visit. Consequently, these
changes can be identified, enabling the source to implement
control measures to insure continuous compliance. Each variable
which has shifted may signify a symptom of possible operation
problems.
To assist the Agency and source operators in the field
inspection program/ a series of industry specific checklists have
been developed. Field inspection procedures have been developed
for:
1. Wet scrubbers;
2. Baghouses;
3. Cyclones and multicyclones; and
4. Fugitive emissions.
Lawh inspection procedure is divided into four parts to
insure that the inspector is focused at each part as to needed
information in order to determine a continuous compliance status
7-5
-------
of the source. The individual parts of the inspection procedure
are:
Part I - General Plant Information;
Part II - Process Data;
Part III - Control Equipment Data; and
Part IV - Inspection Overview.
Following are recommended field evaluation checklists
applicable at lead smelting and lead-acid battery manufacturing
facilities.
7-6
-------
FIELD INSPECTION PROCEDURES
WET SCRUBBERS
-------
PART I - GENERAL PLANT DATA
Company
Report for period
Year
Street address
City
State
Official providing information
Title of official
Furnace - company designation
Furnace permit number or NEDS
number
Furnace type
Furnace rated capacity (charge
rate)
Allowable emission rate and
opacity
PART ZZ - PROCESS DATA
A. FACILITY DATA
Type
Charging method
Control devices
Operating
schedule
D Furnace
D Other
No. of
furnaces
Specify
Batch D Continuous
Fabric collector Specify type
D Scrubber
D Other
hrs/day
Specify type
days/wk
wks/yr
WET SCRUBBERS—1
-------
B. Qparrtina Paraaaters
WET SCRUBBERS — 2
PEKOD OF RECORD
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-------
PART ZIZ - CONTROL. EQUIPMENT DATA
A. General information
Process equipment ducted to this control equipment:
Unit manufacturer:
Model no./type:
Utilized for removal of: paniculate _
organic solvents
acid gases
Type of scrubber wet
..dry
, electrofuluidized
Mode of action: gravel bed , venturi, __
spray tower , quench tower _
sieve tray .
_, flooded disk
, packed tower
Medium: water , limestone slurry
lime slurry , adipic acid
organic solvent , gravel
recirculated , once through
Demisten cyclone separator , brinks
other
, dual aklali
, sodium hydroxide
.chevron
Modules: Total no.
, No. of modules in normal operation
By Pass: Is flue gas normally bypassed
Sketch scrubber system: show CEM's locations, *P measuring points, etc.
Scrubber system sketch:
WET SCRUBBERS—3
-------
B. Control equipment evaluation
Parameter
1. Pressure drop across module, - in.t^O
2. Medium flowrate to module, gal, Ib/min, hour
3. Nozzle pressure, psig
4. Recirculation of scrubbing medium, %
5. Gas temperature, *F, inlet
outlet
6. Recycle tank medium, pH
7. Wa«ii trpy mi** eliminator,
A? in. HjO
8. Classifier reed pump discharge pressure, psig
9. Mist eliminator, aP in. H2O
10. Wash slurry to wash tray flow, gal/min
11. Recycle slurry to wall wash, flow, gal/min
12. Raw water to mist eliminator, flow, gal/min
13. Supemate to mist eliminator, flow, gal/min
14. Inlet plenum static pressure, in. HjO
IS. Bypass damper, open
closed
16. Gas bypass, %
17. Liquid to gas ratio
18. Scrubber inlet
COjt %t wet
02, %, dry
CO, ppm
SOj.ppm
Opacity, %
19. Scrubber outlet
CO2, %, wet
02, *. dry
CO, ppm
SO2, ppm
Opacity, %
Design
Actual
WET SCRUBBERS—4
-------
PART XV - INSPECTION OVERVIEW*
CONCLUSIONS/RECOMMENDATION
1. Compliance status:
2. Need for further action:
3. Corrective actions to be taken:
4. Time required to rectify problems:
5. Special waivers or review of compliance criteria required:
6. Need for follow-up inspection:
7. Inspectors signature:
Date:
Approved by:
Title:
*OTHER NOTES, COMMENTS, SKETCHES (ATTACH ADDITIONAL PAGES, IF NECESSARY).
Schematic drawings showing locations of process and dust control equipment should be prepared, particularly
so, where verbal descriptions may lead to misunderstandings. Locations should be noted for observed
leak sites, evidence of corrosion, warped panels, and other mechanical defects.
WET SCRUBBERS—5
-------
FIELD INSPECTION PROCEDURES
BAGHOUSES
-------
PART Z - GENERAL PLANT DATA
Company
Street address
City
State
Report for period
Year
Furnace - company designation
Furnace permit number or NEDS
number
Official providing
information
Title of official
Furnace type
Furnace rated capacity
(charge rate)
Allowable emission rate and
opacity
A. FACILITY DATA
Type
PART ZZ - PROCESS DATA
D Furnace
D Other
No. of
furnaces
Specify
Charging method Q Batch D Continuous
Control devices Q Fabric collector Specify type
Operating
schedule
D Scrubber
D Other
hrs/day
Specify type
days/wk
wks/yr
BAGHOUSES—1
-------
B. Qparrtin-7
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RAW MATERIALS
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-------
PART ZIZ - CONTROL EQUIPMENT DATA
A. General Information
Process equipment ducted to this control equipment:
Quantity of dust collected
Gas flow rate @ collector inlet
Gas flow rate @ collector outlet
Temperature @ collector inlet
Temperature & collector outlet
Fan speed
Capture velocity of hoods
Over furnace
Charging doors
Pouring spout
tons
afcm
afcm
•F
•F
ipiu
fpm
fpm
fpm
Static pressure in collection system
Stack
Before fan
Collector outlet
Collector inlet
Before radiant coolers
Before water sprays
Duct after hood
-H20
-H2O
•H20
"H20
"H20
•H20
-H20
DJ
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to
n
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Ul
-------
B. Collection Sv»te»(s)
Sections
1. teahouse £l /2 /3 /4
a. Manufacturer
b. Type or trade name
c. Model Mo.
d. No. of conpartments
e. Bags/compartment ~
f. Bag 1 x A
g. Total cloth area
h. Pressure drop,MH2o_
2. Fabric
a. Manufacturer
b. Material
c. Woven or felted ~
d. Operating temp, range
e. Surface treatment
o
w 3. Cleaning system
w
*? a. Method
i b. Frequency
c. Actuated by
d. Anticollapse rings_
e. Hire mesh cages
C. Dust Handling Systemfsi
1. Do baghouse hoppers have:
a. Heaters
b. Insulation
c. Level indicators
d. Vibrators
2. Type of dust transport system_
3. Fate of collected material
-------
PART ZV - OPERATING, PARAMETERS (DESIGN AND ACTUAL)
A. Control Equipment Evaluation
Design Actual
1. Flow rate
2. Pressure drop
3. A/C, gross
4. Temperature, °F
5. Efficiency, %,
6. Emission rate, Ibs/hr,
7. Opacity, %,
B. Operating Experience/Maintenance Aapeeta
1. Percent of time baghouse fully operational when process
is in operation
2. Has a detailed maintenance schedule been instituted?,
3. Is maintenance schedule as recommended by baghouse
manufacturer or by plant?
4. Are maintenance records available for inspection?_
5. How long are records kept on file?
BAGHOUSES—5
-------
C. Problem Areas
Which of the following problem areas have led to periods of excess emissions or caused the process to be
shut down?
Problem area
Insufficient dust pickup and/or
transport (fugitive emissions)
Duct abrasion or corrosion
T *«. • h- k
low
Moisture
Fan abrasion, vibration, etc.
Gross bag failure
Tnximusta Has tension
• »
Bag chafing or abrasion
Pressure lost
f 1*mina nmrhantMt
Visible emissions
Plugged hoppers
Hopper fires
Dust discharge system
Duration
Frequency
.
BAGHOUSES—6
-------
PART V - INSPECTION OVERVIEW*
CONCLUSIONS/RECOMMENDATION
1. Compliance status:
2. Need for further action:
3. Corrective actions to be taken:
4. Time required to rectify problems:
5. Special waivers or review of compliance criteria required:
6. Need for follow-up inspection:
7. Inspectors signature:
Date:
Approved by:
Title:
*OTHER NOTES, COMMENTS, SKETCHES (ATTACH ADDITIONAL PAGES, IF NECESSARY).
Schematic drawings showing locations of process and dust control equipment should be prepared, particularly
so, where verbal descriptions may lead to misunderstandings. Locations should be noted for observed leak
sites, evidence of corrosion, warped panels, and other mechanical defects.
BAGHOUSES—7
-------
FIELD INSPECTION PROCEDURES
CYCLONES AND MULTICYCLONES
-------
PART I - GENERAL PLANT DATA
Company
Street address
City
Official providing
information
Title of official
State
Report for period
Year
Furnace - company designation
Furnace permit number or NEDS
number
Furnace type
Furnace rated capacity
(charge rate)
Allowable emission rate and
opacity
A. FACILITY DATA
Type
PART ZZ - PROCESS DATA
D Furnace
D Other
No. of
furnaces
Specify
Charging method Q Batch D Continuous
Control devices Q Fabric collector Specify type
Operating
schedule
D Scrubber
D Other
hrs/day
Specify type
days/wJc
wks/yr
CYCLONES AND MULTICYCLONES—1
-------
B. Oaerat ina Parma
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\ND MULTICYCLONES — 2
PEJUOr OP RECORD
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PRODUCT SPECIFICATIONS PERCENT
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RAW MATERIALS
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-------
A. qener*! Information
PART III - CONTROL EQUIPMENT DATA
Process equipt leot ducted to this control equipment:
Quantity of dust collected
Gas flow rate @ collector inlet
Gas flow rate @ collector outlet
Temperature @ collector inlet
Temperature @ collector outlet
Fan speed
Capture velocity of hoods
Over furnace
Charging doors
Pouring spout
Unit manufacturer
Cyclones
Multicyclones:
tons
afcm
afcm
°F
•F
rpm
fpm
fpm
fpm
No:
Static pressure in collection system
Stack
Before fan
Collector outlet
Collector inlet
Before radiant coolers
Before water sprays
Duct after hood
Model No./Type
Interconnection: Series
No. of banks Multiclones per bank
Sootblowers of base of multiclone
Sequential blowing
•H>0
"HiO
•H,O
•H->0
•HoO
•H^O
•H^O
Parallel
Quantity
Blow period
frequency
n
K
O
z
w
en
n
K
O
w
M
I
I
Are there dampers for sectionalization for control of A? (based on load and airflow)?
Where are they located?
-------
B. Collection System
1. System of Ap design:
Load ACFM AP(H2O)
MCR
75%
25%
Primary collector
Secondary collector
Hopper ash removal:
Automatic , Manual , Pressure activated ,
Level activated , timer , screw conveyer ,
water slurry , continuous , intermittent ,
frequency
3. Hopper ash removal sequence
4. Hopper ash removal frequency:
5. No. of sections damped off
6. Fan motor, amps:
7. Gas volume flowrate, acfm:
8. %Q£ across collector _____
C. Operating Experience/Maintenance Aspects
1. Percent of time scrubber fully operational when process
is in operation _______________________________________
2. Has a detailed maintenance schedule been instituted?
3. Is maintenance schedule as recommended by scrubber
manufacturer or by plant? , ,
4. Are maintenance records available for inspection?
5. riow long are records kept on file?
CYCLONES AND MULTICYCLONES—4
-------
PART IV - INSPECTION OVERVIEW*
CONCLUSIONS/RECOMMENDATION
1. Compliance status:
2. Need for further action:
3. Corrective actions to be taken:
4. Time required to rectify problems:
5. Special waivers or review of compliance criteria required:
6. Need for follow-up inspection:
7. Inspectors signature:
Date:
Approved by:,
Title:
*OTHER NOTES, COMMENTS, SKETCHES (ATTACH ADDITIONAL PAGES, IF NECESSARY).
Schematic drawings showing locations of process and dust control equipment should be prepared, particularly
so, where verbal descriptions may lead to misunderstandings. Locations should be noted for observed leak
sites, evidence of corrosion, warped panels, and other mechanical defects.
CYCLONES AND MULTICYCLONES—5
-------
FIELD INSPECTION PROCEDURES
FUGITIVE EMISSIONS
-------
PART I - GENERAL PLANT DATA
Company
Report for period
Year
Street address
Furnace - company designation
City
State
Furnace permit number or NEDS
number
Official providing
information
Furnace type
Title of official
Furnace rated capacity
(charge rate)
Fugitive emission contact
person
Facility telephone number
Source SIC code
Allowable emission rate and
opacity
FUGITIVE EMISSIONS—1
-------
PART IX - SOURCE FILE DATA
Yes
No
N/A
1. Does the source have the current permit (and emissions control plan, if
applicable) on file and available for inspection?
2. Is source operator aware of applicable regulations, permit conditions, and/or
control plan specifications under which operation is permitted?
3. Has a regular staff member been assigned to implementation of the control
pirn?
4. Are permanent facility records being kept in accordance with permit or
control plan? If not, what are the deficiencies?
5. Is ambient air monitoring being conducted near the facility?
How is the monitoring equipment cited relative to fugitive sources?
6. For each source, note the type of control being applied (reference to map or plot plan and/or process
diagram).
• Source ID:
Type of material processed:
Type of control:
• Source ID:
Type of material processed:
Type of control:
• Source ID:
Type of material processed:
Type of control:
• Source ID:
Type of material processed:
Type of control:
FUGITIVE EMISSIONS—2
-------
PART ZZZ - VISUAL INSPECTION
A. FACILITY DATA
Type
D Furnace
D Other
No. of
furnaces
Specify
Charging method Q Batch D Continuous
Control devices Q Fabric collector Specify type
Operating schedule
D Scrubber
D Other
hrs/day
days/vk
Specify type
wks/yr
Sketch Facility Diagram
FUGITIVE EMISSIONS—3
-------
B. Fugitive Sourea Data
GENERAL
1. Are all points listed in current permit/control plan still existent?
2. Are there additional points that are not noted in the files? If so, please note
each new point.
3. Does control equipment and/or control measures) match the information in
the current permit file? If not, specify.
4. Does control equipment appear to be well maintained? If not, note that
equipment which does not
5. Is then evidence that the source can and does make repairs to control
equipment? Specify.
Yes
No
N/A
STORAGE PILES
6. Any new storage piles since last inspection?
7. Have any storage piles been deleted since last inspection?
8. Have any storage piles been left dormant since last inspection?
9. Has any of the source extent associated with storage piles changed since last
inspection (i.e., reduced transfer operations, material drops heights, material
throughput, and vehicular traffic on or around piles)?
10. Have any changes been made in storage pile control program since last
inspection?
11. Any equipment downtime associated with watering since last inspection?
:: . >: . : •: RQAD^^^;-;^:.::^-.^^'-; ' / -
12. Have my roads been eliminated/blocked off since last inspection?
13. Have any roads been paved since last inspection?
14. Any new roads?
15. Have traffic volume or vehicle characteristics on road changed because of
process changes, shutdown, etc.?
16. Have any changes been made in control program since last inspection?
17. Any equipment downtime associated with watering or chemical application
since last inspection?
18. Any treated roads been repaired (e.g., bladed, filled in, etc.)?
*.?. A.-y ru-plemental cleaning (e.g., flushing) since last inspection?
•
FUGITIVE EMISSIONS—4
-------
GENERAL
Yes
No
N/A
HOODS
20. Any fugitive losses based upon visual evaluation as indicated by escaping
dust or refraction lines?
21. Any damage to hood or modifications since last inspection that could affect
performance?
22. Evidence of corrosion?
23. Gap distance between hood and duct system to specifications?
24. Hood positioned properly relative to point of contamination generation?
25. Estimation of flowrate [v » 1096.7 (VP/p)0-5] to manufacturer
specification?
. • ''.••-••";. •-:•• ..';;::.-••••••••• DUCTS , . '•••-• '.-••.
26. Any visible emissions or indication of corrosion, erosion or physical
damage?
27. Position of emergency by-pass dampers closed and not leaking?
28. Position of balancing dampers same as previous inspection?
29. Balancing dampers in good operating conditions with no signs of erosion on
blades?
30. Temperature of gas stream at duct same as previous inspection, thus
indicating no air infiltration?
31. Static pressure measurement (*P) same as previous inspection, thus
indicating no deposit buildup?
32. Estimating of flowrate [v - 1096.7 (VP/p)0-5] to manufacturer
specification?
33. Any visible emission or indication of corrosion, erosion or physical damage
to process equipment?
34. Indications of air balancing problems due to material buildup?
35. Good operation and maintenance practices being utilized to minimise fugitive
emissions?
•
FUGITIVE EMISSIONS—5
-------
PART XV - FUGITIVE OR SMOKE EMISSION INSPECTION
.1. Outdoor Location
Sky conditions
Wind direction
Precipitation
Wind speed
Industry
Unit
Sketch process unit; indicate observer position relative to source and sun; indicate potential emission
points and/or actual emission points.
FUGITIVE EMISSIONS—6
-------
2. Indoor location
Industry
Process unit
Light type (fluorescent, incandescent, natural)
Light location (overhead, behind observer, etc.)
Illuminance (lux or footcandles)
Sketch process unit; indicate observer position relative to source; indicate potential emission points and/or
actual emission points.
FUGITIVE EMISSIONS—7
-------
PART XV - INSPECTION OVERVIEW*
CONCLUSIONS/RECOMMENDATION
1. Compliance status:
2. Need for further action:
3. Corrective actions to be taken:
4. Time required to rectify problems:
5. Special waivers or review of compliance criteria required:
6. Need for follow-up inspection:
7. Inspectors signature:
Date:
Approved by:
Title:
*OTHER NOTES, COMMENTS. SKETCHES (ATTACH ADDITIONAL PAGES, IF NECESSARY).
Schematic drawings showing locations of process and dust control equipment should be prepared, particularly
so, where verbal descriptions may lead to misunderstandings. Locations should be noted for observed leak
sites, evidence of corrosion, warped panels, and other mechanical defects.
FUGITIVE EMISSIONS—8
-------
APPENDIX A.
Bibliography
-------
BACKGROUND
Supplementary Guidelines for Lead Implementation Plans, U. S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC,
EPA-450/2-78-038, August, 1978.
Compilation Guide of Procedural Decisions on EPA NSPS Reference
Methods, U. S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park,
NC, EPA-340/1-84-014, September, 1984.
Development of Guideline Document for State Operating and
Maintenance Recordkeeping Programs, U. S. Environmental
Protection Agency, Stationary Source Compliance Division,
Washington, DC, EPA Contract No. 68-01-4146, Task Order
No. 72, March, 1981.
Field Operations and Enforcement Manual for Air Pollution
Control, Vol. II: Control Technology and General Source
Inspection, U. S. Environmental Protection Agency,
Stationary Source Compliance Division, Washington, D.C.,
APTD-1101, August, 1972.
Field Operations and Enforcement Manual for Air Pollution
Control, Volume III: Inspection Procedures for Specific
Industries, U. S. Environmental Protection Agency,
Stationary Source Compliance Division, Washington, DC,
APTD-1102, August, 1972.
Control Techniques for Lead Air Emissions, Volume II:
Chapter 4—Appendix B, U. S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-450/2-77-012,
December, 1977.
Air Compliance Inspection Manual, U. S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-340/1-85-020,
September, 1985.
Technical Assistance -Document (TAD) for Inclusion of Continuous
Emission Monitoring Systems (CEMS). in the Source Permit
Application, U. S. Environmental Protection Agency,
Stationary Source Compliance Division, Washington, DC,
Contract No. 68-02-3960, W.A. £3-112, December, 1984.
Backaround Information for New Source Performance Standards,
Primary Copper Zinc and Lead Smelters, Volume I: Proposed
Standards, U. S. Environmental Protection Agency, Office of
Air Quality Planning and Standards, Research Triangle Park,
NC, EPA-450/2-74-002a, October, 1974.
-------
Control Techniques for Lead Air Emissions, Volume II: Chapter 4
—Appendix B, U. S. Environmental Protection Agency, Office
of Air Quality Planning and Standards, Research Triangle
Park, NC, EPA-450/2-77-012, December, 1977.
-------
INSPECTION
Inspection Manual for Enforcement of New Source Performance
Standards, Secondary Lead Smelters, U. S. Environmental
Protection Agency, Office of Enforcement, Washington, DC,
EPA-340/1-77-001, January, 1977.
Multi-Media Compliance Audit Inspection Procedures, U. S.
Environmental Protection Agency, Office of Legal and
Enforcement Counsel, National Enforcement Investigation
Center, Denver, Colorado, February, 1983.
Baseline Techniques for Air Pollution Control Equipment
Performance Evaluation, U. S. Environmental Protection
Agency, Stationary Source Compliance Division, Washington,
DC, Contract No. 68-01-6312, Task No. 30, February, 1983.
Inspection Procedures for Evaluation of Electrostatic
Precipitator Control System Performance.• U. S.
Environmental Protection Agency, Office of Enforcement,
Washington, DC, EPA-340/1-79/007, February, 1979.
Industrial Boiler Inspection Guide, U. S. Environmental
Protection Agency, Stationary Source Compliance Division,
Washington, DC, EPA-340/1-81-007, October, 1981.
Air Compliance Inspection Manual, U. S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-340/1-85-020, September,
1985.
Opacity Method Compliance Guide for Fugitives, U. S.
Environmental Protection Agency, Stationary Source
Compliance Division, Washington, DC, EPA Contract
No. 68-02-4463, July, 1991.
Basic Inspector Training Course, Fundamentals of Environmental
Compliance Inspections, U. S. Environmental Protection
Agency, Office of Enforcement and Compliance Monitoring,
Washington, DC, February, 1989.
-------
FUGITIVES
Area Sources
Estimating and Controlling Fugitive Lead Emissions from
Industrial Sources, U. S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC, EPA Contract No. 68-02-4395, W.A. #41,
Midwest Research Institute, September, 1990.
Inspection Manual for PM-10 Emissions from Paved/Unpaved Roads
and Storage Piles, U. S. Environmental Protection Agency,
Research Triangle Park, NC, EPA Contract No. 68-02-4463,
W.A. #17, Midwest Research Institute, October, 1989.
Technical Guidance for Control of Industrial Process Fugitive
Particulate Emissions, U. S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA-450/3-77-010, March, 1977.
Review of NSPS for Lead-Acid Battery Manufacture, U. S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Research Triangle Park, NC, Draft,
October 1989.
Development of NSPS, Project Recommendation Report for Secondary
Lead Smelting Industry. U. S. Environmental Protection
Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC, EPA Contract No. 68-02-3059,
May, 1980.
Opacity Method Compliance Guide for Fugitive Sources, U. S.
Environmental Protection Agency, Stationary Source
Compliance Division, Washington, DC, EPA Contract
NO. 68-02-4463, July 1991.
Process Sources
Inspection of Industrial Ventilation Systems, U. S. Environmental
Protection Agency, Stationary Source Compliance Division,
Contract No. 68-02-4466, Work Assignment No. 90-55,
September, 1990.
- Instructor's Guide
- Student Manual
Inspection Techniques for Fugitive VOC Emission Sources, U. S.
Environmental Protection Agency, Stationary Source
Compliance Division, Washington, DC, EPA-340/l-90-026b,
September 1990.
-------
Estimating and Controlling Fugitive Lead Emissions from
Industrial Sources, U. S. Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research
Triangle Park, NC, EPA Contract No. 68-02-4395, W.A. #45,
Midwest Research Institute, September 1990.
-------
CONTROL EQUIPMENT
Operation and Maintenance Manual for Electrostatic Precipitators,
U. S. Environmental Protection Agency, Air and Energy
Engineering Research Laboratory, Research Triangle Park, NC,
EPA-625-1-85-017, September 1985.
Inspection Procedures for Evaluation of Electrostatic
Precipitator Control System Performance. U. S.
Environmental Protection Agency, Office of Enforcement,
Washington, DC, EPA-340/1-79-007, February 1979.
Fabric Filter Inspection and Evaluation Manual, U. S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards, Washington, DC, EPA-340/1-84-002,
February 1984.
Wet Scrubber Performance Evaluation, U. S. Environmental
Protection Agency, Office of Air Quality Planning and
Standards, Washington, DC, EPA-340/1-83-022, September 1983.
-------
APPENDIX B.
Federal Reference Method 9
-------
P». 40, App. A, Mwth. 9 40 Cm Ok I (7-1-fO MHion)
When: Agency. Research Triangle Park. NC. EPA-
r,. 0.003454 mm Hg-mVmKK (or metric 6&0/4-74-024. December. 1973.
units. 7. Annual Book of ASTM Standards. Part
.0.002676 In. Hg-ftVml-'R (or Kngllah 31; Water. Atmospheric Analysis. pp. 40-42.
units. American Society (or Testing and Materials.
6.7 J Calculation from ZntermediaU Philadelphia, Pa. 1974.
Valuta.
i M*Vi OVZBUtUfATXOW OF
OFACITT or EKxauon PIOM STATXOMAMY
Sovwa
_i.r. _ ff* Many stationary sources discharge visible
• r*,A»t(l-*w») emissions into the atmosphere: these emto-
• _____ .__ ». tlons are usually In the ahape o( a plum*.
•q*MM* »-« Tiiis mcthod Involree the determination ot
plume opacity by qualified observers. The
where: method Include* procedure* (or the training
&-4420 (or metric unltt, and certification of observers. and proes-
•0.09460 (or Encllah unltt duree to be uaed in the field for determina-
nt Aeeeptable Results, If 90 percent
wke, reject the reraltt and repeat the teat. Ouenee upon plume appearance Include
6J Stock Oat Velocity and Volumetric Angle of the obeerrer with reepect to the
Plow Rate. Calculate the average stack CM plume: angle of the obeerrer with raepect to
velocity and Tolumetrte flow rate, tf needed, the tun: point of obeerratlon of attached
using data obtained In this method and and detached steam plume; and angle of the
equations m Sections ft J and ft 4 of Method obeerrer with respect to a plume emitted
2. from a rectangular stack, with a large length
6.10 Relative brer — from Sulfurtc l^bte ra the field are luminesoenee and color
Acid MuuteeturmgPronsMa7tt.8. DBXW eontzast between the plume and the back-
PBS. Division of Air Pollution, Public around against which the plume to viewed,
Health Service Publication No. 999-AP-13. These variables exert an tnn««mce upon the
~*--*~ u viewed by an ob-
.
2. Cortett, P. P. The Determination of *8rrer- "* «n affect the ability of the ob,
80. and 80. in Plue OaMa, Journal of the g"« [* acearately assi^opacttT vahjeeto
Institute of Pud. tltn-MX. 1ML ta* obeerved plume. Studies of the theory
3. **"*frv Robert M. Construction r**»tim of plume opacity and field studies haw
of Isokmetie Source a^^ftt^t f^uiim^*, demonstrated that a plume is most visible
fitvironmental Protection Agency. Re- *ad presentt the greatest apparent opacity
search Triangle Park. NC. Air Pollution when viewed against a contrasting back-
Control Office Publication No. APTD-OUi. ground. It follows from this, and to con-
Apdl. 197L firmed by field trials, that the opacity of a
4. Patton. W. P. and J. A. Brink, Jr. New plume, viewed under conditions where a
Equipment and Techniques for «"«p»"g contrasting background is present can be as-
fh+mfryi process Oases. Journal of Air Pol- timed with the greatest degree of accuracy.
lutton Control Atf^ttVm 1 £162. 1963. However, the potential for a positive error to
ft. Rom. J. J. Maintenance, Calibration, also the greatest when a plume is viewed
and Operation of Isokmetie Source Sam- under such contrasting conditions. Under
pllng Equipment. Office of Air Programs, conditions pmenntlni a less contrasting
Brrtronmental Protection Agency. Re- background, the apparent opacity of a
search Triangle Park. NC. APTD-0676. plume Is less and approaches wo as the
Li.vysnh 1972. color **"1 t»m»>TMHfi«ii»n"^ contrast decrease
6. HamO. H. P. and D. K. «"••»•« Col- toward sera. As a result, significant negative
laborative Study of Method for Determtna> bias and negative errors can be made
Uon of Sulfur Dioxide Finlsil m from SU- a plume to viewed under less
tionary Sources (Poesfl Puet-Pbed Steam condltiona. A i
Geaantora). Xnvtronmental Protection than Inrreases the jinssltinitj that a plant
-------
Agency
ft. t», App. A, Mvrh. f
gperttor win be dted for a violation of opac-
ity standards due to observer error.
Studies have been undertaken to deter-
mine the magnitude of positive errors which
eaa be made by qualified observers while
nsdl&t pt'"y«« under fontrasrro*. condl-
BOOS and uatnt the prooedares set forth in
tos) method. The results of these studies
(flekl Mais) which taraive a total of 769 sets
• of 38 readings each an as follows:
(1) For black plumes (133 sets at a smoke
fSDerator). 100 percent of the sets were read
with a positive error • of less than 7 A per-
cent opacity. 99 percent were read with a
positive error of less than 8 percent opacity.
(3) For white plumes (170 seta at a smoke
cenerator, 168 sets at a coal-fired power
plant. 296 sets at a sulfuric add plant), 99
percent of the seta were read with a positive
error of less than 7.8 percent opacity: 98
percent were read with a positive error of
Issi than 8 percent opacity.
The positive observational error •r*r**f*-
sd with an average of twenty-five readings Is
therefore established. The accuracy of the
method must be taken Into account when
determining possible violations of applicable
opacity standards.
L Mneipte aiuf JppHeaMUry
U Principle. The opacity of emissions
from stationary sources Is determined vtou-
aUy by a ejualffled observer.
U Applicability. This method is applica-
ble for the determination of the opacity of
emissions from stationary sources pursuant
to 160.1Kb) and for e-uallfytnc observers for
visually determining opacity of emissions.
The observer qualified to accordance with
paragraph 8 of this method shall use the
following procedures for visually determin-
ing the opadty of mtntmp
3.1 Position. The qualified observer shall
stand at a distance sufficient to provide a
dear view of the emissions with the son art-
•wed In the 140* sector to hto beck. Consist.
cot with *Hfln*^^**»^ fTmflfmfitlim of water vapor *?*** toe
formation of ^h* steam r^v*^.
14 Recording Observations. Opadty ob-
servations shall be recorded to the nearest S
percent at IB second intervals on an obser
vattonal record sheet. (See Figure 9-3 for an
i.) A minimum of 34 observations'
shall be recorded. Each momentary i
tion recorded shall be deemed to :
the average opadty of emissions for a 18-
3J Data Reduction. Opadty shall be de-
termined as an average of 34 consecutive ob-
servations recorded at 18 second Intervals.
Divide the observations recorded on the
record sheet into sets of 34 euusecuUfe ob-
servations. A set to composed of any 34 con-
secutive observations. Sets need not be con-
secutive in tone and in no case shall two sets
overlap. For each set of 34 observations, cal-
culate the average by summing the opadty
of the 34 observations and dividing this sum
by 34. U an applicable standard specifies an
averaging time requiring men than 34 ob-
servations, calculate the average for all ob-
servations made during the sped/led time
period. Record the average opadty on a
-------
ft. 60, Ac*. A, Me*, t
40 CFt Ok I (7-1-fO UHton)
record sheet (See Figure 0-1 for an exam-
ple.)
3. QMiUlcoMofu and TttM*e
3.1 Certification Requirements. To receive
certification as a qualified observer, a candi-
date must be tested and demonstrate the
ability to assign opacity readings In 8 per-
cent Increments to 38 different black
plumes and 28 different white plumes, with
sa error not to exceed 18 percent opacity on
any one reading and an average error not to
exceed 74 percent opacity la each category.
*•*!»'"f*iUM «><«ti be tested ji«""'*i»g to *fvt
procedures described m paragraph 34.
•hall be corrected prior to conducting any
subsequent test run*. The moke meter
ahall be demonitrated. at the time of Instal-
lation, to meet the «pectflcatlon» listed la
Table 9-1. This demonstration shall be re-
peated following any subsequent repair or
replacement of the photocell or sssnrlstert
electronic circuitry «~»»"^«"g the chart re-
corder or output meter, or every 6 months.
whichever occurs first.
TABU 9-1—SMOKI Men* OUMN AND
generators used pursuant to
graph 34 shall be equipped with a
meter which meets the requirements of
paragraph 14.
The certification shall be valid for *
period of 6 months, at which time the quali-
fication procedure must be repeated by any
observer to order to retain certification.
> J Certification Procedure. The eerttflev
tfrm test consists of showing the candidate a
complete run of 80 plumes—38 black plumes
and 38 white plumes—generated by a smoke
generator. Flumes within each set of 38
black and 28 white runs shall be presented
la random order. The candidate assigns an
opacity value to each plume and records his
uLeei'utlon on a suitable form. At the com-
pletion of ifacri run of 80 readings, ttw tffyrr
of the candidate Is determined. If a candi-
date *•"• to qualify, **»^ complete) ma of 80
The smoke test may be administered as part
may be preceded by training or famfliarisft-
tion runs of *•*** ^**p^^ generator **"»*»*g
which candidates are shown Mack and white
plumes of known opacity.
jj *rpn*^ Generator Specifications. *T
smoke generator used for the purposes of
paragraph 34 shall be equipped wtth a
smoke meter Installed to measure opacity
across ti%^ diameter of ^H^ STU^^ generator
stack. The fflv?fci^ in^ter output shall display
tnsteok opacity based T«"» a piTtilfTg***
equal to the stack exit diameter, on a full 0
to 109 percent chart recorder scale. The
smoke meter optical design and perform-
ance shaU meet ^0 specifications shown in
Table »-L The smoke meter shsJl be catt-
brated as prescribed in paragraph 34.1 prior
to ^t*^ *iTTnrw?l 0f each smoke readtng test*
At the completion of each test* *^** sero and
epsa drift «^*>l be checked tM If the drift
±1 percent opacity, the ocndrUoa
34.1 CaHbraUon. The smoke meter to catt.
brated after allowing a "^"t""^ of 30 *•'*'»-
utes warmup by alternately producini
lated opacity of 0 percent and 100 :
When stable response at 0 percent or 100
percent to noted, the smoke meter to adjust-
ed to produce aa output of 0 percent or 100
percent, as appropriate. This calibration
than be repeated uata stable 0 percent and
100 percent readings are produced without
adjustment. Btaaulated 0 percent and 100
percent opacity values may be produced by
alternately switching the power to the light
source on and off white the smoke i
344 Smoke Meter evaluation. The i
meter design and performance are to be
evaluated as foOows:
344.1 tight Source. Verify from marmtso-
tnrer's data-and from voltage measurements
***** at the '«T as «nT*n"**V that the
lamp to operated within ±8 percent of the
nominal rated voltage,
3444 Spectral Response of PhotoeeiL
Verify from manufacturer's data that the
photocell has a photonic-response; Le, the
spectral sensitivity of the cell shall closely
approximate *K* standard spectraHummost-
ty curve for photopie vtotoa which to refer*
tta(b)ofTabte»-t.
-------
lOCATIM
nst
IMC
rm
COBIML onto.
mm OF OOSCHMMM
OKHIOI convicnm MTI.
roue or OUSSURS
KM* OrIISCMMa »OWI_
aoctTM
MSUKI tOCATIQI
•HUM* M Jlltliap
Otrtctto ttm Otidkir|i
»l*t«FO»ttr«MM*t«
•KCMMKKMFfM
MUTHI OMITUn
Hta« Mracttai
JMIwt Tv^trafam
W OMITian (cttw.
•NKMt. f C1M*. tit.}
R« Ksairt m
•UUK« f HIM*
etici Mionum
tolttel
rUi
UNftir OF MttMf OMCIIT
jtt
Tl—
SUrt-fai
OMC<
SMI
,-
H«r«fi
fna U StpKlIf
Ikt MUTtt Mt^NI Mt U MWllMM Mitt U
tkt tlM VMlMtlM Mt MM.
-------
H. 60, App. A, ftUHk f
40 01 Ch. I (7-1-90
Fawv »-2—OBSERVATION RKOMO
10
11
It
n
14
II
IT
li
1*
-------
H. 60, App. Ar AH. Me*. 40 CR Ch. I (7-1-90 Edm*»)
L.the distance tram the photocell to the
limiting aperture. The limiting aperture ti AixoaAn HXTHOO I—DcrnaoiuTxoir or
the point ID the path between the photocell m OACTTY or Eicssioirs PKOM STA-
and the «•»«*• pin™* where the •»§«« of TIOB/UT Sourness RBCOTB.T IT XJDAI
view to mort restricted. In smoke generator This alternate method pravldes the quan-
smoke meten thto to normally an orifice utatlve determination of the opacity of an
plate. emissions plume remotely by a mobile lldar
IJA4 Angle of Projection. Check eon- system (laier radar: light Detection and
•traction ceometry to enaure that the total Ranging). The method includes procedural
angle of projection of the lamp on the for the calibration of the lidv and proce-
smoke plume does not exceed IS*. The total duns to be used in the field for the Udar ds-
anti* of projection may be calculated from: termination of plume opacity. The Udar to
••3 tan* *d/2U where •- total angle of pro- used to measure plume opacity durtnc
j+fti/m; Q> the •"*" of the »••«§**» of the either day or nighttime hours because It
im**m moment * the M******* of the n-««*- contains It* own pulsed light source or
tnganertun: and L- SbsSsUnce tram the transmitter. The operation of the Udar to
iMM to the ih»ittiM snertura. not <*ep*in<*gn* upon ambient lighting
iwap to UM limiting mnuim.
to measuring plume opacity at nu-
UBMT rMMMMimm of the •»•*.> meious wavelengths of laser radiation. How.
•"•"•^•"•siT • ^•i^^sssW ™* "JiisW esMSHtmisst W0P* *AsV DQe^QUBssVDOO 9^TgUUe%tlOO gssOd CIsssW
the smoke meter according to method apply M>IT to a IM«* **»* employs a
J4.1 tod then UiseiUua a series of three ru^y (red light) laser (Reference 8.11.
pathlength. raten calfbnted wtthm ±*
percent shaU be used. Care should be taken
von biserting the fflten to prtrtnt stray
i during both nighttime ***** daylight
Zero and 8pea nuiDetermino conditions, pursuant to 40 CFR 160.1Kb). n
the sero and span drift by calibrating and to nlfft 'n0^**1* for the "^'f^tttftn and
operating the smoke generator m a normal performance verification of the mobile Udar
manner over a 1-hour period. The drift to for the insesniiiiiiiiil of the opacity of <
measured by **"•'**•'§ the ssro sad spaa at stem. A performance/design
the end of thto period. for a baste lldar system to also :
Response Time. Determine the re- Into thto method.
time by producing the series of five LS Deftnlttim
ted 0 percent sad 100 percent upaiHi Asautth angle: The angle m the 1
values and observing the time required to tal plane that designates where the
reach stable response. Opacity vanes of • beam to pointed. It to measured from aa ar»
tmvTiit ITMJ 100 pt""Tit ***T bo -«»"«''-*^*» bttrary fixed leference line to that plan*.
by alternately switching the power to tat P"fc«^™»g ^SeSftt^iLf'of'tne^
dent laser beam doe to reflection from i
tteulates along the beam's i
4. Jts/bnmois> which tn**r Include a •"<*• plume.
4,1 Air PoDutJoB Conttol Dtotrlet Rolss Backscatter signal: The general term for
aad Regulations. Los Angeles County Air the lldar return signal which results from
PoBnXiea Control Dtotriot, HspflaMon IV. laser light bemc backacattend by atrne**
PratuotUons, Rule 60. pherte and smoke plume partlnilttes,
O Wetoburd. Melvto I, PWd Operations .Convergenos dtotaaoK The distance tram
44 Condon. «.0, and Odtohaw. H, Band-
_.. _- — *- -_ . - -- - ^» -- ^^^ ___ fj»-^ «fvgT
Tork.NT.19M.TabtoS.l.n.»4&
-------
APPENDIX C.
Federal Reference Method 22
-------
PI. 60, App. A, Mwth. 22
liquid leakage. Sources that have these con-
ditions present must be surveyed using the
Instrument techniques of O.I or 4.3.2.
Spray a soap solution over all potential
leak sources. The soap solution may be a
commercially available leak detection solu-
tion or may be prepared using concentrated
detergent and water. A pressure sprayer or
a squeeze bottle may be used to dispense the
solution. Observe the potential leak sites to
determine If any bubbles are formed. If no
bubbles are observed, the source to pre-
sumed to have no detectable emissions or
leaks as applicable. If any bubbles are ob-
served, the instrument techniques of 4J.1 or
44J shall be used to determine If a leak
»^y«f or If P!* source has detectable emis-
sions, as applicable.
4.4 Instrument Evaluation Procedures. At
t>yf K«f
-------
invtrorunefrtol PrefwcHon Agwncy ft. 60, Aptx A, MUth. 2S
found m References 7.1 and 7.3 or from tbe from the emission source to recommended.
lecture portion of the Method • osrtiflea- Per outdoor locations, select a position
tion course. where the sun to not directly In the obaerv.
2. JppUcoMHr* and Principle «*• eres.
2.1 Applicability. This method applies to *•* "eld Records.
tbe determination of the frequency of tugl- *f-* Outdoor-Location. Record the tot.
tive »™'—'»"- from stationary sources (lo- lowing information on the field data sheet
cated indoors or outdoors) when specified as dcure 22-1* company name. Industry.
tbe test method for determining «~^p»«~» process unit, observer's name, observer's af•
with new source performance standards. filiation, and date. Record also the estimat-
This method also to applicable for the de- *d wind speed, wind direction, and sky eon-
termination of the frequency of visible dttion. Sketch the process unit being ob»
smoke emissions from flares. served and note the observer location rebv
2J Principle, fugitive ••««•-«•«»«- pro- tive to the eouree and the sun. Indicate the
duced during material iiiiineslni. >««~ni»r potential and actual emission points on the
sad transfer operations or smoke rmlsrtnns sketch.
tram flares are Usually determined by an 8.2J Indoor Location Record the follow-
observer without the aid of instruments. tag information on the field data sheet
i PcUfHHotu (figure 22-2): onmnany name, industry.
S.1 *—«—«"- frequency r*K-mUe?r of araB>a> "^ observer's name, obeerrer't af*
Hi.. 4v«» * «— A«A •ilrhia jtitmtmum *v^ filiation, and date* Record as appropriate
22lL2^22S2r ^^ ^^ to* tnw. location, and tatensity of lighting
on the data sheet. Sketch the process untt
relative to the source. Indicate the potential
IJ fugitive Bmtosions. Pollutant —^ ud •ctu*1 *"«"*»• «ntosloa points on the
ated by an affected faculty which is not eoJ- ah
« 4 i|m«tt W.t^««. Pftthit%nt aywrM- ure the level of mummatton at a location as
foot candles) to considered neeeesary for
properjppUeation of thto method.
8.4 Observations Record the clock time
when observations begin. Use one stopwatch
*«H««g «rtrth BbtamtiflM art to monitor the duration of the i
conducted, not to be less than the period P*rto* rtart this rtopwat^ when Uiej
specified to the applicable regulation. yj'tioa P«nod or
4. XovJpmeii* 2?°ilIL2^Sll*—
oy process smnoowns
unit dtvtoJoni of at least OJI seconds; two re* begins azidrestaittt without resetting'
4J Ught Meter. Ught meter capable of ***^ *"** ""^ 8top ** itap***en •* **•
~~~ ***** t~ t~*~- j*0*?^ tated time tadlcated by thto stopwatch to tho
range, reuuiren lor moHor observations duration of tho observation ~ '
Onhj. MM o^Mnrntim iu*^»«< ta
va^ «r,^m. V^WM^W g^wa^v.* ^
LI Position. Buivtf tbe affected facility During the observation period. <
or Bunding or structure housing the piaesss ly watch the emission source. Upon i
to be obeeiwd and determine the locations tag an emission (condensed water vapor to
of potential emissions. If ^*>t affected faeOl* mrt rmilrtiiieil an emission), start the*
ty to located Inside a bunding, determine an second accumulative stopwatch: stop the
iiheenstlfMJ location that is iri-«-f«"J with watch when the emission stops. Continue
the rtqulrements of the applicable regnla- thto procedure for the entire observation
US-* f|^ mitsftft observation of -~«'—<<»^ period. Tbe accumulated elapsed time 00
escaping the buOdtng/structure or tasldeob- this stopwatch to the total time emtsstoni
servation of *•"'••''"*• ^*iyHr iHrtttinl from were visible during the observation period,
the affected faculty PIBBISS unltx Then Le, the emission time.
select a position that enables a clear view of 8.4.1 Observation Period. Choeee an ob-
the potential emission pointtt) of the affect- serration period of sufficient length to meet
*d faculty or of the bulldmg or structure the requirements for determining compU-
tMoetag the affected faeOtty. as appropriate anes with the emievton regulation in the ap-
for the applicable snbpart. A position at pueaMe subpart. When the length of the ee>
least IS feet, but not mere than 9M mOea. servation period to speefflcaUy stated ta the
-------
ft. Mr Aptx A, M*Hi. 22
applicable subpart, it may not be necessary
to observe the source for this entire period
If the emission time required to Indicate
nffii<«^mpn»Ti«» (based on the specified ob-
servation period) Is observed In a shorter
time oerlod. In other words. If the regula-
tion prohibits emissions for more than 6
minutes in any hour, then observations may
(optional) be stopped after an emission time
of A minutes is exceeded. Similarly, when
the regulation Is expressed as an emission
frequency and the regulation prohibits
emissions for greater than 10 percent of the
Hnw» Ip «t»y hOUr, than pllSf I HitllJIlS *»*f
(optional) be terminated after A minutes of
emissions are observed since A minutes to 10
percent of an hour. In any case, the observa-
tion period shall not be less than A minutes
in duration. In some cases, the process oper-
ation may be Intermittent or cyclic. In such
40 CM Oi. I (7-1-90 UM«i)
period* of high wind. If the view of the p».
tentlal emission polnu Is obscured to such a
degree that the observer questions the w
lldlty of continuing observations, then ths
observations are terminated, and the observ-
er clearly notes this fact on the dau form.
8.5 Recording Observations. Record the
accumulated time of the observation period
on the data sheet as the observation period
duration. Record the accumulated ttnu
emissions were observed on the data sheet
as the emission time. Record the clock Urn*
the observation period began and ended, as
well as the clock time any observer breaks
began and ended.
4.
If MM applicable subpart requires fhtt the
emission rate be expressed as *** emission
servatlon period (In seconds) or by any mml.
»«» oba«rvatton period required m the ap.
«* «» •«««»» oheenrattoo
Uon periods of greater than M minutes, the
observer shall take a break of not less than
ft minutes and not more than 10 minutes
after every IB to 90 minutes of observation,
U continuous observations are desired for
extended time periods, two observers can al-
Uraat* between making observations sad
taking breaks. •
8.O Visual Znterf erenee.' OocMtonaUy.
fugitive missions from sources other than
the affected faculty (e^, road dust) may
prevent a clear view of the affected facility.
Tnk may particularly be a problem during
«ulUplythl.quoti«ntbylOO.
7- WHnrnetu.
7.1 Missan. Robert tad Arnold
Guidelines for Evaluation of Visible
slons Certification. Field Procedures. Legal
Aspects, and Background Uatmlal DA
Publication No, CPA-»*0/1-T»-OOT. Apcfl
1979
7 J Wohlschlegel. P. and D. E. Wagoner.
Guideline for Development of a Quality As-
surance Program: Volume IX— Visual Deter-
mtMHim ^ opacity Bmlsslrnis Prom 8ta>
Uonary Sooross. EPA Publication Ho. EPA-
6M/«-7«-OOt-L If ovember ifTS.
-------
H.M, Apfk A, Me*.
Oft tMOKI IMB80M WVKnON
Ot/TDOOft IMAT10N
SMiefi procwr unit
ftlrtx «• Mure* m< wo;
OUtNVATIONS
-------
Ft. 60, App. A, M«th. 22 40 CFI Ch. I (7-1-90 UMwi)
i«* MMion tiMpMtien Mbor toot Ion tlU*
FUBTTIVK IHIS8 tOM HBMLi HH
IMUDR UOQZON
Untlon AtmUtion.
oiit
type (eiuorweMt, tn
loeatlen (evwtMd, tahlnd ttomrmr. «tc.)_
(!>• or
ttecoh ptuum vnitt indicate utan m poaitien raUtiw to •oucwi Indleaw pocantUl
«lMien point* «4/or «ctt»l •tiwlcn points.
pviod
dock dnttan.
•intMB
tagiming
------- |