United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
October 1989
Air
Review of
New Source
Performance
Standards for
Lead-Acid Battery
Manufacture
Preliminary Draft
-------
Review of New Source
Performance Standards for
Lead-Acid Battery Manufacture
Preliminary Draft
Emissions Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1989
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TABLE OF CONTENTS
Page
1.0 SUMMARY 1-1
1.1 Industry Trends 1-1
1.2 Control Technology 1-2
2.0 INTRODUCTION 2-1
2.1 Scope of the Review 2-1
2.2 New Source Performance Standards 2-1
2.2.1 Background 2-2
2.2.2 Summary of the NSPS for Lead-Acid Battery Manufacture 2-2
2.2.3 Appl icabil ity of the Standards 2-3
2.2.3.1 Affected Facilities 2-3
2.2.3.2 Applicability Date 2-4
2.2.3.3 Modification 2-4
2.2.3.4 Reconstruction 2-5
2.2.4 Testing and Monitoring Requirements 2-6
2.3 References 2-7
3.0 THE LEAD-ACID BATTERY INDUSTRY 3-1
3.1 General 3-1
3.1.1 Industry Profile 3-1
3.1.2 Process Description 3-7
3.2 Grid Casting 3-16
3.3 Paste Mixing 3-17
3.4 Three-Process Operation -- Stacking/Burning/Assembly 3-18
3.5 Formation 3-19
3.5.1 Wet Formation Process 3-20
3.5.2 Dry Formation Process 3-20
3.6 Lead Oxide Production 3-21
3.6.1 Ball Mill Process 3-22
3.6.2 Barton Process 3-22
3.7 Lead Reclamation 3-22
3.8 References 3-24
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TABLE OF CONTENTS
(Continued)
Page
4.0 EMISSION CONTROL TECHNOLOGY 4-1
4.1 Grid Casting Machines and Furnaces 4-1
4.1.1 Scrubbers • }'J
4.1.2 Fabric Filters 4-2
4.2 Paste Mixer.
4-2
4.2.1 Scrubbers .................... . ............................ 4-2
4.2.2 Fabric Filters ......... . ............... . .................. 4-3
4.3 Three-Process Operation (Stacking, Burning and Assembly) ...... .. 4-3
4.3.1 Fabric Filters.... ...... ............ ---- ....... ....... .... 4-3
4.3.2 Scrubbers ........ ......... . ..... . ................... ...... 4-3
4.4 Lead Oxide Production ............... . ......... . ................. 4-4
4.5 Lead Reclamation ................................................ 4-4
4.5.1 Scrubbers .................. . .............................. 4-4
4.5.2 Fabric Filters ............................................ 4-5
4.6 Formation [[[ 4-5
4.6.1 Good Work Practice ........................................ 4-6
4.6.2 Water Sprays .............................................. 4-6
4.6.3 Foam Covers ............................................... 4-6
4.6.4 Scrubbers. . ............................................... 4-6
4.6.5 Mist Eliminators ........................................ .. 4-7
4.7 Central Vacuum Systems .......................................... 4-7
4.8 New Control Techniques .......................................... 4.7
4.8.1 Cartridge Collectors ...................................... 4-7
4.8.2 High Efficiency Particulate Air Filters ................. '.'. 4-8
4.9 References [[[ 4.9
5.0 COMPLIANCE STATUS .
5.1 Affected Facilities
5.2 Emissions Data...1
5.2.1 Grid Casting .................. 5 4
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TABLE OF CONTENTS
(Continued)
Page
5.2.3 Three-Process Operation 5-13
5.2.4 Lead Oxide Production 5-17
5.2.5 Lead Reclamation 5-19
5.2.6 Other Lead Emitting Operations 5-20
5.2.7 Combined Facilities 5-22
5.3 References 5-25
6.0 COST ANALYSIS 6-1
6.1 Introduction 6-1
6.2 Process Description 6-1
6.2.1 Grid Casting 6-1
6.2.2 Paste Mixing 6-2
6.2.3 The Three-Process Operation 6-3
6.2.4 Formation 6-3
6.2.5 Lead Oxide Production 6-4
6.2.6 Lead Reclamation 6-5
6.2.7 Central Vacuum Systems 6-5
6.3 Pollution Control Devices 6-5
6.4 Cost Data, Methodology and Assumptions 6-13
6.4.1 Capital Costs 6-13
6.4.2 Annual Costs 6-16
6.5 Annual Control Costs 6-30
6.6 Cost Effectiveness 6-41
6.7 Comparison with Section 114 Letter Data 6-42
6.8 References 6-45
Appendix A - Ductwork Description 6-49
Appendix B - Capital Cost Example 6-55
Appendix C - Line Item Annual Cost Example 6-56
7.0 ENFORCEMENT ASPECTS 7-1
7.1 Definition of Affected Facility 7-1
7.2 Emission Testing 7-3
7.3 References 7-5
i n
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LIST OF FIGURES
Figure ^e
3-1 U. S. Total Shipments of SLI Batteries 3-8
3-2 Breakdown of U. S. Battery Shipments (1942-86) 3-9
3-3 A Lead-Acid Storage Battery. 3-13
3-4 Components of a Battery Element 3-14
3-5 Process Flow Diagram 3-15
5-1 Emissions Data for Grid Casting Facilities 5-5
5-2 Emissions Data for Paste Mixing Facilities 5-9
5-3 Emissions Data for Three-Process Facilities.. 5-14
5-4 Emissions Data for Lead-Oxide Production Facilities 5-18
5-5 Emissions Data for Other Lead Emitting Facilities 5-21
5-6 Emissions Data for Combined Facilities 5-23
6-1 Fabric Filter Total Installed Capital Investment Costs,
Second Quarter, 1988 6-44
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LIST OF TABLES
Table Page
3-1 United States Lead-Acid Battery Manufacturing Facilities 3-2
3-2 Consumption of Lead in United States by Product Category . 3-6
3-3 U.S. Replacement Battery Shipments, and U.S. Original
Equipment Battery Shipments 3-10
3-4 U.S. Battery Shipments: Replacement and Original
Equipment Shares by Product Category 3-11
3-5 Typical Formulas for Positive and Negative Battery Pastes 3-17
5-1 Lead-Acid Battery Plants with Subject Facilities 5-2
6-1 Lead-Acid Battery Manufacture Model Facility Parameters
and Control Systems 6-6
6-2 Capital Cost: For Control of Grid Casting Furnace
and Machine 6-17
6-3 Capital Cost: For Control of Paste Mixing 6-18
6-4 Capital Cost: For Control of Lead Oxide Manufacturing 6-19
6-5 Capital Cost: For Control of Three-Process Operation 6-21
6-6 Capital Cost: For Control of Lead Reclamation 6-22
6-7 Capital Cost: For Control of Paste Mixing Plus
Three-Process Operation by Same Device 6-23
6-8 Capital Cost: For Control of Grid Casting Plus Lead
Reclamation by Same Device 6-24
6-9 Capital Cost: For Control of Formation 6-25
6-10 Capital Cost: For Control of Central Vacuum System 6-26
6-11 Unit Cost Used for Estimating Control System Annual Costs.... 6-27
6-12 Annual Cost: For Control of Grid Casting Furnace and
Machine 6-31
6-13 Annual Cost: For Control of Paste Mixing 6-32
6-14 Annual Cost Analysis: For Control of Lead-Oxide
Manufacturing 6-33
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LIST OF TABLES
(Continued)
Table
6-15 Annual Cost: For Control of Three-Process Operation..... ---- 6-34
6-16 Annual Cost: For Control of Lead Reclamation. ---- . ...... .... 6-35
6-17 Annual Cost: For Control of Paste Mixing Plus Three-
Process Operation Controlled by Same Filter .............. .. 6-36
6-18 Annual Cost: For Control of Grid Casting Plus Lead
Reclamation Controlled by Same Device .............. . ....... 6-37
6-19 Annual Cost: For Control of Formation ................. . ..... 6-38
6-20 Annual Cost: For the Control of Central Vacuum System ....... 6-39
6-21 Cost Effectiveness: Control of Grid Casting, Lead Oxide
Manufacture, Lead Reclamation, and Grid Casting Plus
Lead Reclamation. . . ....... ......... ....... . ...... . ....... . . 6-43
6-22 Cost Effectiveness: Control of Paste Mixing, Three-Process
Operation, Formation, and Paste Mixing Plus Three-Process
Operation .................................................. 6-44
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1.0 SUMMARY
The new source performance standards (NSPS) for lead-acid battery
manufacturing plants were promulgated by the U.S. Environmental Protection
Agency (EPA) on April 16, 1982, under Section 111 of the Clean Air Act. The
standards limit emissions of lead from new, modified, and reconstructed
facilities at any lead-acid battery manufacturing plant which has the design
capacity to produce in one day batteries which would contain, in total, an
amount of lead equal to or greater than 5.9 Mg (6.5 tons). These standards
apply to any affected facility which commences construction or modification
after January 14, 1980. The affected facilities included in this source
category are the grid casting facil-ity, paste mixing facility, three-process
operation facility, lead oxide manufacturing facility, lead reclamation
facility, and other lead emitting operations.
The objective of this report is to document the review of the NSPS for
lead-acid battery manufacture, and to assess the need for revision on the
basis of developments that have occurred since the standards were promulgated.
This review is required under Section lll(b) of the Clean Air Act, as amended.
The following paragraphs summarize the findings of this review.
1.1 INDUSTRY TRENDS
Two major types of lead-acid storage batteries are manufactured in the
United States: starting-lighting-ignition (SLI) batteries, and industrial
storage batteries. SLI units by far account for the majority of the North
American Battery Industry. In 1986, United States SLI battery shipments
reached 75.7 million units; in 1987, SLI shipments were valued at $2.10
billion (1982 $). As of 1985, the industrial battery sector accounted for
approximately $375 million in annual sales.
1-1
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Growth is expected in the future for both the SLI and industrial battery
markets. SLI battery shipments are expected to increase 4.5 percent annually
between 1987 and 2000. In 1985, it was estimated that the industrial battery
market would experience annual growth of 2 to 5 percent through 1989. The
trend is toward fewer, larger plants, with the already small number of small
plants decreasing.
1.2 CONTROL TECHNOLOGY
The lead-acid battery industry applies various air pollution controls,
including: baghouses, low energy wet scrubbers, and more recently, cartridge
collectors and secondary high efficiency particulate air filters (HEPA).
Manufacturers often vent a number of processes to the same control device via
a collection system of ducts and hoods. The control systems used at
individual plants depend upon plant layout, applicable OSHA regulations, and
economics of product recovery. The emissions data collected during this
review show no major difficulties in meeting the allowable NSPS limits.
1-2
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2.0 INTRODUCTION
2.1 SCOPE OF THE REVIEW
The Clean Air Act Amendments of 1977 require that the Administrator of
EPA review and, if appropriate, revise established standards of performance
for new stationary sources (NSPS) at least every 4 years.1 The purpose of
this report is to document this review and to assess the need for revisions
of the existing standards for lead-acid battery manufacture, based on
developments that have occurred or are expected to occur within the
industry. The information presented in this report was obtained from
reference literature, discussions with industry representatives, trade
organizations, process and control equipment vendors, EPA Regional Offices,
and State and local agencies. Additional information was obtained from
plant surveys, and responses to information requests under Section 114 of
the Clean Air Act.2
The review conducted to assess the current NSPS for lead-acid battery
manufacture included several areas, such as:
~ new manufacturing processes (production of low
maintenance or maintenance free batteries)
" technologies being used for compliance
~ enforcement and compliance experiences.
2.2. NEW SOURCE PERFORMANCE STANDARDS
This section presents the current federal' regulations for new sources
of lead and visible emissions from lead-acid battery manufacture. A summary
of the NSPS is first presented, followed by detailed discussions of the
requirements, definitions, and specifications of the NSPS.
2-1
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2.2.1 Background.
New source performance standards regulate emissions of air pollutants
from new, modified, and reconstructed facilities in various industrial
categories. The authority for the NSPS regulations is granted to the U.S.
Environmental Protection Agency (EPA) under Section 111 of the Clean Air
Act.3
The regulation for lead-acid battery manufacture is listed in Subpart
KK of 40 CFR 60, (Code of_ Federal Regulations; Title 40-Protection of
Environment; Part 60-Standards of Performance for New Stationary Sources;
Subpart KK - Standards of Peformance for Lead-Acid Battery Manufacturing
Plants). Subpart KK addresses specific requirements for this source
category, but Subpart KK also incorporates the general requirements for any
NSPS. These general requirements are listed in Subpart A (General
Provisions) of 40 CFR 60.
2.2.2. Summary of the NSPS for Lead-Acid Battery Manufacture.
New source performance standards were promulgated by the EPA on April
16, 1982, limiting emissions o* lead from new, modified, and reconstructed
facilities at any lead-acid battery manufacturing plant which has the design
capacity to produce in one day batteries which would contain, in total, an
amount of lead equal to or greater than 5.9 Mg (6.5 tons). These standards
apply to any affected facility which commences construction or modification
after January 14, 1980.
The affected facilities for this standard are the grid casting
facility, paste mixing facility, three-process operation facility, lead
oxide manufacturing facility, lead reclamation facility, and other lead
emitting operations. The emission limits are defined as follows:
2-2
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Facility Lead Emission Limit Opacity
Lead oxide production 5.0 mg/Kg (0.010 lb/ton)* 0%
Grid casting 0.40 mg/dscm (0.000176 gr/dscf) 0%
Paste mixing 1.00 mg/dscm (0.00044 gr/dscf) 0%
Three-process operation 1.00 mg/dscm (0.00044 gr/dscf) 0%
Lead reclamation 4.50 mg/dscm (0.00198 gr/dscf) 5%
Other lead emitting
operations 1.00 mg/dscm (0.00044 gr/dscf) 0%
* The emission limit for lead oxide production is expressed in
terms of lead emissions per kilogram of lead processed.
Compliance is demonstrated by an initial performance test using EPA
Reference Methods 9 and 12. The regulation includes monitoring and record
keeping requirements, which will be discussed in detail in section 2.2.4.
2.2.3. Applicability of the Standards.4
2.2.3.1. Affected Facilities. The affected facilities included in this
source category are the grid casting facility, paste mixing facility, three-
process operation facility, lead oxide manufacturing facility, lead
reclamation facility, and other lead emitting operations. These devices are
defined as follows:
- The grid casting facility is the facility which includes all
lead melting pots and machines used for casting the grid used in
battery manufacturing.
- The paste mixing facility is the facility which includes
lead oxide storage, conveying, weighing, metering, and
charging operations; paste blending, handling, and cooling
operations; and plate pasting, take-off, cooling, and
drying operations.
2-3
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- The three-process operation facility is the facility
which includes those processes involved with plate
stacking, burning or strap casting, and assembly of
elements into the battery case.
- The lead oxide manufacturing facility is the facility
which produces lead oxide from lead, including product
recovery.
- The lead reclamation facility is the facility which
remelts lead scrap and casts it into lead ingots for use in
the battery manufacturing process, and which is not a
furnace affected under Subpart L.
- Other lead emitting operations are any lead-acid battery
manufacturing plant operations from which lead emissions
are collected and ducted to the atmosphere and which are
not part of a grid casting, lead oxide manufacturing,
lead reclamation, paste mixing, or three-process
operation facility, or a furnace affected under
Subpart L.
2.2.3.2 Applicability Date. The NSPS applies if the construction or
modification commenced after January 14, 1980, (the date of the original
proposal of the regulation) for any affected facility. The term "commenced"
is defined in the General Provisions to 40 CFR 60, (Section 60.2);
"Commenced means that an owner or operator has undertaken a continuous
program of construction or modification or that an owner or operator has
entered into a binding agreement or contractual obligation to undertake and
complete, within a reasonable time, a continuous program of construction or
modification."
2.2.3.3. Modification. Uhile NSPS are intended primarily for newly
constructed facilities, existing sources can become subject to an NSPS
2-4
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through either "modification" or "reconstruction." These terms are defined
in detail in the General Provisions for Part 60, (40 CFR 60.14 and 40 CFR
60.15).
An existing facility becomes subject to the NSPS under the modification
provisions if there is any physical or operational change that causes an
increase in the emission rate. A number of clarifications, exemptions, and
exceptions to the modification provision are listed. The following actions
by themselves are not considered to be modifications:
- routine maintenance, repair, and replacement
~ production increases achieved without any capital
expenditure
~ production increases resulting from an increase in the
hours of operation
~ use of an alternative fuel if the existing facility was
originally designed to accommodate such an alternative
use
• addition or replacement of equipment for emission control
(as long as the replacement does not increase emissions)
" relocation or change of ownership of an existing
facility.
Also, the addition or modification of one facility at a source will not
cause other unaltered facilities at that source to become subject to the
NSPS.
2.3.3.4. Reconstruction. An existing facility becomes subject to the
NSPS upon reconstruction regardless of any change in the rate of emissions.
Reconstruction is defined as the replacement of components of an existing
facility to the extent that the cumulative fixed capital cost of the new
components exceeds 50 percent of the cost that would be required to
construct a comparable entirely new facility.
2-5
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2.2.4. Testing and Monitoring Requirements.^
The owner or operator of a facility subject to NSPS is required to
conduct performance tests within a specified period after start-up, and
thereafter from time to time as may be specified by the EPA. These
performance tests are required in order to demonstrate that the standards
are being met by the new device. General testing, monitoring, and reporting
requirements are listed in the General Provisions for 40 CFR Part 60,
(Sections 60.7, 60.8, and 60.13), while details specific to this source
category ar found in Subpart KK, (Section 60.374).
The initial test of performance of a facility must be conducted within
60 days after the facility first achieves its maximum intended rate of
operation, but not later than 180 days after the initial startup. Thirty
days must be allowed for prior notice to the EPA, to allow the Agency to
designate an observer to witness the test.
To demonstrate compliance with the standards limiting lead emissions,
EPA Reference Method 12 is used to measure lead concentrations. The
sampling time for each run shall be at least 60 minutes and the sampling
rate shall be at least 0.85 dscm/h (0.53 dscf/min). Lead emissions from
lead oxide manufacturing facilities, expressed in terms of mass emissions
per mass of lead charged, is determined using the concentration of lead in
the exhaust stream, the volumetric flow rate of the exhaust stream, and the
lead feed rate to the facility. EPA Reference Method 9 is used to
demonstrate compliance with the opacity regulations.
For any affected facility controlled by a scrubbing system, the
pressure drop across the scrubbing system is to be measured and recorded at
least once every 15 minutes. These records must be kept on file for at
least two years. Pressure drop monitoring and recording is also required
during all performance testing.
2-6
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2.3 REFERENCES
1. Clean Air Act as Amended, August 1977. 42 U.S.C. Title I -- Air
Pollution Prevention and Control. Part A — Air Quality and
Emission Limitations: Section 111 — Standards of Performance for New
Stationary Sources. Washington, DC.
2. Reference 1, Section 114 -- Inspections, Monitoring, and Entry.
3. Reference 1.
4. U.S. Environmental Protection Agency. Code of Federal
Regulations. Title 40, Part 60. Office of the Federal
Register.Washington, DC July 1, 1985.
5. Reference 4.
2-7
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3.0 THE LEAD-ACID BATTERY INDUSTRY
3.1 GENERAL
The largest single use of lead in the United States is in the manufacture
of lead-acid, or secondary, storage batteries. There are approximately 90
lead-acid battery manufacturing facilities in the United states, scattered
throughout the country.1'2 These facilities are generally located in highly
urbanized areas near markets for their batteries, and can range in size from
one small plant producing a single type of battery, to a large complex of
several plants producing many different types of batteries. Some of the larger
facilities have secondary smelting operations, or lead oxide production
facilities, or both; smaller firms tend to purchase the lead constituents from
outside vendors. Table 3-1 lists U.S. lead-acid battery manufacturing
facilities as of October, 1988.
3.1.1 Industry Profile
Two major types of lead-acid storage batteries are manufactured in the
United States: 1) starting-lighting-ignition (SLI) batteries, used in
automobiles, golf carts, and aircraft, SIC (Standard Industrial Classification)
36911, and 2) industrial storage batteries for low-voltage power systems,
industrial fork-lift trucks, and the like, SIC 36912.
SLI units by far account for the majority of the North American Battery
Industry.8 SLI battery shipments in 1987 were valued at $2.10 billion
(1982$)', accounting for 0.055 percent of the 1987 gross national product (GNP)
of $3808 billion (1982 $)'.
The battery industry receives lead from two sources: mines and secondary
lead smelters. United States mine production of recoverable lead in 1985 was
413,955 Mg (456,303 tons).10 Secondary lead recovery in 1985 was 594,200 Mg
(654,987 tons).10 The storage battery industry consumed 853,824 Mg (941,164
tons) of lead in 1986.n Lead consumption by individual products in the years
1982 through 1986 is summarized in Table 3-2.
3-1
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TABLE 3-1. UNITED STATES LEAD ACID BATTERY
MANUFACTURING FACILITIES ''•-^•'•'
COMPANY
MANUFACTURING LOCATIONS
Acme Battery Manufacturing Co.
St. Louis, MO
Alaska Husky Battery, Inc.
Anchorage, AK
AMP King Battery Co.
San Francisco, CA
Atlantic Battery Company, Inc.
Watertown, MA
Battery Builders, Inc.
Naperville, IL
Bell City Battery Manufacturing Co.
Belleville, IL
C&D Power Systems, Inc.
Plymouth Meeting, PA
St. Louis, MO
Anchorage, AK
San Francisco, CA
Watertown, MA
Naperville, IL
Belleville, IL
Conyers, GA
Huguenot, NY,
Leola, PA
Car-Go Battery Company
Denver, CO
Continental Battery Manufacturing Co.
Dallas, TX
Crown Battery Manufacturing Co.
Fremont, OH
Daniell Battery Manufacturing Co.
Baton Rouge, LA
Delco Remy Division of G.M.
Anderson, IN
Douglas Battery Manufacturing Co.
Winston-Salem, NC
Dyno Battery Co.
Seattle, WA
Denver, CO
Dallas, TX
Fremont, OH
Baton Rouge, LA
Anaheim, CA
Fitzgerald, GA
Muncie, IN
Olathe, KS
New Brunswick, NJ
Winston-Salem, NC
Seattle, WA
3-2
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TABLE 3-1.
UNITED STATES LEAD ACID BATTERY
MANUFACTURING FACILITIES (Continued)
COMPANY
MANUFACTURING LOCATIONS
East Penn Manufacturing Co.,
Lyon Station, PA
Electro-Lite Battery Co.
Chattanooga, TN
Estee Battery Co.
Commerce, CA
Exide Corporation
Reading, PA
Inc.
Lyon Station, PA
Chattanooga, TN
Commerce, CA
City of Industry, CA
Visalia, CA
Burlington, IA
Manchester, IA
Frankfort, IN
Logansport, IN
Salina, KS
Richmond, KY
Allentown, PA
Hamburg, PA
Reading, PA
Greer, SC
Sumter, SC
Farmland Industries, Inc.
Kansas City, MO
Gates Energy Products, Inc.
Denver, CO
GNB Incorporated
St. Paul, MN
Kansas City, MO
Denver, CO
Warrensburg, MO
Ft. Smith, AR
City of Industry,
Sun Valley, CA
Orlando, FL
Columbus, GA
Kankakee, IL
Kansas City, KS
Leavenworth, KS
Shreveport, LA
Florence, MS
Salem, OR
Dunmore, PA
Memphis, TN
Dallas, TX
Lynchburg, VA
CA
3-3
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TABLE 3-1.
UNITED STATES LEAD ACID BATTERY
MANUFACTURING FACILITIES (Continued)
COMPANY
MANUFACTURING LOCATIONS
Interspace Battery Co,
West Covina, CA
Johnson Controls, Inc.
Milwaukee, WI
K.W. Battery Company
Skokie, IL
Miami Battery Manufacturing Co.
Miami, FL
Mule Battery Company, Inc.
Providence, RI
New Castle Battery Manufacturing Co.
New Castle, PA
Norton Battery Manufacturing, Inc.
Rial to, CA
Old Ironsides, Inc.
Campbell sport, WI
Pilot Batteries, Inc.
Kankakee, IL
Powerstone Batteries Inc./Keystone Batteries
Fairfield, CA
Prime Battery Manufacturing Co.
Anderson, IN
Prime Battery Mfg. Co./West Kentucky Battery
Benton, KY
West Covina, CA
Fullerton, CA
Middletown, DE
Tampa, FL
Geneva, IL
Louisville, KY
Owosso, MI
St. Joseph, MO
Winston-Salem, NC
Holland, OH
Canby, OR
Garland, TX
Bennington, VT
Milwaukee, WI
Skokie, IL
Miami, FL
Providence, RI
New Castle, PA
Rialto, CA
Campbell sport, WI
Kankakee, IL
Fairfield, CA
Anderson, IN
Benton, KY
3-4
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TABLE 3-1. UNITED STATES LEAD ACID BATTERY
MANUFACTURING FACILITIES (Continued)
COMPANY
MANUFACTURING LOCATIONS
Ray Glass Batteries, Inc.
Thomasville, GA
Sound Battery Company, Inc.
Tacoma, WA
Standard Industries
San Antonio, TX
Standard Storage Battery Co.
St. Paul, MN
Surrette Storage Battery Co.
Tilton, NH
Teledyne Battery Products
Redlands, CA
Trojan Battery Co.
Santa Fe Springs, CA
U.S. Battery Manufacturing Co.
Signal Hill, CA
Voltmaster Company, Inc.
Corydon, IA
Thomasville, GA
Tacoma, WA
San Antonio, TX
St. Paul, MN
Tilton, NH
Redlands, CA
Santa Fe Springs, CA
Lithonia, GA
Signal Hill, CA
Evans, GA
Corydon, IA
3-5
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TABLE 3-2
CONSUMPTION OF LEAD IN UNITED STATES11
BY PRODUCT CATEGORY
Lead Content - Short Tons
M«UI Products Total
Ammunition - shot & bullets
Bearing metals total
Machinery except electrical
Electncal 4 electronic equipment
Motor vehicles & equipment
Other transportation equip.
Brass 4 bronze - billets 4 ingots
Cable covering - power & communication
Calking lead - building construction
Casting metals total
Electncal machinery & equipment
Motor vehicles 4 equipment
Other transportation and equipment
Nuclear radiation shielding
Pipes, traps 4 other extruded
products total
Building construction
Storage tanks, process vessels, etc.
Sheet lead total
Building construction
Storage tanks, process vessels, etc.
Medical radiation shielding
Solder total
Building construction
Metal cans 4 shipping containers
Electronic components 4 accessories
Other electrical machinery 4 equipment
Motor vehicles 4 equipment
Storage battery gnds. posts, etc. total
Storage battenes - SLI automotive
Storage battenes - ndustnal 4 traction
Storage battery oxides total
Storage battenes - SLI automotive
Storage battenes - ndustnal 4 traction
Teme metal - motor vehicles 4 equipment
Type metal - printing 4 allied industnes
Other metal products (a)
Other Oxides Total
Paints
Glass 4 ceramic products
Other pigments
Gasoline Additives
Miscellaneous Uses
Total
1982
965,436
48.763
6,761
1.340
106
2.227
3.088
12.513
16.734
4.471
27,626
884
724
26.018
(C)
9.567
9,100
467
16.710
11.011
138
5.561
31.416
7,430
8.223
6,577
2.978
6,208
344.562
313.891
30.671
431,820
410.150
21.670
3.624
3.049
7.820
67,093
14,743
38.059
14.291
131,433
21,471
1.185.433
1983
1,068,093
48.168
6.442
1.414
155
3.095
1.778
12.103
11.580
3.937
17.907
1,408
761
6.214
9.524
14,348
14.078
270
15,702
12.058
143
3.501
31.405
8.327
5.667
6.255
2.681
8.475
421.453
(b)
(b)
468.000
(b)
(b)
5.574
2.800
8.674
75,722
17022
43.729
14,971
98.236
23,938
1,265,989
1984
1,131,327
52.721
5,155
985
280
3.194
696
7.665
13.525
4.372
17,422
1.818
840
3.723
6.041
15.055
12.534
2,521
16.165
14.746
176
1.243
26,941
7,212
3.610
5.909
2.454
7,756
469.915
(b)
(b)
484.181
Ib)
(b)
6.695
2.383
9.132
84,666
19.136
50.819
14,71 1
87.009
27,521
1.330,523
1985
1,104,437
55.372
5,943
366
274
4,271
1.032
3.623
17.087
2.522
21.399
2.030
1.124
12.285
5.960
13.068
12.629
439
16.349
12.562
1.766
2.021
23.560
4,926
3.190
4.615
2,363
7,966
516.703
(b)
(b)
410,273
(b)
(b)
5,609
1.789
6 140
80^208
15 494
48,663
16,051
50\369
30.764
1.265,778
1986
1,102,160
48.923
6.089
640
295
4,174
980
9.241
18.807
2.021
11.319
1.321
1.496
7.485
1.017
13.325
13.117
708
19.043
13.858
2,247
2,938
23.482
4,975
2258
4,776
2.421
9.052
538.955
(b)
(b)
402.209
(b)
(b)
3.355
337
4,054
76 540
1 5,373
44'953
, C Q * A
J, O 1 **
31.461
29!671
1.239,932
3-6
-------
Total United States battery shipments reached 75.7 million SLI units in
1986.n Figures 3-1 and 3-2 show the shipments of SLI units (replacement,
original equipment, and exports) since 1942. Shipments of replacement units
have shown steady growth over the past ten years, accounting for nearly 80
percent of the 1986 SLI battery shipments.12 Tables 3-3 and 3-4 summarize SLI
battery use from 1982 to 1986. Approximately 80 percent of the SLI units are
used in automobiles.13 Preliminary values for 1987 United States battery
shipments (not including exports) are 59.5 million replacement units and 13.1
million original equipment units.1*
The other major type of lead-acid storage battery manufactured in the
United States is industrial storage batteries. There are two major categories
of industrial batteries, motive power and stationary. As of 1985, the motive
power sector accounted for annual sales in the range of $200 million, with
approximately $175 million in annual sales being attributed to the stationary
sector.18 At that time, over 85 percent of the motive power category market
was for forklifts and material handling equipment, and over 75 percent of the
stationary market was for telecommunications and UPS (uninterrupted power
source).18
Growth is expected in the future for both the SLI and industrial battery
markets. SLI battery shipments are expected to increase 4.5 percent annually
between 1987 and 2000.19 In 1985, it was estimated that the industrial battery
market would experience annual growth of two to five percent through 1989.18
The trend is toward fewer, larger plants, with the already small number of
small plants decreasing.20
3.1.2. Process Description
A lead-acid battery consists of any number of cells, depending on the
voltage of the battery. Stationary batteries contain up to 120 cells (240
volts), whereas automobile batteries generally contain 3 or 6 cells (6 or 12
volts). Lead acid storage batteries range in size and weight. The electrodes
are made of lead, and the electrolyte consists of a solution of sulfuric acid
and water. The cathode consists of lead peroxide and the anode consists of
porous or spongy lead. Both the anode and the cathode are converted to lead
sulfate when the battery is discharging. Many complicated chemical reactions
take place inside a lead-oxide battery during discharge, resulting in
3-7
-------
FIGURE 3-1
U.S. TOTAL SHIPMENTS* OF S.LI. BATTERIES
MILLIONS OF UNITS
15
1942
1943
1944
1945
1946
1947
1948
1949
1950
70
60
50
40
30
20
S
z
o 10
at
O
3
16.5
18.1
20.4
19.0
21.0
31.2
31.0
26.2
32.9
1951 29.7 1960 34.4 1969 46.4 1978 73.2
1952 28.4 1961 35.2 1970 46.9 1979 69.3
1953 31.3 1962 39.0 1971 50.6 1980 61.7
1954 30.8 1963 41.0 1972 55.5 1981 65.5
1955 35.4 1964 39.1 1973 57.1 1982 64.6
1956 32.3 1965 40.8 1974 55.6 1983 69.0
1957 33.4 1966 41.6 1975 52.9 1984 74.7
1958 30.6 1967 40.2 1976 64.1 1985 74.4
1959 34.4 1968 45.0 1977 70.7 1986 75.7
ir S
r •
T
T
•T
§ £ * S
?SES8S88£88§£S3S!88£3Sg£££S£^®OT0^CT™
-------
FIGURE 3-2
BREAKDOWN OF U.S. BATTERY SHIPMENTS (1942-86)
YEAR
1942
1943
1944
1945
1946
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
REPLACEMENT
MILLIONS OF
15.2
17.0
19.1
17.6
17.5
25.8
25.1
19.4
24.4
22.2
22.5
23.6
23.8
25.8
25.0
25.9
25.3
27.5
26.3
23.3
30.5
31.7
ORIGINAL
EQUIPMENT
UNITS
1.0
.7
.7
.7
3.1
4.8
5.3
6.3
8.0
6.8
5.5
7.3
6.6
9.2
6.9
7.2
5.1
6.7
7.9
6.7
8.2
9.1
EXPORT
12V, 6V
.3
4
.6
.7
4
6
.6
.5
.5
.7
4
4
4
4
4
3
.2
.2
.2
2
.3
.2
YEAR
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
REPLACEMENT
29.6
29.5
31.1
31.0
33.8
35.5
37.9
39.1
43.2
43.5
44.4
42.6
49.2
54.6
56.4
53.7
50.1
53.6
54.2
56.1
593
58.7
60.3
ORIGINAL
EQUIPMENT
9.3
11.1
10.3
9.0
10.7
10.1
8.2
10.6
11.3
12.6
10.1
9.0
13.4
14.7
15.2
14,4
10.0
10.0
8.4
10.8
12.8
13.5
13.3
EXPORT
12V. 6V
2
2
2
2
.5
.8
.8
.9
1.0
1 0
1.1
1.3
1 5
1.4
1 6
1 2
1 6
1 9
20
2.1
2.6
2.2
2.1
U.S. EXPORT, ORIGINAL EQUIPMENT, REPLACEMENT
80-
70~i (MILLIONS OF UNITS)
60 H
50-i
40-j
30-i
ORIGINAL EQUIPMENT
YEAR
3-9
-------
TABLE 3-3
UNITED STATES
REPLACEMENT BATTERY SHIPMENTS:
PRODUCT CATEGORY (OOO's) I3
PRODUCT CATEGORY
Passenger Car:
12 Volt
6 Volt
Heavy Duty:
12 Volt
6 Volt
Special Tractor
Marine
General Utility
Golf Car
Miscellaneous
Total
1982
44.207.8
1,460.7
2,002.9
1,719.7
751.3
1,414.4
1,156.2
866.2
255.7
53,834.9
UNITED STATES
ORIGINAL EQUIPMENT BATTERY
PRODUCT CATEGORY (OOO's)
PRODUCT CATEGORY
Passenger Car:
12 Volt
6 Volt
Heavy Duty:
12 Volt
6 Volt
Special Tractor
Marine
General Utility
Golf Car
Miscellaneous
Total
1982
7,384.5
31.2
451.1
30.9
28.8
9.7
319.5
67.6
0.0
8,373.3
1983
1984
45.080.0 47,354.5
1.282.7 1,234.0
2,379.6
1,705.0
853.8
1,770.5
1,395.7
915.0
329.7
55,712.0
SHIPMENTS
1983
9,576.6
34.5
499.9
44.7
32.0
4.6
473.8
150.2
0.0
10.816.3
2,757.6
1,775.2
878.8
2.003.9
1,477.2
1,175.7
260.2
58,917.1
•
1984
10.936.0
12.3
838.2
52.5
43.1
5.3
669.7
208.1
0.0
12,765.2
1985
46.685.6
1.095.0
2.766.0
1.656.8
785.6
2.097.3
1,591.4
1,270.9
324.1
58.272.7
fg
1985
11.656.9
12.1
6670
42.6
29.5
6.7
748.1
303.6
0.0
13.466.5
1986 ^
47.682.1
960.8
3.031.1
1,557.5
842.5
2,442.5
1,748.4
1.303.3
315.6
59.883.8
^P^-
^H^^SSH
•Mil
1986 ^
w
11.320.1
7.7
716.0
33.8
16.8
28.9
778.0
370.7
0.0
13.272.0
3-10
-------
TABLE 3-4
U.S. BATTERY SHIPMENTS
17
REPLACEMENT AND ORIGINAL EQUIPMENT
SHARES BY PRODUCT CATEGORY (%'s)
1982
1983
1984
1985
1986
PRODUCT CATEGORY %R/%OE %R/%OE %R / %OE %R/%OE %R / %OE
Passenger Car, Light
Commercial -12 V 86/14 82/18 81/19 80/20 81/19
6V 98/2 97/3 99/1 99/1 99/1
Heavy Duty Commercial
12V 82/18 83/17 77/23 81/19 81/19
6V 96/4 97/3 97/3 97/3 98/2
Special Tractor
Marine
General Utility
Golf Car
96/4
99/1
78/22
93/7
96/4
100/0
75/25
86/14
95/5
100/0
69/31
85/15
96/4
100/0
68/32
81/19
98/2
99/1
69/31
78/22
3-11
-------
neutralization of the two plates and weakening of the electrolytic solution by
formation of water. Figure 3-3 shows the components of a battery.
The electrodes, or plates, consist of two parts: (1) an inactive lead
grid, which provides mechanical support for the active portion (the plate) and
a conductive path for the electric current, and (2) a lead oxide sulfate paste,
which is applied and bonded to the grids. Other materials in the lead-acid
battery include plastic separators or envelopes, and the outer case materials,
which are usually vulcanized rubber, polypropylene, nylon, or acrylics. Figure
3-4 shows the arrangement of battery components in an element.
Consumer attention has recently been directed toward the waterless or
"maintenance free" batteries. These batteries are typically supplied without
vent plugs or provisions for adding water. Though they appear to be totally
sealed, they are always vented in some way, usually by small holes in the top
of the battery case. These batteries are practically identical to the
conventional battery except in appearance; they all use lead-lead peroxide
plates in a sulfuric acid electrolite. There are subtle differences in the
lead alloy used in some of the plates (usually a substitution of calcium for
the antimony) and generally they do consume so little water during normal
operation that water addition is usually unnecessary during the life of the
battery. However, manufacturing processes for these batteries, and the
attendant emissions, are for all practical purposes identical to those for the
conventional battery. Therefore, this document makes no distinction between
this style of battery and conventional batteries.
Lead oxide (gray or black lead) is used in preparing the active materials.
Many battery plants prepare the oxide in-house, and several processes are used.
A process flow diagram for the manufacture of lead-acid storage batteries
is shown in Figure 3-5. As the figure indicates, this study encompasses only
the battery manufacturing process and production of lead oxide (PbO); it does
not include lead smelting operations, which are covered by separate new source
performance standards.
Battery manufacturing begins with grid casting and paste mixing. The
grids are generally cast in doublets (two grids per casting) from molten lead
to which calcium or antimony has been added to provide hardness. These grids
3-12
-------
VENT PLUG
GASKET
VISUAL LEVEL FILL
PLATE STRAP
PLATE
BRIDGE
CELL COVER
TERMINAL POST
PROTECTED CELL
CONNECTOR
CASE
SEDIMENT CHAMBER
FIGURE 3-3. A lead-acid storage battery.
21
3-13
-------
NEGATIVE PLATE GROUP-
SEPARATORS,
POSITIVE PLATE GROUP
POSITIVE PLATE
CELL TERMINAL
PLATE STRAP
NEGATIVE PLATE
FIGURE 3-4. Components of a battery element
(shown pulled apart).
22
3-14
-------
LCAD IICDII
CUB
CASH 16
fUllACI
COIIIOL
OCVICC
COIIML
UllCf
COIIIOL
Mild
0110
fAIII1C
PLAII
1IACIIIC
CUhCII
IUIIIIC
DRY BATTERY LINE
CIMtll
ASSEMBLt
EIHAUSI SlICAM
PIOCKSS ftlEAM
LCAD IClAf .
ltA»
IICUMIIOI —• I IAD ,ICOII
IACILIII I
mine
AID
on no
COITIOl
DIIICI
roiM
1
IICI
DU<4P
D
AC
0
ASSf«ll.l li
lAIItll CASI
ACID
term.
0
DOOII
•AS!
AID
fAIII
HET BATTERY LINE
FIGURE 3-5. Process Flow Diagram
-------
are coated with either positive or negative paste, formed (a process discussed
later), cured, cut into two separate grids (a process called slitting) and then
sent to be assembled into batteries.
Except for the lead oxide manufacturing facility, the particulate
pollutant catch from the pollution control systems, whether wet or dry, is
reclaimed by a lead smelter. The particulate captured from the lead oxide
manufacturing operation is used in the paste mixer.
3.2 GRID CASTING
Techniques for casting of grids vary with the alloy used, the type of
molds, and mold preparation before casting. Molten lead alloy ingots are
melted in electric or gas-fired lead pots at approximately 370°C (700°F).23
The furnace is often equipped with a hood to vent the fumes to a control device
or to the atmosphere.
In some grid casting operations, melting pots are attached directly to the
casting machines. The molten lead flows from the pots directly into the molds,
where the grids are formed and then are ejected, trimmed, and stacked. A newer
type of casting machine produces a continuous strip of grids, rather than
individual 2-grid panels, which is wound on a reel, or fed directly into the
pasting line.24' "• " Some facilities feed the casting machines from a central
pot furnace, from which the molten lead is either pumped or fed by gravity.
Pumping may cause air to be entrained in the molten lead, resulting in problems
at the molding machines. Entrained air is not a problem with grid casting
machines that are fed by gravity flow.
Emissions from the grid casting operations are lower than emissions from
some of the other facilities in a battery manufacturing plant. Some
manufacturers control emissions from this operation and others do not.
Exhausts from the grid casting furnace are usually vented to the atmosphere to
protect workers from the lead emissions. The areas around the casting machines
are generally unvented. Testing of a grid casting facility during the original
NSPS development project indicated uncontrolled lead concentrations ranging
from 0.00039 gr/dscf to 0.0026 gr/dscf."
Another process for grid production is called "expanded metal." A thin,
narrow strip of lead "sheet" first has small slits punched into it, and then is
expanded into a continuous strip of grids.28 This strip often feeds directly
into a pasting 1 ine.
3-16
-------
3.3 PASTE MIXING
The paste mixing operation, a batch-type process, is done with a muller,
Day, or dough-type mixer. From 272 to 1361 kg (600 to 3000 Ib) of lead oxide
is added to the mixer; water and sulfuric acid are then added, and the mixture
is blended to form a stiff paste.27 Because reactions of the process are
exothermic, mixers are usually water-jacketed and air-cooled to prevent
excessive temperature buildup which causes the paste to become stiff and
difficult to apply to the grids. Approximately 1 weight percent of expander
(generally a mixture of barium sulfate, carbon black, and organics) is added to
batches of paste for negative plates." Carbon black also provides color
identification for the negative paste. A duct system vents the moisture-laden
exhaust gases from the mixer. The duration of the mixing cycle depends on the
type of mixer, ranging from 15 minutes to an hour." Typical formulas for
positive and negative pastes are shown in Table 3-5.
TABLE 3-5. TYPICAL FORMULAS FOR POSITIVE AND
NEGATIVE BATTERY PASTES29
IngredienTPositiveNegative"
Lead oxide, kg (Ib)272 (600)272 (600)
Dynel fiber, kg (Ib) 0.068 (0.15) 0.068 (0.15)
Expander, kg (Ib) None 1.90 (4.2)
Water, liter (quart) 23 (25) 26 (28)
HZS04 (1.375-1.400 s.g.), 25 (26) 21 (22)
1iter (quart)
3-17
-------
The major emissions from paste mixing occur during charging of the dry
ingredients to the mixer. The high-emissions phase is about the first 10
minutes of a 60-minute mixing cycle. The emissions are in the form of lead
oxide, with small amounts of other paste constituents such as Dynel, organics,
and carbon black.
Source tests were performed during the original NSPS development project
at a facility where the mixer was vented to a baghouse during materials
charging and to a low energy impingement entrainment scrubber during mixing.
The baghouse also controlled the plate slitting operation, and the scrubber
also controlled the grid casting operation. Two tests run at the baghouse
inlet during charging showed uncontrolled lead emissions of 0.050 and 0.015
gr/dscf. A single test to determine emissions from the slitting process
indicated uncontrolled lead emissions of 0.0188 gr/dscf."
The paste is next applied to the grids, they are flash dried, and then
stacked and sent to curing ovens. These ovens most often operate under
conditions of high humidity, but occasionally supply only dry heat, depending
upon the desired plate characteristics. Grids produced by continuous casting
or expanded metal are pasted while still in strip form, and cut into individual
grids prior to drying and curing. Some facilities apply a layer of tissue
paper to each side of the continuous wet pasted strips of grids before cutting
them. This tissue paper helps hold the paste in place, and decreases
emissions.28
3.4 THREE-PROCESS OPERATION STACKING/BURNING/ASSEMBLY
After the plates are cured, they are normally sent to the three-process
operation, which includes plate stacking, burning, and assembly of elements
into the battery case. Most plants are equipped with an associated plate
slitter, which cuts the double plates apart. Depending upon the individual
plant's design, the plate slitter can be considered part of the paste mixing
facility, three-process facility, or the "other lead emitting" facility. At
some plants the plates are parted by hand, after which they are stacked in an
alternating positive and negative block formation with plastic separators
sandwiched between each plate to insulate the oppositely charged plates while
permitting free ionic flow. Many plants now insert the positive plates in
envelopes, and then stack, rather than using separators. These envelopes are
3-18
-------
made of several materials, one of which is PVC. Machines have been designed to
stack the plates and separators automatically, or envelope and stack, but hand
stacking is still done at some plants. In some instances, the battery plates
are wrapped in a fiberglass mat before stacking. This mat will absorb the acid
in the battery, and help minimize spilling or leakage should the unit overturn.
Leads (pronounced leeds) are welded to the tabs of each positive plate and
each negative plate, fastening the assembly (element) together. Then a
positive and a negative terminal are welded to the element. This is the
burning operation. A more common alternative to the welding or burning process
is the cast-on-strap process, in which molten lead is poured around and between
the plate tabs to form the connections and terminals. The completed elements
are then assembled into battery cases either before wet formation or after dry
formation. The difference between wet and dry formation is explained in
Section 3.5.
Most lead emissions are generated during plate stacking and burning or
casting operations. Handling of plates between process steps also generates
considerable lead emissions. Typically, operators straighten stacks by
striking them against a grated surface. Upon impact, particles of paste become
airborne. Work areas are generally vented to collect these particles and to
protect the health of the workers.
Source tests during the original NSPS development project indicated that
uncontrolled lead emissions from the three-process operation ranged from 0.0087
to 0.023 gr/dscf.30 These tests indicated total three-process emissions, since
testing of each process step in the facility was not feasible.
The post building operation is often included in the three-process
facility. This is the attachment of the positive and negative terminal posts
to the outside of the battery case. Depending upon the individual plant's
design, this operation can be considered part of either the three-process
facility, or the "other lead emitting" facility.
3.5 FORMATION
During formation, the inactive lead oxide-sulfate paste is chemically
converted into an active electrode. Formation is essentially an oxidation-
reduction reaction, in which the lead oxide in the positive plates is oxidized
to lead peroxide and in the negative plates is reduced to metallic lead. This
3-19
-------
is accomplished by placing the unformed plates in a dilute (10-25 percent)30
sulfuric acid solution and connecting the positive plates to the positive pole
of a direct current (dc) source and the negative plates to the negative pole of
the dc source.
During the formation process, hydrogen is released in the form of small
bubbles, which carry sulfuric acid with them as they break through the surface
of the solution and enter the atmosphere above the container. The process,
therefore, is a source of sulfuric acid mist emissions.
Charging rate and temperature affect the emissions of sulfuric acid mist,
which generally increase with increasing temperature and rate of charge. Also,
as the process nears the end of the formation cycle, the release of hydrogen
bubbles increases. Emissions therefore increase with time.
3.5.1 Wet Formation Process
In the manufacture of lead-acid batteries using the wet (or "jar")
formation process, the elements are assembled into the case before forming. It
is common practice to place the cells in the battery case, place the lid on the
battery, and add sulfuric acid. The plates are then formed within the battery
case. After formation, additional acid is added to completely fill the
battery, or the spent acid is dumped from the battery and new acid is added.
Often, the units require an additional boost charge. Then the unit is ready
for use, requiring only decoration and manufacturer's markings.
Wet formation generally takes 1 to 4 days. Most plants use a 36- to 48-
hour forming cycle. The charging rate is high during the first 24 to 36 hours
and lower during the remaining 12 hours. The ampere rates depend on the
battery size.31
Sulfuric acid mist emissions from wet formation processes are usually not
controlled or ducted to a stack. Therefore, no data are available on
quantitative emissions from the wet formation process. However, because of the
slow charging rate, the fact that there is a lid or cap on the battery during
formation, and the absence of a strong acid odor at wet formation processes,
emissions from the process are believed to be small.
3.5.2 Dry Formation Process
The dry (or "tank") formation process can be performed in several ways.
In some cases, the plates are individually formed in tanks of sulfuric acid and
3-20
-------
then assembled. Most often, however, the plates are assembled into elements
before formation. The completed elements are then formed by placing the
elements in large tanks of sulfuric acid and making an electrical connection to
form the elements. Some manufacturers place the assembled elements directly in
the battery case for formation. Thereafter, they remove the formed elements,
dump the acid, rinse and dry the cases and elements, and reassemble them. The
batteries are shipped dry, or refilled with acid at this point. Dry formation
typically lasts 16 hours, with the plates or elements loaded into tanks during
the day shift, and formed during the evening and night shifts. Occasionally,
following dry formation, the plates or elements are cured in dry charge ovens
prior to reassembly.32 This process, however, is becoming less prevalent
within the battery industry.
When forming batteries by the dry formation process, the acid mist can be
controlled by the use of mist eliminators or scrubbers, or by some sort of
cover over the acid bath or receptable. The cover is often a surface foaming
agent such as Alkonol or Dupanol.
Two dry formation processes were sampled by EPA during the original NSPS
development process. The first test did not yield any valid results because
the process was not operating properly (one of the three formation circuits was
inoperative). Also, acid mist emissions from the control device were not
detectable when EPA Reference Method 8 was used to collect emissions over a two
hour sampling period. The second EPA test showed uncontrolled acid mist
emissions toward the end of the cycle to average 66 mg/m3 (0.029 gr/dscf, 0.70
lb/hr).33
3.6 LEAD OXIDE PRODUCTION
The lead monoxide used in battery paste production is called lead oxide,
black oxide, or battery oxide. The typical lead oxide contains approximately
70 percent PbO." The balance is free metallic lead. Lead oxide is produced
either by the ball mill process or Barton process.
Each of the lead oxide manufacturing processes incorporates a baghouse for
product recovery, since the value of the product is relatively high. Air-to-
cloth ratios of these fabric filters generally are about 3/1, whether the
filters are designed for product recovery or for emissions control. As a
result, emissions from the lead oxide production facility are lower than
emissions from some of the other facilities at a battery manufacturing plant.
3-21
-------
3.6.1 (foil Mill Process
In the ball mill process, oxidation is initiated by heat generated by
tumbling pure lead pigs (ingots) in a mill. During the tumbling action the
lead oxide that forms on the surface of the lead pigs and fine particles of
unoxidized lead are broken off, forming a fine dust that is removed from the
mill by a circulating air stream. The larger fraction is ground further in a
hammermill. Air flow through the mill, the temperature of the charge, and the
weight of the charge are controlled to produce a specified ratio of lead oxide
to finely divided metallic lead. The product is conveyed by totally enclosed
screw conveyors, or pneumatic systems, to storage bins. Enough product is
entrained in the mill exhaust gases to justify gas cleaning for product
recovery. Fabric filtration is also a part of the process.
Tests performed during the original NSPS development project yielded
average lead emissions of 0.475 g/kg (0.0095 Ib/ton) of lead input.34 This
plant operated two ball mill production lines equipped with fabric filters, one
with an air-to-cloth ratio of 2/1 and the other with a ratio of 4/1. The
filters were vented to a common stack.
3.6.2 Barton Process
In the Barton process, molten lead is fed to a circular pot and stirred
rapidly. A series of baffles within the pot atomize the lead into extremely
small droplets, which are then oxidized by an air stream directed over the
surface of the molten lead. The resulting lead oxide is conveyed by the air
stream to a fabric filter where the product is removed. The particle-size
distribution, apparent density, and reactivity of the oxide are controlled by
the temperature maintained in the pot and by the volume and speed of the air
stream that carries away the reacted products. The larger particles are
captured in a cyclone prior to the fabric filter and pulverized in a
hammermill. They are then conveyed and collected by the fabric filter.
3.7 LEAD RECLAMATION
Lead reclamation is the process whereby relatively clean lead scrap is
remelted and cast into pigs for use in the process. The melting is generally
done in a pot-type furnace. Scrap, in the form of small parts or defective
grids, is charged to the furnace. This is often done sporadically, only when
enough material is available for charging. Emissions from pot-type furnaces
3-22
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tend to be minimal. The lead is melted at relatively low temperatures and
emissions usually are visible only when oily scrap or floor sweepings are
charged. Source tests performed during the original NSPS development project
on a lead recovery process show uncontrolled lead emissions averaging 298 g/kg
(5.9 Ib/ton) of scrap input.35 Many of the smaller plants have no lead
reclamation facilities and send out the scrap for reclamation.
3-23
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3.8 REFERENCES
1. Materials from Griffiths, M.N., Battery Council International, to
Michelitsch, D.M., EPA. June 22, 1988. Battery Manufacturing Plants
1987.
2. Letter from Griffiths, M.N., Battery Council International, to
Michelitsch, D.M., EPA. September 23, 1988. Comments on draft report of
June 22, 1988, meeting between BCI and EPA.
3. Battery Council International. 1987 Membership Directory. Chicago,
Illinois. 1987. 32 p.
4. U.S. Environmental Protection Agency. Compliance Data System Report.
February 2, 1988.
5. Letter and attachments from Turlinski, B.E., EPArRegion III, to
Michelitsch, D.M., EPA:ISB. April 7, 1988. Response to request for
information on battery manufacturing plants subject to the NSPS.
6. Memo from Nicewander, M.H., EPA:Region VI, to Michelitsch, D.M., EPA:ISB.
April 20, 1988. Response to request for information on battery
manufacturing plants subject to the NSPS.
7. Memo from Michelitsch, D.M., EPA:ISB, to Durkee K.R., EPA:ISB.
November 7, 1988. Report on July 13, 1988, trip to Trojan Battery
Manufacturing Company, Lithonia, Georgia.
8. Battery Council International. Industry Statistics: 1987. Chicago,
Illinois. 1987. p. 1.
9. Secondary Battery Shipments to Approach $3.8 Billion in 1992. The Battery
Man. 30:10-11. July 1988.
10. U.S. Department of the Interior: Bureau of Mines. Mineral Industry
Surveys: Lead Industry in- August, 1986. October 31, 1986. p. 2.
11. Reference 8, p. 26.
12. Reference 8, p. 1.
13. Reference 8, p. 10.
14. Letter from Hall, L.G., Battery Council International, to Michelitsch,
D.M., EPA. April 22, 1988. United States battery shipment statistics.
15. Reference 8, p. 3.
16. Reference 8, p. 4.
17. Reference 8, p. 9.
3-24
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18. Amistadi, R.L. Battery Shipment Review and Five Year Forecast. The
Battery Man. January 1987. p. 18-20.
19. Reference 9.
20. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB. November
2, 1988. Report on June 22, 1988, meeting with representatives of Battery
Council International. 5 p.
21. U.S. Environmental Protection Agency. Lead-Acid Battery Manufacture
Background Information for Proposed Standards. EPA-450/3-79-028a.
November 1979. p. 3-10.
22. Reference 21, p. 3-11
23. Reference 21, p. 3-15.
24. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.D., EPA:ISB. November
1, 1988. Report on July 26, 1988, trip to Exide Corporation, Reading
Pennsylvania.
25. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.D., EPA:ISB.
December 6, 1988. Report on July 27, 1988, trip to East Penn
Manufacturing Company, Lyon Station, Pennsylvania.
26. Wirtz Continuous Casting and Plate Making System. The Battery Man. 30:
24-25. August 1988.
27. Reference 21, p. 3-16
28. Reference 25.
29. Reference 21, p. 3-17
30. Reference 21, p. 3-19.
31. Reference 21, p. 3-20.
32. Reference 25.
33. Reference 21, p. 3-21.
34. Reference 21, p. 3-22.
35. Reference 21, p. 3-23.
3-25
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4.0 EMISSION CONTROL TECHNOLOGY
The lead-acid battery industry applies various particulate controls,
including baghouses, low energy wet scrubbers, and more recently, cartridge
collectors and secondary high efficiency particulate air filters (HEPA).
Manufacturers often vent a number of processes to the same control device via
a collection system of ducts and hoods. The control systems used at
individual plants depend upon plant layout, applicable OSHA regulations, and
economics of product recovery. The following sections describe emission
control technology applicable to facilities in the lead-acid battery industry.
4.1 GRID CASTING MACHINES AND FURNACES
Emissions from grid casting facilities are often uncontrolled, and many
plants vent this facility directly to the outside air. Some plants have used
low-energy wet scrubbers to control these exhausts. There are also some
applications of fabric filters on this facility.1"6
4.1.1 Scrubbers
An impingement and entrainment scrubber, such as the type N Roto-
Clone,™ is a common device for controlling grid casting emissions. These
units are relatively small, with moderate power requirements (1245 Pa or 5 in.
W.G. pressure drop) and low water requirements (makeup water typically less
than 0.134 1/m3 or 1 gal./lOOO acf). The liquid-to-gas ratio is typically
about 2.6 1/m3 (20 gal./lOOO acf) of exhaust. Collection efficiency is
generally about 90 percent.7
Multiwash centrifugal or cascade scrubbers are also used. These units
typically accommodate up to 1415 m3/min (50,000 acfm) with a liquid to gas
ratio as low as 0.4 1/m3 (3 gal./lOOO acf).'
Frequently, grid casting machines and furnaces are vented along with
other operations, such as small parts casting and lead reclamation, to a
single low-energy scrubber.
4-1
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4.1.2 Fabric Filters
During the original NSPS development project, there were no known
applications of fabric filters on this facility, primarily due to the
anticipation of bag blinding and fire hazards caused by hydrocarbons and mold
release agents. Due to the increased use of spark arresters, better bag
fabrics, and better hygiene practices, the incidence of fires has decreased.
Therefore, fabric filters are now being used to control grid casting emissions
in some cases (most often, this baghouse is controlling other facilities at
the plant as well).1'6'3
At least one facility is still having some difficulties with bag
blinding due to hydrocarbon build-up.9'9 This is believed to be due to the
incomplete combustion of fuel for the melt pots, and the open flame in the
ladle area of the casting machines.9'9 Some proposed solutions to this problem
include the use of Goretex™ bags with a lime precoat, and higher baghouse
operating temperatures.9
4.2 PASTE MIXER
Both baghouses and scrubbers are used to control paste mixing emissions.
Some plants vent the mixer to a baghouse during the material charging phase
and then to a wet collector during the final "wet" mixing and application
phase.
Typically when two control devices are used, other operations are
controlled by the same devices. Use of a scrubber during the wet mixing cycle
prevents possible blinding of the bags by the moist exhaust. The exhaust
stream is transferred from one control device to the other via an
automatically operated damper located at the mixer hood. Emissions from the
pasting lines (where the paste is applied to the grids) are generally
controlled by one of the mixer control devices.
4.2.1 Scrubbers
An impingement entrainment scrubber such as the Type N Roto-Clone™ is
frequently used to control mixing operations. These units are relatively
small, (in the range of 30 to 300 m3/min [1,000 to 10,000 acfm]) with a
pressure drop of approximately 1245 Pa (5 in. W.G.). Makeup water is
generally less than 0.134 1/m3 (1 gal./lOOO acf) and liquid-to-gas ratios
generally are about 2.6 l/mj (20 gal./lOOO acf) of exhaust.10 Most of the
4-2
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water loss is due to evaporation; about 20 percent results from recirculation
tank blowdown. Collection efficiency is approximately 90 percent.'0
4.2.2 Fabric Filters
Fabric filters with air-to-cloth ratios ranging from 4/1 to 8/1 are used
to control particulate and lead emissions from the charging phase of paste
mixing. The bags are typically made from orlon felt, polyester, cotton
sateen, dacron, wool, or Goretex.™ Pressure drops across the bags are 249 to
1494 Pa (1 to 6 inches W.G.)."
In some cases, fabric filters are used to control emissions from the
entire mixing cycle.12"15 However, preventing condensation of moisture
in the fabric filters usually involves insulation of the baghouse and all
ductwork leading to it, and often requires the installation of a small
auxiliary heater to keep the gas temperature above its dew point. This
auxiliary heat is sometimes needed only during startup or shutdown of the
facility. To provide a margin of safety, it is recommended that the gas
temperature be maintained 50-75T above its dew point.16 A properly
maintained baghouse controlling this process can reduce lead emissions by at
least 98 percent.17
4.3 THREE-PROCESS OPERATION (STACKING, BURNING AND ASSEMBLY)
Lead-acid battery plants use fabric filters or scrubbers to control the
three-process operation. Most plants vent the stacking, burning, and assembly
operations into a common duct prior to cleaning the gases. Other plants clean
exhausts from the three-process operation and various other facilities with a
common system.
4.3.1 Fabric Filters
Based on plants surveyed by EPA, the industry typically uses shaker-type
or pulse-jet fabric filters having air-to-cloth ratios of 6/1 to 7/1 to
control three-process emissions. The lead removal efficiencies are greater
than 97 percent.18 Hood design is very important because of the large number
of emission points (stacking, burning, and assembly usually are performed at
several stations).
4.3.2 Scrubbers
Impingement type scrubbers are sometimes used to control three-process
emissions. These scrubbers typically operate with a pressure drop of
4-3
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approximately 1245 Pa (5 inches W.G.) with lead collection efficiencies
ranging about 90 percent.18 Makeup water requirements for this type of
scrubber are usually less than 0.134 1/m 3 (1 gal./lOOO acf) at a liquid-to-
gas ratio of 2.6 1/m1 (20 gal./lOOO acf) of exhaust.18
4.4 LEAD OXIDE PRODUCTION
Lead oxide in the form of fine particulate matter is manufactured in a
ball mill or a Barton pot. Most lead oxide facilities of both types use
mechanical collectors followed by a baghouse to capture the lead oxide
production after it leaves the ball mill or Barton pot. Most of the product
is separated in a settling chamber or cyclone, and the baghouse serves to
increase the product collection efficiency. The baghouse is considered as
both process equipment and air pollution control equipment. Therefore, for
economic reasons, wet collection devices are not used. Air-to-cloth ratios of
baghouses for collection of lead oxide range from 2/1 to 4/1.!8
During the original NSPS development project, emissions tests were
conducted only at a well controlled ball mill system. At that time, it was
determined that a well controlled Barton system could achieve a similar
emissions level (as the air flow rates per unit production rate are
similar).19 Since then, several Barton systems have indeed demonstrated
compliance with the NSPS, as will be shown in Chapter 5.
4.5 LEAD RECLAMATION
The exhaust gas stream from the lead reclamation process is similar to
the grid casting and small parts casting exhaust gases in that both are
characterized by high temperatures and lead fumes. Since these gas streams
are similar in character it is not uncommon to vent these processes to a
common control device.
4.5.1 Scrubbers
Lead reclamation facilities are generally controlled with low-energy wet
scrubbers. Low-energy multistage or impingement-entrainment type wet
collectors are used most frequently, with pressure drops less than 2 kPa (8
inches W.G.) and liquid-to-gas ratios of 0.4 to 0.7 1/m3 (3 to 5 gal./lOOO
acf).20 Lead collection efficiencies have been shown to be above 98 percent.21
4-4
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4.5.2 Fabric Filters
As was the case for grid casting, there were no known applications of
fabric filters on this facility during the original NSPS development project.
Once again the reason being anticipated bag blinding and fire hazards due to
hydrocarbons and mold release agents contained with the scrap. As was
discussed earlier, the use of spark arresters, better bag fabrics, and better
hygiene practices have reduced the incidence of fires. Therefore, fabric
filters are now being used to control lead reclamation emissions in some cases
(most often, this baghouse is controlling other facilities at the plant as
well).22"24 It is estimated that a collection efficiency in excess of 98
percent is achievable for these facilities using fabric filters with air-to-
cloth ratios between 3/1 and 6/1.2S
4.6 FORMATION
As explained in Chapter 3, formation processes are divided into two
categories, those which form in the battery case and those which form in open
tanks (a practice which is decreasing within the industry). Formation
processes do not emit lead, but are a source of sulfuric acid mist. Battery
plates formed inside the battery case are formed slowly (1 to 4 days), and
those formed in open tanks are formed more rapidly (usually 16 hours). The
type of emissions control for these processes depends on whether or not the
formation area is enclosed.
Very little data on emissions from formation processes are available
from any source. However, based on observations during plant inspections, the
processes which appear to generate much higher emissions are those which form
the plates in open vats.21 This is also evidenced by the fact that most
companies which form the battery plates inside the assembled battery have no
ductwork to remove emissions from the work area. Plants which do duct the
emissions from the work area (those which form in an open vat) have a more
acute emission problem. These plants typically use either foam, scrubbers,
mist eliminators, or combinations of these control techniques to minimize
emissions to the production area and the outside air. Following are emission
control practices used for formation processes.
4-5
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4.6.1. Good Work Practice
When the formation area is not vented to a control device, such as when
the battery is formed after complete assembly, the operator should form the
batteries slowly and keep every battery filler cap on the battery at all times
during the formation period.26 This minimizes emissions to the work area, and
hence to the atmosphere. Some facilities leave the top of the battery case
off during the assembly process and do not install the top until after
formation is complete. During formation, a dummy, reusable cover is placed on
top of the batteries being formed. This helps to reduce emissions since much
of the sulfuric acid mist impinges on the slave cover and condenses back into
the battery.26
4.6.2 Water Sprays
Many plants which form in the battery case (wet formation) spray the
batteries with water during the formation process. The spray may absorb some
sulfuric acid mist but is primarily used to keep the temperature of the
batteries lower than it would normally be since sulfuric acid mist emissions
increase proportionally with acid temperature during formation.26
4.6.3 Foam Covers
Some companies which form the batteries in open tanks (dry formation)
cover the tanks with a Tayer of foam. The foaming agent controls sulfuric
acid mist by collecting the mist particles from the surface of the sulfuric
acid solution before they can escape into the formation room. Three formation
processes using foam were surveyed by EPA during the original NSPS development
project. Subjective measurements of the mist cloud above forming tanks and
the characteristic acid odor in the forming room suggested a decrease in acid
mist emissions when foam is used."
4.6.4 Scrubbers
The scrubbers used to control formation emissions are typically low
energy type scrubbers, such as the Heil™ fume washer (a scrubber and mist
eliminator), and several non-commercial designs. Plants which use scrubbers
either enclose the formation tanks and duct the emissions to the scrubber, or
they form the battery in a room which can be closed off. The emissions in the
room are then ducted to the scrubber.27
4-6
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4.6.5 Mist Eliminators
Some companies use mist eliminators rather than scrubbers to control
formation emissions. A popular brand used by this industry is the Tri-Mer*
scrubber. This mist eliminator catches the mist particles as they go through
a fan separator followed by a packed tower. The packing is then periodically
washed or flushed on a schedule ranging from once per day to two or three
times per shift.28
4.7 CENTRAL VACUUM SYSTEMS
Many lead-acid battery manufacturing plants use central vacuum systems
for general housekeeping practices. These units have, in several cases, been
determined as subject to the NSPS as an "other lead emitting" source.29"32
Based on plants surveyed by EPA, the industry typically uses fabric filters to
control exhaust emissions from these vacuum systems. The fabric filters
encountered were generally pulse-jet or reverse air units, with air-to-cloth
ratios of approximately 4/1 to 7/1.29~31
4.8 NEW CONTROL TECHNIQUES
Since the original NSPS development project, fabric filters have become
an accepted method for controlling emissions from grid casting and lead
reclamation. Also, there have been two new lead control techniques applied to
various facilities in the lead-acid battery manufacturing process. These are
the use of cartridge dust collectors as primary control devices, and the use
of HEPA filters for secondary collection.
4.8.1 Cartridge Collectors
Cartridge collectors are similar to baghouses, but they have rigid,
pleated cellulose cartridges rather than bags, allowing more filter surface
area per total volume of the collector. These pulse-jet units have an air-to-
filter surface ratio of approximately 1.5/1, and operate at a pressure drop
between 1 and 2 inches W.G.33 Due to very fine pore size, cartridge
filtration media will remove particles as small as one micron." Another
advantage of these units is ease and safety of maintenance; the cartridges can
be changed quickly without entering, or even leaning into, the collector.
There is still some question over the successful application of these systems
to moist exhausts. However, there have been reported cases of a cartridge
collector controlling the entire paste mixing cycle, including the wet
4-7
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portion.31'" Also, at least one firm manufactures a filter cartridge that is
reported to be applicable for filtering particulate in moist streams.36
4.8.2 High Efficiency Particulate Air Filters
High efficiency particulate air filters (HEPA filters) are used
primarily as a secondary control device following a fabric filter or cartridge
collector.37"3' Use of a HEPA filter makes it possible to recirculate the
exhaust to the plant; recirculation helps reduce make-up air costs, as well as
heating costs during colder weather. OSHA requires HEPA filters for
recirculation systems, and this requirement is currently the primary reason
for use of such units.40
The HEPA filter is constructed of an extended-pleated dry filter medium,
enclosed in a rigid casing the full depth of the pleats/1 The collection
efficiency is a minimum of 99.97 percent for 0.3 urn particles, and a clean
unit has a maximum pressure drop of 0.25 kPa (1.0 in. W.G.).39'41 Large
airflows are controlled by banks of several filters. The filters are
generally replaced when the pressure drop reaches 0.5 kPa (2.0 in. W.G.).41
Used filters must be disposed of as a hazardous waste material.42
4-8
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4.9 REFERENCES
1. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPA:ESD. August 5, 1988. Response to Section 114 Information
Request for Fort Smith, Arkansas, plant.
2. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPA:ESD. July 27, 1988. Response to Section 114 Information
Request for Zanesville, Ohio, plant.
3. Letter and attachments from Frank S., Gates Energy Products,
Incorporated, to Michelitsch, D.M., EPA:ISB. August 17, 1988. Response
to Section 114 Information Request.
4. Materials from Baranski, J.P., Exide Corporation, to Michelitsch, D.M.,
EPA:ISB. July 26, 1988. Response to Section 114 Information Request.
5. Letter and attachments from McMullen, S.R., Delco-Remy, Division of GM,
to Fanner, J.R., EPA:ESD. July 14, 1988. Response to Section 114
Information Request for Olathe, Kansas, plant.
6. Letter and attachments from Sprague, F.L., Delco-Remy, Division of GM,
to Farmer, J.R., EPA:ESD. July 14, 1988. Response to Section 114
Information Request for Fitzgerald, Georgia, plant.
7. U.S. Environmental Protection Agency. Lead-Acid Battery Manufacture--
Background Information for Proposed Standards. EPA-450/3-79-028a.
November 1979. p. 4-2.
8. Memo from Michelitsch, D.M., EPA;ISB, to Durkee, K.R., EPA:ISB.
December 6, 1988. Report on July 19, 1988, trip to Johnson Controls,
Incorporated, Winston-Salem, North Carolina.
9. Letter and attachments from Meverden, J.R., Johnson Controls
Incorporated, to Farmer, J.R., EPA:ESD. August 9, 1988. Response to
Section 114 Information Request.
10. Reference 7, p. 4-10.
11. Reference 7, p. 4-13.
12. Reference 1.
13. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPArESD. August 18, 1988. Response to Section 114 Information
Request for Columbus, Georgia, plant.
14. Reference 3.
4-9
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15. Letter and attachments from Hanslick, J., Battery Builders,
Incorporated, to Farmer, J.R., EPArESD. August 16, 1988. Response to
Section 114 Information Request.
16. Reference 7, p. 4-14.
17. Reference 7, p. 4-17.
18. Reference 1, p. 4-24.
19. U.S. Environmental Protection Agency. Standards of Performance for New
Stationary Sources; Lead Acid Battery Manufacture - Proposed Rule and
Notice of Public Hearing. 45 FR 2790. Washington, D.C. Office of
Federal Register. January 14, 1980.
20. Reference 7, p. 4-27.
21. Reference 7, p. 4-29.
22. Letter and attachments from Reich, P.J., C&D Charter Power Systems,
Incorporated, to Farmer, J.R., EPArESD. June 21, 1988. Response to
Section 114 Information Request.
23. Reference 4.
24. Reference 8.
25. Reference 7, p. 4-32.
26. Reference 7, p. 4-33.
27. Reference 7, p. 4-34.
28. Reference 7, p. 4-35.
29. Reference 9.
30. Reference 15.
31. Reference 18.
32. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
December 6, 1988. Report on July 27, 1988, trip to East Penn
Manufacturing Company, Lyon Station, Pennsylvania.
33. Douglas Battery Manufacturing Company Achieves Outstanding Air Quality
Energy Savings. The Battery Man. 30:20-22, 27.
34. Reference 2.
4-10
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35. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
November 7, 1988. Report on July 13, 1988, trip to Trojan Battery
Company, Lithonia, Georgia.
36. Letter and attachments from Hrycak., W.L. Gore & Associates,
Incorporated, to Dimmick, F., EPA:ESD. October 10, 1988. Information
on GORE-TEX™ membrane filters.
37. Reference 32.
38. Reference 33.
39. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB. October
18, 1988. Report on July 20, 1988, trip to Douglas Battery
Manufacturing Company, Winston-Salem, North Carolina.
40. Facsimile from Rife, K.L., Douglas Battery Manufacturing Company, to
Michelitsch, D.M., EPA:ISB. March 9, 1989. Requirements for air
recirculation.
41. U.S. Environmental Protection Agency. Characterization and Control of
Radionuclide Emissions from Elemental Phosphorous Production.
EPA-450/3-89-020. February 1989.
42. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
November 2, 1988. Report on June 22, 1988, meeting with Battery Council
International.
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5.0 COMPLIANCE STATUS
5.1 AFFECTED FACILITIES
Thirty-one plants have been identified as having facilities subject to
the new source performance standards (NSPS) for lead-acid battery manufacture.
Table 5-1 lists these plants. Emissions data were received from 30 of the 31
plants reported as subject to the NSPS. Information concerning these plants
was obtained from EPA's Stationary Source Compliance Division (SSCD), Regional
and State agencies, and responses to several Section 114 Information Requests.
5.2 EMISSIONS DATA
Emissions testing is required to demonstrate compliance with the NSPS
emission limits, which are summarized as follows:
Facil itv Lead Emission 1 imit Opacity
Lead oxide production 5.0 mg/kg (0.010 lb/ton)* 0%
Grid casting 0.40 mg/dscm (0.000176 gr/dscf) 0%
Paste mixing 1.00 mg/dscm (0.00044 gr/dscf) 0%
Three-process operation 1.00 mg/dscm (0.00044 gr/dscf) 0%
Lead reclamation 4.50 mg/dscm (0.00198 gr/dscf) 5%
Other lead emitting
operations 1.00 mg/dscm (0.00044 gr/dscf) 0%
* The emission limit for lead oxide production is expressed in
terms of lead emissions per kilogram of lead processed.
The lead mass emissions are determined using EPA Reference Method 12, and
opacity is determined using EPA Reference Method 9. The compliance emissions
data collected during this review are presented and discussed in the following
sections.
5-1
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TABLE 5-1
EAD-ACID BATTERY PLANTS WITH SUBJECT FACILITIES*
Battery Builders, Incorporated
- Naperville, IL
C&D Power Systems, Incorporated
- Conyers, GA
- Hugeunot, NY
Leola, PA
Conshohocken, PA (recently closed)
Douglas Battery Manufacturing Company
Winston-Salem, NC
East Penn Manufacturing Company
Lyon Station, PA
Exide Corporation
- City of Industry, CA
- Visalia, CA
- Logansport, IN
- Burlington, IA
- Manchester, IA
Salina, KS
- Allentown, PA
- Muhlenberg/Laureldale, PA
Greer, SC
Sumter, SC
Gates Energy Products, Incorporated
Warrensburg, MO
GNB Incorporated
- Fort Smith, AR
- Columbus, GA
Zanesville, OH (recently closed)
Johnson Controls, Incorporated
- Middletown, DE
- Tampa, FL
St. Joseph, MO
- Winston-Salem, NC
- Holland, OH
- Milwaukee, WI
Trojan Battery Company
Santa Fe Springs, CA
- Lithonia, GA
5-2
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TABLE 5-1, CON'T.
LEAD-ACID BATTERY PLANTS WITH SUBJECT FACILITIES*
U.S. Battery Manufacturing Company
Evans, GA
West Kentucky Battery, Incorporated
- Benton, KY
*Note: References listed in Section 5.3
5-3
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5.2.1 Grid Casting
Emissions data for grid casting facilities were received from 14 plants.
This information is shown in Figure 5-1.
Data from Plant B includes the casting fume exhaust system vent and the
general casting area vent. Both of these exhaust streams are uncontrolled.
Opacity data were not included with the test reports.
Plant C includes emissions data from the grid casting area vent and a
cast-on-strap facility, which has, in this case, been interpreted as a casting
facility rather than the usual definition as part of the three-process
operation (the emissions would also be below the limit for three-process
facilities). Emissions from the casting area are controlled by a baghouse,
and a cartridge collector is used to control the emissions from the cast-on-
strap facility. Opacity data were not included with the test reports.
The five casting facilities tested at Plant E are all uncontrolled, with
0 percent opacity. These tests include the combined exhaust of four carousel
casters, a general casting area vent, an annealing oven, a fifth carousel
caster, and a small parts die caster. All of these units had emissions below
the allowable 1imit.
The data for Plant I are for the exhaust from the entire casting
operation. These average uncontrolled emissions are above the standard;
however, the allowable limit stated in the test report is incorrect, making
the facility appear below the NSPS limit. The local enforcement agency is
currently taking actions to correct this permitting error. The opacity for
this facility was measured at 0 percent.
The two tests presented for Plant K are both for the same uncontrolled
general casting area vent. The first test shows the emissions are above the
level of the standard. The second, later test shows the emissions are now
below allowable limits. There were no opacity data included with these
reports.
The data for Plant N are for the combined exhaust from the grid casting
and small parts casting operations. This exhaust stream is controlled by a
baghouse, and the opacity was measured at 0 percent.
5-4
-------
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11 EPA
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Plant
Later
Mod.
Earlier
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Figure 5-1. Emissions Data for Grid
Casting Facilities
NOTE: References shown in Section 5.3.
-------
The first nine tests presented for Plant S are for the following
facilities:
Casting Machine #1 - Uncontrolled
Casting Machine #2 - Uncontrolled
Casting Machine #3 - Uncontrolled
0 Casting Machine #4 - HEPA Filter
Casting Machine #5 Uncontrolled
Antimony/lead Melt Pot - Uncontrolled
0 Calcium/lead Melt Pot - Uncontrolled
Industrial Casting - Uncontrolled
0 Casting Machine #6 - HEPA Filter
Although several of these units have emissions above the allowable NSPS, the
local enforcement agency for this plant interpreted the regulation such that
compliance with the grid casting standard is determined by taking a weighted
average of the emissions from all grid casting related operations at the
plant. This average (denoted on Figure 5-1 by "Ave.") is below the allowable
limit. Test information was also received for further modifications to some
of the facilities noted above (these tests are marked "later Mod." on Figure
5-1). HEPA filters were added to both lead melt pots (bringing the antimony/
lead pot within the allowable limits), and the controls were removed from
Casting Machine #6, causing its emissions to rise slightly above the NSPS
limit. Opacity data were included with five of these test reports, and all
were 0 percent.
The data from Plant T and Plant V are both for general grid casting area
vents. These facilities are each controlled by a baghouse. No opacity data
were included with the emissions information.
The two facilities at Plant W are both uncontrolled lead melt furnaces;
one for antimony/lead and one for calcium/lead. Opacity data were not
included.
The first five tests presented for Plant Aa are all for grid casting
machines. The first four tests are for single units (#l-#4) with uncontrolled
exhaust streams, and the fifth test is for two units (#5, #6) with the exhaust
stream combined and controlled by a wet scrubber. All of these tests included
opacity readings of 0 percent. Although several of these units have emissions
5-6
-------
above the NSPS allowable, the local enforcement agency for this plant
interpreted the regulation such that compliance with the grid casting standard
is determined by taking a weighted average of the emissions from all the grid
casting machines. This average (denoted on Figure 5-1 by "Ave.") is below the
allowable limit. Test information was also received for several earlier tests
on machine #5 individually and one for the combined (#5, #6) exhaust stream.
(These tests are marked "Earlier Tests" on Figure 5-1). The first three of
these earlier reports for machine #5 show emissions above the NSPS limit, with
the single unit at that time being uncontrolled; the forth test reflects the
addition of a wet scrubber resulting in emissions below allowable. The last
of the earlier tests is for the addition of the exhaust from machine #6 to the
wet scrubber controlling machine #5, and it exceeds the standard. The later
emissions test for this unit combined (which was used to compute the weighted
average) shows that subsequent modifications were made to bring the units
emissions below the allowable limit.
The data presented for Plant Cc are for the following facilities:
0 Casting Machine #1 - Uncontrolled
° Casting Machine #2 - Uncontrolled
0 Casting Machine #4 - Uncontrolled
0 Casting Machine #3 Uncontrolled
0 Casting Machine #6 - Uncontrolled
0 Casting Machines #5 & 7 - Wet scrubber
0 Post Pouring Station - Uncontrolled
0 Casting Machine #7 Uncontrolled
0 Casting Machine #8 - Uncontrolled
0 Casting Machine #10 - Uncontrolled
The emissions are all below the NSPS allowable limits. Post pouring is
normally not included in the grid casting facility; this unit was later re-
permitted as an "other lead emitting" facility. Opacity readings were
included for casting machines #7, #8, and #10, and were all at 0 percent.
The data for Plant Dd is from one uncontrolled grid casting machine
(actually 3 single units, together called a "bank"). The emissions shown are
above the NSPS, but the unit has recently been retested, and is now reported
to be in compliance. No opacity readings were included with the test report.
5-7
-------
The data received for Plant Ee is also for one uncontrolled grid casting
unit. In this case, the emissions are below allowable limits. Once again, no
opacity data were included.
Of the 51 emission tests received for grid casting facilities, 37 of
these were in compliance with the NSPS. These units included: 25 that were
uncontrolled, 4 controlled by baghouses, 3 by wet scrubbers, 2 by primary HEPA
filters, 2 with prefilters and HEPA filters, and 1 by a cartridge collector.
Of the 14 tests not in compliance, 13 units were uncontrolled, and 1 was
controlled by a wet scrubber. Eleven of the facilities with emissions above
the allowable were included in weighted average determinations of compliance.
Of the remaining three, two have been brought into compliance, and one is
being pursued by the local enforcement agency.
5.2.2 Paste Mixing
Emissions data for paste mixing facilities were received from 14 plants.
This information is shown in Figure 5-2.
The facilities tested at Plant A include the following:
° Negative Oxide Unloading
0 Positive Oxide Unloading
0 Positive Paste Mixing
0 Negative Paste Mixing
° Drying Oven-West
0 Drying Oven-East
All of these facilities are controlled by baghouses, except for the drying
ovens, which are uncontrolled. The mass emissions are all below the NSPS
limits, and the opacities are 0 percent.
The three tests presented for Plant B are all for the same paste mixing/
paste application exhaust stream, controlled by a wet scrubber. The second
test was a result of a modification to the unit, and was above the NSPS limit.
The third test reflects changes made (apparently in air flow rates) to bring
the emissions below the allowable value. Opacity readings were included with
the first test only, and were all 0 percent.
5-8
-------
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Figure 5-2. Emissions Data for
Paste Mixing Facilities
NOTE: References shown in Section 5.3.
KEY
U - Uncontrolled
B - Baghouse
S - Wet Scrubber
H - Primary IIEPA
B/H - Baghouse w/IIKPA
-------
The six units tested at Plant E are as follows:
0 Manual Pasting (5 stations) Baghouses (2 units)
0 Negative Paste Mixing Wet Scrubbers
8 Positive Paste Application (2 units) - Baghouse
0 Positive Oxide Silo - Baghouse
° Negative Oxide Silo - Baghouse
0 Modification to Positive Oxide Silo - Baghouse
Opacity readings of 0 percent were included with each test report. The mass
emissions for all the units are below the allowable limits.
The data presented for Plant H are for a combined exhaust stream from
two paste mixers and two paste application lines. The emissions are
controlled by a wet scrubber. No opacity readings were included with the test
report.
Plant I also has the emissions from paste mixing and paste application
combined and controlled by a wet scrubber. Opacity data of 0 percent were
included for all test runs.
Both tests presented for Plant J are for the same paste mixer,
controlled by a wet scrubber. The second test reflects the installation of a
new scrubber to bring the emissions below the NSPS allowable limits. Opacity
readings of 0 percent were included with the second test.
The data from Plant M are for the combined emissions for the entire
pasting area. This exhaust stream is controlled by a wet scrubber. No
opacity data were included.
The tests presented for Plant S are for the following facilities:
° Automotive Plate Curing Ovens - Uncontrolled
0 Industrial Plate Curing Ovens - Uncontrolled
° Paste Mixing & Paste Application - Baghouse w/HEPA
0 Oxide Silos A&B Baghouse
0 Oxide Silo #2 - Baghouse
Although the automotive plate curing ovens have emissions above the NSPS
allowable, the local enforcement agency for this plant interpreted the
regulation such that compliance with the paste mixing standard is determined
by taking a weighted average of the emissions from all operations at the plant
that are included in the definition of paste mixing. This average (denoted on
5-10
-------
Figure 5-2 by "Ave.") is below the allowable limit. No opacity measurements
were included with the test reports.
The data from Plant X are for an uncontrolled paste drying oven, and for
a Cortex1" baghouse controlling paste mixing/application. The baghouse data
also included opacity measurements of 0 percent.
The one test from Plant Y is for a paste mixer. The unit is controlled
by a baghouse. No opacity information was included in the test report.
The data presented for Plant Aa include the following facilities:
0 North Oxide Storage Tank - Baghouse
0 South Oxide Storage Tank - Baghouse
0 Paste Mixers #1, #2, and #3 (wet cycle) - Wet Scrubber
0 Paste Mixers #1, and #2 (dry cycle) - Baghouse
0 Paste Mixer #3 (Dry Cycle) - Baghouse
° Curing Oven #1 - Uncontrolled
0 Curing Oven #2 - Uncontrolled
0 Curing Oven #3 - Uncontrolled
Several of these units have emissions above the allowable NSPS, including two
controlled by baghouses; however, the local enforcement agency for this plant
interpreted the regulation such that compliance with the paste mixing standard
is determined by taking a weighted average of the emissions from all units
defined as part of the paste mixing operation. This average (denoted on
Figure 5-2 by "Ave.") is also above the NSPS limit. The plant is therefore
currently operating under a consent order with their local enforcement agency.
Test information was also received for two earlier tests; one on the wet
scrubber controlling paste mixers #1, #2, and #3, and one on the baghouse
controlling paste mixer #3 (these tests are marked "Earlier Tests" on Figure
5-2). These earlier tests had higher emissions than those later used to
compute the weighted average discussed above. Opacity readings of 0 percent
were included with all the test reports.
The two tests presented for Plant Bb are for the same paste mixer; one
test is for a wet scrubber controlling the wet cycle of mixing, and the other
is for a baghouse controlling the dry cycle. Both tests are below allowable
limits. No opacity data were included with the test report.
5-11
-------
The data presented for Plant Cc are for the following facilities:
° Paste Mixers #1, #2, #3, #4 (Dry Cycle) - Baghouse
0 Drying Oven #3 Uncontrolled
0 Modification to Paste Mixers #1, #2, #3, #4
(Dry Cycle) - Baghouse
0 Paste Mixers # 3, U (Wet Cycle) - Wet Scrubber
0 Paste Mixers #1, #2 (Wet Cycle) - Wet Scrubber
° Drying Oven #1 - Uncontrolled
° Drying Oven #2 - Uncontrolled
0 Pasting Lines (#1, #2, #3) - Primary HEPA
0 Modification to Paste Mixers #3, #4
(Wet Cycle) - Wet Scrubber
0 Oxide Storage Tank C - Baghouse
0 Modification to Paste Mixers #1, #2,
#3, #4 (Dry Cycle) - Baghouse
° Chem-Set Room (Plate Curing) - Uncontrolled
Opacity readings for the last four tests were all 0 percent. The test
information for the three uncontrolled drying ovens is above the level of the
standards. However, the local enforcement agency has interpreted the
regulation such that the affected facility includes all equipment associated
with paste mixing and application. Information on which actual test runs were
used to compute a weighted average was not included; therefore, an actual
average value is not presented.
The data presented for Plant Dd are for the following facilities:
0 Paste Mixer #3 (Wet Cycle) - Wet Scrubber
0 Paste Mixers #1, #2, #3 (Dry Cycle) - Baghouse
0 Pasting Line #3 - Primary HEPA
0 Paste Mixers #3, #4 (Wet Cycle)
(addition of #4) - Wet Scrubber
0 Pasting Line #4 - Primary HEPA
0 Paste Mixer #4 (Dry Cycle) - Baghouse
Opacity readings were not included with any of the test reports. The test
presented for paste mixer #4 (dry cycle) shows emissions in excess of
5-12
-------
allowable. This unit was recently retested, and is now reported to be in
compliance.
Of the 58 emission tests received for paste mixing facilities, 45 were
in compliance with the NSPS. The control devices on these units included: 21
baghouses, 15 wet scrubbers, 3 primary HEPA filters, 1 baghouse and HEPA
filter, and 5 uncontrolled units. There were 13 tests received with emissions
above the allowable limit. Seven of these units had uncontrolled emissions,
four used baghouses, and two used scrubbers. Ten of the units with emissions
not in compliance with the NSPS are used in the computation of a weighted
average to determine compliance. The other three remaining units have been
brought into compliance.
5.2.3 Three-Process Operation
Emissions data for three-process operation facilities were received from
12 plants. This information is shown in Figure 5-3.
The data presented for Plant B includes the following:
0 A & B Series Assembly Area Baghouse
0 C Series Assembly Area Baghouse
0 Modification to C Series Assembly Area - Baghouse
0 D Series Assembly Area - Baghouse
0 Modification to A and B Assembly Baghouse
0 E Series Assembly Area Baghouse
0 Three Wrapper/Stacker Units Baghouse
Opacity readings of 0 percent were included with three of the test reports.
The mass emissions for the wrapper/stacker units are above the allowable NSPS.
However, the local enforcement agency has interpreted the regulation such that
compliance is determined by a weighted average of emissions from all equipment
associated with the three-process operation.
The three tests from Plant D are for the assembly processes for three
different types of batteries. All of the units are controlled by fabric
filters and are in compliance with the NSPS. No opacity data were included
with the test reports.
5-13
-------
O
hf
Ol O
1 -H
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1 .0 x 10 5
1 .0 x 10~4
1 .0 x 10~5
»
1.0 x 10~6
,
3.0 x 10~7
i
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-------
The data presented for Plant E includes the following:
° Laser Bonders (Plate burning) - Uncontrolled
0 Stacking Area - Baghouse
0 Post Brush - Baghouse
0 Modified Laser Bonders (addition
of a control device) - Baghouse
0 Bond Repair - Baghouse
0 Lasers and Stacking (now combined
exhaust) - Baghouse
Opacity readings of 0 percent were included with all of the test reports. The
laser bonders initially showed emissions in excess of the allowable NSPS;
however, the later tests show this to be corrected via addition of a control
device.
The one test from Plant H is for an automotive battery assembly system.
Emissions are controlled by a cartridge collector with a secondary HEPA filter
and are below the allowable NSPS. No opacity information was included with
the test reports.
The test from Plant I is for the combined exhaust from two baghouses
controlling various battery assembly processes (stack and burn, elements into
cases, etc.). The mass emissions are within allowable limits, and the opacity
was measured at 0 percent.
Plant J presents emissions data from one baghouse controlling plate
wrapping, stacking, and cast-on-strap-operations, which shows the unit to be
in compliance. The opacity was measured at 0 percent.
The three tests presented for Plant P are all for stack and burn
operations. Each facility is controlled by a baghouse, with mass emissions
below the allowable NSPS. No opacity data were included with the test
reports.
The first seven tests presented for Plant S are for the following
facilities:
0 Automatic Repair Station - HEPA Filter
° Conventional Assembly #1 Uncontrolled
0 Automatic Assembly #1 - Baghouse w/HEPA
5-15
-------
0 Automatic Assembly #2, #3 - Baghouse w/HEPA
(Later changed to cartridge house w/HEPA, but no new
test received)
0 Conventional Assembly #2 - Uncontrolled
0 Industrial Assembly - Goretex™ Baghouse w/HEPA
0 Conventional Stack & Burn - Cartridge Collector
All of these units have emissions below the NSPS allowable. The local
enforcement agency for this plant interpreted the regulation such that
compliance with the three-process standard is determined by taking a weighted
average of the emissions from all three-process related operations at the
plant. This average is denoted on Figure 5-3 by "Ave". Test information was
also received for further modifications to some of the three-process
facilities at Plant S (these tests are marked "Later Mod." on Figure 5-3).
The first later test is for a new stacker/cast-on-strap operation (controlled
by a baghouse), and the second test is for a modification to this unit. The
final test is for a modification to the industrial assembly area. All of
these later tests are also in compliance with NSPS limits. Only two tests
from Plant S included opacity data, both of which were 0 percent.
The first three tests presented for Plant Aa are as follows:
0 Cast-on strap/Assembly #1, #2 - Baghouse
0 Cast-on-strap/Assembly #3 Baghouse
° Cast-on-strap/Assembly #4 Baghouse
Opacity readings of 0 percent were included with all of the reports, and the
mass emissions are all below the NSPS allowable. The local enforcement agency
for this plant interpreted the regulation such that compliance with the three-
process standard is determined by taking a weighted average of the emissions
from all of the three-process related units at the plant. This average is
denoted on Figure 5-3 by "Ave." One earlier test was also received for the
baghouse controlling two cast-on-strap/assembly lines (#1 and #2), and it was
above the allowable limit. The later test (used to compute the weighted
average) shows that this situation was corrected.
The data received for Plant Bb is from two cast-on-strap/assembly lines,
both controlled by primary HEPA filters. The first unit has emissions
slightly above the allowable NSPS; however, information on actions to lower
5-16
-------
these emissions has been forwarded to the local enforcement agency. No
opacity data were included with the reports.
The two test reports for Plant Cc are for the same stack, which serves
several three-process stations controlled by several primary HEPA filters, and
both show compliance with the NSPS. The second test reflects modifications to
the facility. Opacity readings of 0 percent were included with the second
report.
The data from Plant Dd are for two cast-on-strap/assembly lines. Both
units are controlled by primary HEPA filters, with emissions below the
allowable limit. Opacity data were not included with the test reports.
Of the 41 emission tests received for three-process facilities, 37 were
in compliance with the NSPS. These units are controlled by: 24 baghouses, 5
primary HEPA filters, 4 baghouses with HEPA filters, 1 cartridge collector, 1
cartridge collector with HEPA filter, and 2 units are uncontrolled. Of the
four tests not meeting the NSPS limits, two are for units controlled by
baghouses, one by a primary HEPA filter, and one is uncontrolled. Two tests
with emissions above allowable have been used in computing a weighted average
to determine compliance, and one unit has been brought into compliance.
Information concerning action to bring the remaining unit into compliance has
been forwarded to the local enforcement agency.
5.2.4 Lead oxide production
Emissions data for lead oxide production facilities were received from
seven plants. This information is shown in Figure 5-4. All of the data
received are from systems using the Barton Process rather than a ball mill.
The two stacks tested for Plant C are from the same oxide mill; one
serves the regular process baghouse, and the other is for an emergency back-up
baghouse. Both are in compliance with the NSPS. Opacity readings were not
included with the test report.
A baghouse with Goretex™ bags controls the oxide mill at Plant H. No
opacity information was received. The mass emissions are within NSPS limits.
Plant K presented data for two oxide mills. Both units are controlled
by baghouses with Goretex™ bags, and are in compliance. Opacity readings
were not included with the test reports.
5-17
-------
LEAD-CXIDE PRODUCTION FACILITIES
(Barton Process)
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NOTE: References
shown in
Section 5.3.
C H K 0
S S V Z
Ave.
Plants
Figure 5-4-. Emissions Data for Lead-Oxide Production Facilities
5-13
-------
The data from Plant 0 are for three separate oxide mills, each
controlled by a baghouse with Goretex™ bags. Opacity data were not included
with the test report. The test for the first mill shows emissions slightly
above the NSPS limit. However, the local enforcement agency has interpreted
the regulation such that compliance is determined using a weighted average of
the emissions from all lead oxide production equipment.
The first test presented for Plant S is for a combined exhaust stream
from two baghouses, each serving a single oxide mill. The second test is for
a Goretex™ baghouse controlling a third oxide mill. All three mills have
emissions well below the NSPS limit. No opacity data were included with the
test reports. The local enforcement agency for this plant interpreted the
regulation such that compliance with the lead oxide production standard is
determined by taking a weighted average of the emissions from all lead oxide
production facilities at the plant. This average is denoted on Figure 5-4 by
"Ave."
The data from Plant V are for one oxide mill, controlled by a baghouse,
and is in compliance with the NSPS. Opacity data were not included with the
test information.
The two tests from Plant Z are for two oxide mills, each controlled by a
baghouse. Opacity readings of 0 percent were included. The test for the
second mill shows emissions slightly above the allowable limit; however, the
unit was recently re-tested, and is now reported to be in compliance.
All 13 tests received for oxide production facilities were for units
controlled by baghouses. Two of these tests showed emissions above the
allowable NSPS. One of the tests not in compliance was used to compute a
weighted average of emissions, and the other unit has been brought into
compliance.
5.2.5 Lead Reclamation
No compliance data were received for lead reclamation facilities
individually. There were, however, several cases where lead reclamation
facility emissions were combined with those from another type of unit, and
controlled by one device. This information is presented in Section 5.2.7.
5-19
-------
5.2.6 Other Lead Emitting Operations
Emissions data for those facilities categorized as "other lead emitting
operations" were received from four plants. This information is shown in
Figure 5-5.
The facilities presented for Plant B are as follows:
0 Central Vacuum System - Cyclone/Baghouse
0 Plate Processing A Baghouse
0 Modification to Plate Processing A - Baghouse
° Plate Processing B - Wet Scrubber
All of the units had mass emissions below allowable limits. Opacity readings
were included for two of the tests on plate processing, and were all at 0
percent.
The data presented for Plant W are for a plate unracking and brushing
station. This unit is controlled by a baghouse, and is in compliance with the
NSPS. No opacity information was included with the test report.
The facilities presented for Plant Aa are as follows:
0 Central Vacuum System - Baghouse
0 Plate & Paste Salvadge - Wet Scrubber
0 Modification to Plate & Paste Salvage - Wet Scrubber
Opacity readings for the first and third tests were 0 percent. The central
vacuum system is shown to have emissions slightly above the allowable limit;
however, the unit has been re-tested, and is now reported to be in compliance.
The tests from Plant Cc are for two post pouring stations. Both of
these units are uncontrolled, with emissions below the allowable NSPS.
Opacity readings for all three facilities were 0 percent.
Of the 10 emission tests received for "other lead emitting" facilities,
9 were in compliance with the NSPS. These units were controlled by four
baghouses, three wet scrubbers, and two units were uncontrolled. The one
facility not meeting the NSPS was controlled by a baghouse; this unit has now
been brought into compliance.
5-20
-------
OTHER LEAD EMITTING
FACILITIES
o
CO
13
laC
03
c
o
•H
co
CO
ziz ^::::::_ 1.
KEY
B - Eaghouse
U - Uncontrolled
S - Wet Scrubber
C/B - Cyclone
w/Baghouse
NOTE: References
shown in
Section 5.3
Figure 5-5.
Emissions Data for
Other Lead Emitting
Facilities
5-21
-------
5.2.7 Combined Facilities
In some cases, emissions from several different type facilities (often
with different allowable emissions) are controlled by a common device. In
this case, the allowable emission limit can be calculated by taking the
weighted average of the standards for each unit. Emissions data for combined
facilities were received from five plants, all of which were in compliance.
This information is shown in Figure 5-6.
The first test presented for Plant G is from a baghouse controlling the
combined emissions of the complete paste mixing (as well as application) and
assembly (three-process) operations. The standard for both of these
facilities is 4.4 x 10'4 gr/dscf. The second test is for the combined,
uncontrolled emissions from the grid casting and lead reclamation operations.
The weighted average allowable limit was stated in the test report to be
1.66 x 10"3 gr/dscf. No opacity data were included with the test reports.
The facility presented from Plant M is a baghouse controlling the
combined exhaust from several lead melt pots (grid casting) and a lead
reclamation operation. An allowable limit of 6.3 x 10" gr/dscf was presented
in the test report. No opacity data were received.
The facility presented for Plant Y is a baghouse controlling the
combined exhaust from the paste application and grid casting operations. An
allowable limit of 4.3 xlO'* gr/dscf was presented in the test report. No
opacity data were included.
The data from Plant Bb is for the combined emissions from six grid
casting units and a lead reclamation operation, all being controlled by a wet
scrubber. The weighted average allowable limit was calculated to be 5.18 x
10'" gr/dscf. Opacity information was not included.
At Plant Gg, all emissions from the plant are ultimately controlled by
one central baghouse (some units have primary control devices prior to final
control by this baghouse). The major emission points include:
0 Oxide Silo Vent Filter
° Plate Breaking and Buffing Baghouse
0 Paste Mixing
0 Pasting and Three Process Control Devices (several)
0 Grid Casting
5-22
-------
y
en
•a
art
en
O
en
en
F
a
1.0 x 10~3
,
1.0 x 10~4
1.0 x 10~5
2.0 x 10
i
i
COMBINED
FACILITIES
'. Allow ; :
L66xlO~3 ! ;
•- j
t ----- ' :
i j All^w '
- .: : -11 ; KEY
- \llor ! ; Allow !5 13-in"4 ' U ~ Uncontrolled
^; f, i B - Baghouse
4.4xlU ; A.JxiU : : S - Wet Scrubber
i . m \
. n "i t - = - _L_ ' ! '
n : p : -, - . : !
_L_ , -„ , — :
• ' • ' • i
1 — . — . . .
* : B! :
:- |l ! ! •
i . 1 ,
U t
B
; ' • No
t • ;
: Calculated,-
=• ; : . J i :
--:. ! j -- Data Below Ahy
--- . ; :- Aliqwabie Level NUTE: References
: : - ... . ; i j shown in
1 ' ii| Section 5 3
._.._._ ---.-_ - j- _j_ -- ...
~ . : . " : ; - -
r - • -.-!•!.!*.-••
i T.. . • i - - • . | • : :
--•-'. " : - i : ' — £
- ' . - • • " : - : : 1 ~ : -
: - ! ' • ; -= -
'-'•'- • -' ' .' \ :=:_-
'• \ ' .._"__-_ „ . ~~- '.
.- - - i :i: -.* ! : •—; ! ':
"f :; i :::"TT"f ":" 1 [ i j i 1 i ' ^ i:T :T"j"::-
G M Y Bb Gg
Plant
Figure 5-6. Emissions Data for
Combined Facilities
5-23
-------
It was not possible to calculate a weighted average emission limit with the
available information; however, the emissions were well below any of the
applicable limits. The opacity was stated to be 0 percent, although no actual
data sheets were included.
5-24
-------
5.3 REFERENCES
1. Letter and attachments from Hanslik, J., Battery Builders, Incorporated,
to Farmer, J.R., EPA:ESD. August 16, 1988. Response to Section 114
Information Request.
2. Letter and attachments from Reich, P.J., C&D Charter Power Systems,
Incorporated, to Farmer, J.R., EPA:ESD. June 21, 1988. Response to
Section 114 Information Request.
3. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R.,EPA:ISB.
January 9, 1989. Report on July 12, 1988, trip to C&D Charter Power
Systems, Incorporated, Conyers, Georgia.
4. Letter and attachments from Eng, K., EPA:Region II, to Michelitsch,
D.M., EPA:ISB. April 4, 1988. Response to request for information on
battery manufacturing plants subject to the NSPS.
5. Letter and attachments from Turlinski, B.E., EPA:Region III, to
Michelitsch, D.M., EPA:ISB. April 7, 1988. Response to request for
information on battery manufacturing plants subject to the NSPS.
6. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
October 18, 1988. Report on July 20, 1988, trip to Douglas Battery
Manufacturing Company, Winston-Salem, North Carolina.
7. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
December 6, 1988. Report on July 27, 1988, trip to East Penn
Manufacturing Company, Lyon Station, Pennsylvania.
8. Materials from Baranski, J.P., Exide Corporation, to Michelitsch, D.M.,
EPA:ISB. July 26, 1988. Response to Section 114 Information Request.
9. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
November 1, 1988. Report on July 26, 1988, trip to Exide Corporation,
Reading, Pennsylvania.
10. Materials from Baranski, J.P., Exide Corporation, to Michelitsch, D.M.,
EPA.-ISB. December 9, 1988. Additional stack test information.
11. Memo from Whitmore, C., EPA:Region VII, to Michelitsch, D.M., EPA:ISB.
March 31, 1988. Response to request for information on battery
manufacturing plants subject to the NSPS.
12. Letter and attachments from Frank, S., Gates Energy Products,
Incorporated, to Michelitsch, D.M., EPA:ISB. August 17, 1988. Response
to Section 114 Information Request.
13. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPA:ESD. August 5, 1988. Response to Section 114 Information
5-25
-------
Request for Ft. Smith, Arkansas, plant.
14. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPA:ESD. August 18, 1988. Response to Section 114 Information
Request for Columbus, Georgia, plant.
15. Letter and attachments from Miner, J.R., GNB Incorporated, to Farmer,
J.R., EPA:ESD. July 27, 1988. Response to Section 114 Information
Request for Zanesville, Ohio, plant.
16. Memo from Nicewander, M.H., EPA:Region VI, to Michelitsch, D.M.,
EPA:ISB. April 20, 1988. Response to request for information on
battery manufacturing plants subject to the NSPS.
17. Letter and attachments from Meverden, J.R., Johnson Controls,
Incorporated, to Farmer, J.R., EPA:ESD. August 9, 1988. Response to
Section 114 Information Request.
18. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
December 6, 1988. Report on July 19, 1988, trip to Johnson Controls,
Incorporated, Winston-Salem, North Carolina.
19. Letter and attachments from Ishihara, M.R., Johnson Controls,
Incorporated, to Michelitsch, D.M., EPA:ISB. November 9, 1988.
Additional Stack test information.
20. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
November 7, 1988. Report on July 13, 1988, trip to Trojan Battery
Manufacturing Company, Lithonia, Georgia.
21. Materials received from Goodwin, J.G., Trojan Battery Manufacturing
Company, to Michelitsch, D.M., EPA:ISB. November 28, 1988. Test
information on Santa Fe Springs, California, plant.
22. Materials from Flanders, G., U.S. Battery Manufacturing Company, to
Farmer, J.R., EPA:ESD. May 12, 1988. Response to Section 114
Information Request.
23. Materials from VanMeter, L., West Kentucky Battery, to Michelitsch,
D.M., EPA:ISB. November 18, 1988. Response to Section 114 Information
Request.
5-26
-------
6.0 COST ANALYSIS
6.1 INTRODUCTION
This chapter presents the capital investment, total annual costs,
and cost effectiveness ratios in second quarter 1988 dollars for
models of alternative control devices to meet New Source Performance
Standards (NSPS). These control devices serve various emission points
in model lead-acid battery manufacturing plants.
The control costs are estimated relative to a baseline reflecting
a total absence of emission controls. The operations for which
estimates are developed include grid casting, paste mixing, the
"three-process" operation, formation, lead oxide manufacturing, lead
reclamation, and the use of central vacuum systems.
The balance of this chapter is organized into five principal
sections. Section 6.2 describes the major steps in the manufacture of
lead-acid batteries, and identifies the emission points that would
need to be controlled under the NSPS. Section 6.3 describes the
alternative controls, while Section 6.4 presents the capital costs for
the controls and the unit costs used in estimating the annual control
costs. Total annual costs are developed in Section 6.5. Finally,
Section 6.6 examines the cost effectiveness of each control
alternative and Section 6.7 compares the estimates herein with
industry experience reported in Section 114 letter responses.
6.2 PROCESS DESCRIPTION
6.2.1 Grid Casting
The manufacture of lead-acid batteries begins with the production
of the lead-alloy grids which constitute the mechanical supporting
structures for the battery electrodes or plates. For the most part,
grids are produced through a casting process. They are also produced
in the form of expanded metal obtained by punching and stretching a
6-1
-------
wide strip of sheet lead alloy. In the context of this discussion,
however, concern 1s only with the casting process.
Grids are generally cast in doublets (i.e., two grids per casting
from molten lead alloy. The lead alloy is melted 1n gas-fired pots at
a temperature of approximately 700°F (371°C). Casting 1s performed
with single, rotary, or continuous casting machines. In some
operations, the melting pots are attached directly to the casting
machines. In other situations, the casting machines are fed from a
central pot furnace.
Emissions from grid casting tend to be lower than those from other
facilities at a lead-acid battery plant. However, a large plant can
still emit up to 1,200 kg/yr of lead from this operation. In some
instances, the emissions from the casting furnaces are vented directly
to the atmosphere. This 1s done primarily to reduce worker exposures
to lead. Generally, the areas around the casting machines are not
vented.
6.2.2 Paste Mixing
Paste mixing is a batch operation performed using a muller, Day, or
dough-type mixer. From 600 to 3,000 Ib (272 to 1,361 kg) of lead
oxide are added to the mixer. Water and sulfuMc acid are then added,
and the mixture blended to form a stiff paste. Different pastes are
formulated for the positive and negative plates. About one weight
percent of expander (commonly a mixture of carbon black, barium
sulfate, and organic materials such as 1ignosulfonic acid) is added
to batches of paste for negative electrodes. Depending on the type
of mixer being used, the mixing cycle can last from 15 minutes
to one hour.
The bulk of the emissions from the mixing operation occur during
the charging of the dry ingredients to the mixer. In a one-hour
cycle, the high-emissions phase would occur for roughly the first
10 minutes. The emissions consist of lead oxide, plus small amounts
of other paste constituents such as Dynel®, organics, and
carbon black.
Following the mixing operation, the paste is applied to the grids
by hand or machine. The plates are then subjected to a drying and
curing process to achieve the porosity and mechanical strength
6-2
-------
required for adequate performance and service Hfe. Curing ensures
proper control of oxidation and sulfatlon of the plates.
6.2.3 The Three-Process Operation
Following the curing process, the plates are usually sent to the
"three-process" operation, which consists of plate stacking, burning,
and assembly of elements in the battery case. The plates are stacked
1n an alternating positive and negative block formation with
insulating separators inserted between each pair of plates. The
stacking is commonly performed by hand, although the operation can be
automated.
The burning operation entails the welding of leads to the tabs of
each positive and each negative plate, thereby fastening the element
together. The completed elements are then assembled into battery
cases either before formation (in "wet" formation) or after formation
(in "dry" formation). An alternative to this operation is the
"cast-on-strap" process 1n which molten lead 1s poured around and
between the plate tabs to form the connection. A positive and a
negative terminal are then welded to the element.
Most of the lead emissions 1n the three-process operation are
generated during the plate stacking and burning/casting operations.
The handling of plates between the process steps also produces
considerable lead emissions. Workers typically straighten stacks of
plates by striking them against a grated surface. The impact causes
particles of paste to become airborne. These particles are generally
collected in vents to protect the health of workers.
6.2.4 Formation
In the formation process, the inactive lead oxide-sulfate paste is
chemically converted to an active electrode. The lead oxide in the
positive plates is oxidized to lead peroxide. In the negative plates,
the lead oxide is reduced to metallic lead. The process involves
placing unformed plates 1n a dilute sulfuric acid solution, and
connecting the positive plates to the positive pole of a direct
current (dc) source, and the negative plates to the negative pole
of the dc source.
6-3
-------
During the process, hydrogen is released in the form of small
bubbles. These bubbles carry sulfuric acid with them as they break
through the surface of the solution and enter the atmosphere. The
process is thus a source of sulfuric acid mist emissions. The
emissions tend to increase with increases 1n temperature and charging
rate. In addition, as the formation process nears Us end, the
release of hydrogen bubbles tends to Increase.
Formation of the battery plates may be performed either within the
battery case after assembly ("wet" formation) or 1n open tanks prior
to battery assembly ("dry" formation). In wet formation, the cells
are placed in the battery case, the lid 1s attached, sulfuric acid is
added, and a charge is applied. After formation, the charging
electrolyte is often removed from the battery for reuse, and new acid
is added. Depending on the particular charging method used, wet
formation may require from one to seven days for completion. In dry
formation, the battery elements are formed by placing them in large
tanks of sulfuric add, then making an electrical connection. The
process typically requires about 16 hours for completion.
Emissions from wet formation operations tend to be minor, and
are usually not controlled or ducted to a stack. In dry formation,
the emissions of acid mist may be controlled through the use of
a surface foaming agent, mist eliminators, scrubbers, or some
combination of these controls.
6.2.5 Lead Oxide Production
The lead oxide mixture used in battery, paste production is
typically 70 percent PbO, with the balance being free metallic lead.
Lead oxide is produced by either the ball mill process or the Barton
process. In the ball mill process, high purity lead pigs (ingots) are
tumbled 1n a mill while being subjected to a regulated flow of air.
Oxidation is initiated by the heat generated through the tumbling
action. During the tumbling, the lead oxide that forms on the surface
of a pig is broken off, along with fine particles of unoxidized lead.
The resulting dust is removed from the mill by a circulating air
stream. Larger particles are ground further 1n a hammermill. The
6-4
-------
lead oxide mixture 1s conveyed to storage bins by means of totally
enclosed screw conveyors. Enough lead oxide 1s entrained in the mill
exhaust gases to justify gas cleaning for product recovery.
In the Barton process, molten lead is fed into a pot and stirred
rapidly. Baffles in the pot break the lead Into fine droplets. The
droplets are then oxidized by an air stream directed over the surface
of the molten lead. The resulting lead oxide is then conveyed by an
alrstream to a fabric filter for recovery. The particle-size
distribution and apparent density of the oxide are controlled by the
temperature maintained in the pot and the volume and velocity of the
air stream that conveys the reacted products. Larger particles are
captured in a cyclone prior to the fabric filter, and passed through a
hammermil1.
6.2.6 Lead Reclamation
Lead reclamation is a process in which relatively clean lead scrap
is melted and cast into pigs for use 1n the battery manufacturing
process. The melting 1s generally done 1n a pot-type furnace.
Reclamation tends to be sporadic, being performed only when enough
scrap lead is available for charging. The emissions from the pot-type
furnaces tend to be minimal.
6.2.7 Central Vacuum Systems
Many lead-add battery plants employ central vacuum systems for
general housekeeping purposes. A central vacuum system is a utility
which usually includes a fan and a small baghouse ducted to the
various work stations. The vacuum connections at the work stations
are used for clean up as required. In several cases, these units have
been determined to be subject to the NSPS on the grounds that they
fall within the category of "other lead emitting" sources.
6.3 POLLUTION CONTROL DEVICES
The alternative control devices are identified in Table 6-1. The
alternatives for lead emissions are impingement scrubbers, fabric
filters, and cartridge collectors. Recently some plants have
6-5
-------
TABLE 6-1- LEAD-ACID BATTERY MANUFACTURE MODEL FACILITY PARAMETERS
AND CONTROL SYSTEMS (a,a)
Facility
Grid Casting])
Paste Mixing
Plant(b)
Site
Stall
Hediui
Large
Small
NediiB
Large
Description
Control Device
Wet Scrubberjd)
F/F-6/1 »/C(e)
Cart. Col. (n)
Sec. HEPAJp)
Met Scrubber (d)
F/F-6/1 A/C(e)
Cart. Col. (n)
Sec. HEPA(p)
Met Scrubber |d)
F/F 6/1 »/C(e)
Cart. Col. (n)
Sec. HEPMp)
F/F-6/1 »/r:(e)
Cart. Col.(n)
Sec. Hm(p)
F/F-6/1 A/C(e)
Cart. Col.(n)
Sec. HD>Mp)
F/F-6/1 »/C(e)
Cart. Col.(n)
Sec. HEPA(p)
of Contro
Noistire
(»)
2-3
2-3
2-3
2-3
2-3
2-3
2-3
2-3
23
2-3
2-3
2-3
2-
2-
2-
2-
2-
2-
2-
2-
2-
Systei
tafttt
(C)
76.5
76.5
76.5
76.5
76.5
76.5
76.5
76.5
76.5
76.5
76.5
76.5
38.0
38.0
38.0
38. 0
38.0
38.0
38.0
38.0
38.0
I
•ature
if]
170
170
170
170
170
170
170
170
170
170
170
170
100
100
100
100
100
100
100
100
100
Vol
•3/liQ
96.0
98.0
98.0
98.0
489.9
489.9
489.9
489.9
734.8
734.8
734.8
734.8
317.1
317.1
317.1
1,585.7
1,585.7
1,585.7
2,378.6
2,378.6
2,378.6
(•e
acfB
3,460
3,460
3,460
3,460
17,300
17,300
17,300
17,300
25,950
25,950
25,950
25,950
11,200
11,200
11,200
56,000
56,000
56,000
84,000
84,000
84,000
Uhcon
Ekiss
kg/F
156.9
156.9
156.9
q
784.5
784.5
784.5
q
1,176.9
1,176.9
1,176.9
q
4,517.5
4,517.5
q
22,586.0
22,586.0
q
33,879.2
33,879.2
q
trolled
ions
Ibs/yr
345.8
345.8
345.8
q
1,729.6
1,729.6
1,729.6
q
2,594.6
2,594.6
2,594.6
q
9,959.4
9,959.4
q
49,793.9
49,793.9
q
74,691.1
74,691.1
q
Contro
Efcissi
kg/fr
4.7
0.6
0.6
I. BE 04
46.7
6.0
6.0
I.8IE 03
106.3
13.3
13.3
3.99B-03
37.9
37.9
0.0114
381
381
0.1141
852.1
852.1
0.2554
lled(c)
ons
Ibs/yr
10.3
1.3
1.3
3.9E-04
103
13.3
13.3
3.99E-03
234.2
29.3
29.3
8.80E-03
83.5
83.5
0.0251
840
840
0.2517
1878.5
1878.5
0.5631
Pollut
Collet
kg/yr
152.2
156.3
156.3
0.5998
737.8
778.5
778.5
5.998
1,070.6
1,163.6
1,163.6
13.2%
4,479.6
4,479.6
37.888
22,205
22,205
380.886
33,027.1
33,027.1
851.845
ants
ted
Ibs/fr
335.5
344.5
344.5
1.3
1,626.6
1,716.3
1,716.3
13.296
2,360.4
2,565.3
2,565.3
29.291
9,875.9
9,875.9
83.475
48,953.9
48,953.9
839.748
72,812.6
72,812.6
1,877.937
I
cr.
-------
TABLE 6-1. LEAD-ACID BATTERY MANUFACTURE MODEL FACILITY PARAMETERS
AND CONTROL SYSTEMS (a,s) (cont.)
Facilitf
Lead Oiide
Manufacturing (h)
Seven
LinkUter
SfStWS
Two Barton
Systems
Three Process
Operation
Piant(b)
Site
sun
Nediui
Large
SUll
Nediw
Large
Description
Control Device
f
F/P-2/1 l/C(q)
Cart. Col. (•)
Sec. HEPAJp)
P/P-2/1 */C(q)
Cart. Col. (n)
Sec. HO>Mp)
F/F-2/1 »/C(g)
Cart. Col. (n)
Sec. HEPftjp)
P/F-6/1 »/C(e)
Cart. Col. (n)
Sec.HEPA(p)
F/F-6/1 »/C|e)
Cart. Col. (n)
Sec. HEPMp)
F/F-6/1 VC(«)
Cart. Col.(n)
Sec. HEPMp)
of Control
Moisture
(»)
f
2-3
2-3
2-3
2-1
21
2-3
2-1
2-1
2-3
1-2
1-2
1-2
1-2
1-2
1-2
1-2
1-2
1-2
Sjstffl
Teqwi
(C)
f
115
115
115
115
115
115
115
115
115
27
27
27
27
27
27
27
27
27
a tire
IF)
f
240
240
240
240
240
240
240
240
240
BO
80
80
80
80
80
80
80
80
Vol
•i/iln
f
6%. 6
696.6
696.6
1,044.9
1,044.9
1,044.9
171.8
371.8
171.8
534.6
514.6
534.6
2,671.1
2,671.1
2,671.1
4,009.7
4,009.7
4,009.7
UK
acfi
f
24,600
24,600
24,600
36,900
36,900
36,900
13,200
13,200
13,200
18,880
18,880
18,880
94,400
94,400
94,400
141,600
141,600
141,600
unooi
tois;
kg/ir
f
101.9
101.9
q
152.8
152.8
q
152.8
152.8
q
2,564.0
2,564.0
q
12,819.0
12,819.0
q
19,228.5
19,228.5
q
itrolled
.ions
Ibs/yr
f
224.6
224.6
q
336.9
336.9
q
336.9
336.9
q
5,652.6
5,652.6
q
28,261.2
28,261.2
q
42,391.8
42,391.8
q
Con In
Ebiss
k9/rr
f
51.1
51.1
0.0153
76.5
76.5
0.0229
76.5
76.5
0.0229
64.1
64.1
0.0190
641.1
641.1
0.1918
1442.6
1442.6
0.4326
)lled(c)
ons
Ibs/jr
f
112.7
112.7
0.0318
168.6
168.6
0.0506
168.6
168.6
0.0506
141.1
141.3
0.0419
1413.4
1413.4
0.4228
3180.5
3180.5
0.9537
Pollu
Colla
kq/»r
f
50.8
50.8
51.085
76.3
76.3
76.477
76.3
76.3
76.477
2,499.9
2,499.9
64.081
12,177.9
12,177.9
640.908
17,785.9
17,785.9
1,442.170
Lants
:ted
lbs/,r
f
111.9
111.9
112.666
168.3
168.3
168.549
168.3
168.3
168.549
5,511.3
5,511.1
141.258
26,847.8
26,847.8
1412.96
19,211.3
39,211.3
3,179.550
cr>
i
-------
TABLE 6-1. LEAD-ACID BATTERY MANUFACTURE MODEL FACILITY PARAMETERS
AND CONTROL SYSTEMS (a,s) (cont.)
Facility
Lead
tion (j,k) )
Foraation(l)
Central VACUA
Sjstos
Plant(b)
Sixe
Sull
Media
Large
Snll
Nediw
Large
Sull
Hediui
Large
Description
Control Device
Net ScntterH)
r/T-ii/1 »/C(e)
Cart. Col.(i)
Sec. MEPk(p)
Met ScnMer(d)
F/F-6/1 l/C|e)
Cart. Col.(i)
Sec. HEPA(p)
Net Scritter(d)
F/F-6/1 A/C(e)
Cart. Col.(n)
Sec. KEPA(p)
Hist Eliiinator
Hist Eliiinator
Hist Eliainator
F/F-3.9/1 A/C|r)
F/F-3.9/1 A/C(r)
F/F-3.9/1 A/C(r)
of Control
Moisture
(»)
2-3
2-
2-
2-
2-
2-
2-3
2-3
2-3
2-3
2
2-
M. .
M. .
N. .
SjStM
Tofttl
(C)
115
115
115
115
115
115
115
115
115
115
115
115
27
27
27
21
21
21
I
•ature
(n
240
240
240
240
240
240
240
240
240
240
240
240
80
60
80
70
70
70
Vol
•3/Bin
196
196
196
198
198
198
198
198
198
198
198
198
1,310.9
6,654.4
9,981.7
16.4
82.1
123.2
iae
acfi
7,000
7,000
7,000
7,000
7,000
7,000
7,000
7,000
7,000
7,000
7,000
7,000
47,000
235,000
352,500
580
2,900
4,350
Uncon
Ekiss
kg/fr
134.1
134.1
1)4.1
q
671.1
671.1
671.1
q
1,006.6
1,006.6
1,006.6
q
2.00E.06
9.83E«06
1.J4E.07
trolled
ions
lbs/,r
295.7
295.7
295.7
q
1,479.6
1,479.6
1,479.6
q
2,219.3
2,219.3
2,219.3
q
4.41Ei06
2.17E.OJ
2.95E.07
Cont re
Efctssi
kq/ir
6.4
3.1
3.1
0.00092
33.1
14J
14.7
0.00440
49.5
22.0
22.0
0.00659
2.00E.04
9.83E.04
1.34E>05
lled|c)
ons
lbs/,r
14.2
6.7
6.7
0.00203
73.1
32.3
32.3
0.00969
109.2
46.5
48.5
0.01454
4.4IE.04
2.I7E.05
2.95E.05
Pollut
Col lee
kq/rr
127.7
131. 0
1)1.0
3.099
6)8.0
656.4
656.4
14.6%
957.1
984.6
984.6
21.993
1.98E<06
9.73C.06
1.33E<07
ants
ted
IbS/fT
281.5
289.0
289.0
6.698
1,406.5
1,447.3
1,447.3
32.290
2,110.1
2,170.8
2,170.8
48.485
4.)7E.06
2.15E.07
2.92E.07
cr>
i
oo
-------
Table 6-1 (Continued)
(a) Developed using information from original Background Information
for Proposed Standards (EPA-450/3-79/028a, November 1979),
original Background Information for Promulgated Standards
(EPA-450/3/79/-028b, November 1980), and information gathered
from industry through survey letters and plant visits; revised
according to comments received from Battery Council
International (BCI).
(b) A small plant is one with the capacity to produce in any one day
batteries which would contain, in total, an amount of lead equal
to 18.1 Mg (20 tons); a medium plant could product lead equal
to 90.7 Mg (100 tons); a large plant could product lead equal to
136.1 Mg (150 tons). This is based upon an average weight of
lead per battery of 20 Ibs.
(c) Emissions controlled to the level of the standard, in comparison
to the uncontrolled case, except where otherwise noted.
(d) Impingement-type scrubber operating at a pressure drop of about
1.25 kPa (5 in W.G.).
(e) Pulse-jet fabric filter with a 6/1 air-to-cloth ratio.
(f) It is assumed that small plants have no lead-oxide manufacturing
facilities.
(g) Pulse-jet fabric filter with a 2/1 air-to-cloth ratio.
(h) Lead-oxide manufacturing facilities include a fabric filter (3/1
A/C ratio) for product recovery as part of the process; this is
presented as uncontrolled. The controlled case represents a
well controlled system, which uses a cartridge collector or a
fabric filter with a 2/1 A/C (air-to-cloth) ratio, in lieu of a
3/1 A/C ratio fabric filter that is used only for economical
recovery of lead oxide. For Barton process oxide production,
two systems are available; Linklater and Barton. The Barton
units are large, and only used in large plants; they also have a
much smaller air flow rate per unit of production than Linklater
systems. Therefore, for large plants, two model plants are
presented; one using Linklater equipment, and one using Barton
equipment.
(j) The emissions from the fabric filter and cartridge collector
controlled cases are calculated to the level achievable by these
systems, which 1s lower than the current standard.
(k) All plant sizes are assumed to have- the same size reclaim
facility, however, they process different amounts of lead per
year.
6-9
-------
Table 6-1 (Continued)
(1) Emissions from the formation process consist of H2S04 mist. The
emission values are based upon the dry formation process, using
a mist eliminator with 99 percent control efficiency as a
control device.
(n) Pulse-jet cartridge collector with a 1.5/1 air-to-filter-surface
ratio.
(p) Secondary high efficiency particulate air filter (HEPA) to
achieve additional pollutant collection following fabric filters
or cartridge collectors. The pollutants collected are those in
addition to those collected by the primary device, assuming a
HEPA collection efficiency of 99.97 percent.
(q) The "uncontrolled" values for the secondary collectors are the
controlled values for the primary collectors, which will vary
depending upon the primary collector used (i.e., fabric filter
or cartridge collector).
(r) Pulse-jet fabric filter with a 3.9/1 air-to-cloth ratio.
(s) Plant sizes and exhaust volumes were changed due to BCI comments
and emission values adjusted accordingly. The uncontrolled
emissions from the pasting line portion of the "paste mixing"
process were assumed to be equal to the uncontrolled emissions
from the three-process operation (on a per-battery basis).
6-10
-------
Installed high efficiency participate air (HEPA) filters downstream of
the primary emission control filter (a "secondary HEPA") to further
clean the exhaust air to allow 1t to be redrculated through the work
area. HEPA filters have a collection efficiency of 99.97 percent and
are described in detail in Reference 1. This reduces costs by
allowing the heated exhaust air to be recirculated 1n the winter time.
HEPA filters can be applied to any of the facilities where the primary
emission control device is either a fabric filter or cartridge
collector. Specifically, they can be used in grid casting, paste
mixing, lead oxide manufacturing, the three-process operation, or lead
reclamation.
The fabric filters estimated for this study were pulse-jet designs
with polyester felt bags using Venturis and cages. It was estimated
from data 1n References 2 through 7 that 30 percent of the bags would
require replacement annually. Cartridge collectors are similar to a
pulse-jet baghouse, but utilize a non-woven filter media of chemically
treated cellulose and synthetic fibers. The filter media are pleated
to Increase the filtering area and to reduce the pressure drop across
the filter without sacrificing the unit collection efficiency. Also,
the media are formed Into cartridges to allow easy replacement. The
cartridges are cleaned automatically during the operation of the unit.
About 50 percent of the cartridges are replaced annually (Reference 7).
Cartridge collectors are finding Increasing application in lead-add
battery plants. The average a1r-to-f1lter-surface ratio of a
cartridge collector is 1.5/1.
For grid-casting operations, the alternatives include impingement
scrubbers, pulse-jet fabric filters, pulse-jet cartridge collectors,
and secondary HEPA filters. In Table 6-1, these are denoted as "Wet
scrubber," "F/F--6/1 A/C," "Cart, col.," and "Sec. HEPA,"
respectively.
Impingement scrubbers are commonly used to control emissions from
grid casting machines and furnaces. The units are relatively small,
and have moderate power requirements (1.25 kPa or 5 in W.G.) and low
water requirements.
6-11
-------
For paste mixing, the alternatives include pulse-jet fabric
filters, pulse-jet cartridge collectors, and secondary HEPA filters.
The specifications are the same as those given above. Currently, both
baghouses and scrubbers are used to control emissions from paste
mixing operations. Some plants vent emissions to a baghouse during
the material charging phase, and to a wet collector during the final
wet mixing stage. However, there would appear to be no technological
reasons why fabric filters or cartridge collectors could not be used
to control emissions during the entire mixing cycle.
Lead oxide production facilities employ settling chambers or
cyclones followed by a shaker fabric filter operating at a 3/1
air-to-cloth (A/C) ratio to collect the product. The arrangement
provides economical product recovery but does not achieve the required
NSPS emission rates. To meet NSPS emission rates either a second
fabric filter must be installed downstream of the product collection
filter or the product collection filter must be replaced with one with
a 2/1 A/C ratio (F/F-2/1 A/C in Table 6-1) or another control device
of similar efficiency. Whichever arrangement is used to meet NSPS
emission rates, a secondary HEPA can be installed downstream if 1t 1s
desired to recirculate the exhaust.
For the three-process operation, the alternative controls include
pulse-jet fabric filters, pulse-jet cartridge collectors, and
secondary HEPA filters. The specifications of the alternatives are as
previously described. Currently, fabric filters or scrubbers are used
to control emissions from the three-process operation. Most plants
vent the stacking, burning, and assembly operations to a common duct
before cleaning the gases. Other plants use a common system to
control emissions from the three-process operation and paste mixing.
The alternative control devices for lead reclamation include
impingement scrubbers, pulse-jet fabric filters, pulse-jet
cartridge collectors, and secondary HEPA filters. The specifications
for these devices are as previously discussed. The exhaust stream
from lead reclamation operations is similar to that emanating from
6-12
-------
grid casting. It 1s therefore a common practice to vent these
operations to a single control device.
As noted earlier, the formation process 1s a source of sulfuric
acid mist. Higher emissions are generally associated with dry
formation. The formation model plant emissions 1n Table 6-1 are based
on the dry formation process. The control device is usually an
Irrigated mist eliminator ("M1st Eliminator," 1n Table 6-1) consisting
of a fan/separator followed by an Integral short packed section.
These units typically have a 99 percent removal efficiency (Reference
9). The scrubbing liquid is sprayed into the fan inlet. Gas-liquid
contacting is promoted by the turbulence in the fan which also acts as
a centrifugal separator, removing the larger droplets. The remaining
droplets are separated by inertlal Impingement in the short packed
section. As shown in Table 6-1 there is a large quantity of acid mist
which dissolves in the scrubbing liquor. The liquor must be treated
before 1t 1s discarded.
For central vacuum systems, the proposed control device 1s a
pulse-jet fabric filter with a 3.9/1 air-to-cloth ratio (F/F-3.9/1 A/C
1n Table 6-1).
6.4 COST DATA, METHODOLOGY AND ASSUMPTIONS
The exhaust stream volumes on which the control cost estimates are
based are given in Table 6-1. The volumes are based on data supplied
by the Battery Council International. The data and the calculations
used to develop the flows 1n Table 6-1 are given in Reference 10.
Since the size of these exhaust streams is partially attributable to
OSHA standards, the costs developed also partially result from the
OSHA standards.
All costs, both capital and annual, are based on inclusion of
controls 1n new plant construction.
6.4.1 Capital Costs
Capital costs include the purchased equipment costs and the direct
and indirect costs of installation. The purchased equipment costs
Include the cost of major equipment items and auxiliaries such as
instrumentation and the cost of taxes and freight. Direct
6-13
-------
Installation costs Include foundations, erection, electrical, piping,
and similar charges. Indirect charges are those resulting from
engineering, supervision, contractors' fees, and start-up assistance
and tests.
All capital costs Include ductwork, control device, fan, and
Instrumentation and controls. All equipment was estimated in carbon
steel except that used 1n formation, where plastic and stainless steel
were used to resist the add mist. Hooding was not included. The
estimates were developed assuming that OSHA workplace air quality
standards, would require hoods and therefore these should not be
charged against EPA emissions standards. If there were no emission
requirements the hoods would be ducted directly to a fan mounted on
the building roof, probably directly above the operation, which
discharged directly to the atmosphere. Since there are emission
standards, the individual hoods are ducted to large collecting ducts
which lead the exhaust of all the hoods for a particular facility to
an emission control device and fan. Only the costs of the collecting
ducts were included 1n this study.
Ductwork was sized at 4,500 ft/min (Reference 11). Ductwork sizes,
lengths, and fittings estimated for each model facility are listed in
Appendix A. Ductwork costs were obtained from References 12 and 13 for
the carbon steel ductwork and Reference 14 for the fiberglass
reinforced plastic (FRP) specified for the formation area.
Fan costs were estimated using a vendor's budget quote
(Reference 15) for sizes up to 16,200 acfm and References 16 and 17
for the larger sizes.
Wet scrubber costs were estimated from a manufacturer's budget
quote (Reference 18 and 19). With the exception of lead oxide
manufacture and the central vacuum systems, fabric filters were
estimated as pulse jets using a 6/1 a1r-to-cloth ratio. Sizes between
4,000 and 16,000 ft2 of filtering area were estimated using the
data and procedures in Reference 20. Manufacturer's quotes,
References 21 and 22, were used for the sizes which are not covered by
the charts in Reference 20.
6-14
-------
Cartridge collector costs were estimated from a manufacturer's
budget quotes (References 23 and 25). Reference 24 1s a
manufacturer's quote for HEPA filters.
Sulfuric add mist 1s removed from air exhausted from formation by
an irrigated mist eliminator; budget costs were obtained from the
manufacturer (References 26 and 27). The mist eliminator discharge
must be treated before 1t leaves the plant so these systems include a
carbon steel storage tank and a plastic or stainless steel feed pump
for 50 percent NaOH. Storage tank costs were estimated from data in
References 28 and 29. A manufacturer's quote list (Reference 30) was
used to estimate the caustic feed pump cost for the small and medium
model facilities. Pumps for the medium and large facilities were
estimated from data in Reference 31.
Basic equipment costs obtained as described above were factored to
obtain first the total purchased equipment cost and then the direct
and Indirect Installation costs using procedures and factors in
Reference 32. The total purchased equipment costs and the direct and
indirect Installation costs were then summed to obtain the total
capital Investment. A detailed example of capital cost estimation
using this procedure is given in Appendix B. An exception to this
procedure was made for wet scrubbers and pulse-jet fabric filters
handling less than approximately 10,000 acfm. These controls can be
obtained with the fan, motor, and instruments mounted on the unit and
prewired. This substantially reduces installation costs. For these
units an Installation cost of 25 percent (Reference 20) of the
purchased equipment cost was used.
Pulse-jet fabric filters larger than about 10,000 acfm and
cartridge filters do not appear to be available as package units,
hence, the factors in Reference 32 were used for all installations of
these controls.
The only basic equipment items included in the secondary HEPA
filter Installations were the filters and the filter frames. The cost
estimates are for standard 24 in by 24 1n by lift 1n filters, which are
sized at 1200 acfm per filter. It was assumed that any increase in
fan and motor capital cost resulting from the low pressure drop (<2
6-15
-------
1n H20) would be negligible. The cost of ductwork was not Included
as a separate Hem. It was assumed that since the HEPA filters would
be Installed close to the primary control device the small amount of
ductwork required would be covered by the Installation cost factors.
Factors from Reference 32 were used to establish the Installation cost
and the total capital Investment for HEPA filters.
All capital costs are on a second quarter 1988 basis. Where
necessary, costs were adjusted to second quarter 1988 using the cost
Indices published in Chemical Engineering. The specific indices used
were:
Index
Fans Process Machinery
Motors Electrical Equipment
Fabric Filters Process Equipment
Storage Tanks Process Equipment
Costs calculated as described above should have study estimate
accuracy of about + 30 percent.
The factors used to establish total capital Investment Include an
allowance for Instruments, but individual Instruments are not broken
out. The NSPS requires that for any subject facility controlled by a
scrubbing system, a monitoring device be Installed that measures and
records the pressure drop across the scrubbing system at least once
every 15 minutes. A differential pressure transmitter and a remote
(if desired) 24-hour circular chart recorder to accomplish this task
have a total purchased cost of $2,000 (Reference 33 for the recorder,
Reference 34 for the transmitter). Installation costs would be highly
dependent on the particular situation but might range from $400 to
$2,000. Annual operating costs would be minimal.
Capital costs for all controls are given In Tables 6-2 through 6-10.
6.4.2 Annual Costs
Annual costs are the sum of direct operating and maintenance
charges, which are the direct costs of operating the equipment and
indirect costs most of which are fixed and accrue whether the
equipment is operating or not. Direct operating costs include
operating and maintenance labor, maintenance materials, replacement
6-16
-------
TABLE 6-2. CAPITAL COST: FOR CONTROL OF GRID CASTING
FURNACE AND MACHINE
New Construction - Second quarter 1988 dollars
Control device and basic equipment
Wet scrubber
Scrubber, fan, motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Fabric filter
Fabric filter, fan, motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Cartridge collector
Cartridge collector
Fan and motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Secondary HEPA filter
HEPA filter
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Small
12.2
4.9
3.1
2"O
25. 2b
16.1
4.9
3.8
2"O
31. Ob
12.8
3.5
4.9
3.8
2570
54.1
1.8
0.3
Z7T
4.8
Cost (thousand $J
Plant size
Medium
27.7
10.8
6.9
45.4
86.7
41.0
10.8
9.3
61.1
132.6
36.6
9.0
10.8
10.2
66.6
144.5
5.7
1.0
6.7
14.5
Large
56.0
12.8
12.4
81.2
155.0
64.3
12.8
13.9
91.0
197.4
46.4
20.7
12.8
14.4
9473
204.6
9.5
1.7
11.2
24.4
3The installation cost, which is the difference between the purchased
equipment cost and the total capital investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown in Appendix B.
^Installation costs are low for the wet scrubber and fabric filter for
the small plant for this facility because they can be obtained as
packaged units.
6-17
-------
TABLE 6-3. CAPITAL COST: FOR CONTROL OF PASTE MIXING
New Construction - Second quarter 1988 dollars
Control device and basic equipment Small
Cost (thousand $)
Plant size
Medium
Large
Fabric filter
Fabric filter, fan, motor
Ductwork
Freight, taxes, instruments
* rchased equipment cost
Total capital Investment3
Cartridge collector
36.5
8.9
8.2
5175
116.3
102.7
9.8
20.3
13271
288.3
143.6
21.5
29.7
19175
422.8
Cartridge collector
Fan and motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Secondary HEPA filter
HEPA filter
Freight, taxes, Instruments
Purchased equipment cost
Total capital investment3
28.0
7.0
8.9
7.9
5TT5
112.5
4.1
0.7
0
10.6
83.1
21.0
9.8
20.5
lIO
291.8
17.7
3.2
2075
45.2
102.0
26.8
21.5
27.1
177.4
384.9
25.8
4.6
3O
66.1
aThe installation cost, which is the difference between the purchased
equipment cost and the total capital investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown in Appendix B.
6-18
-------
TABLE 6-4. CAPITAL COST: FOR CONTROL OF LEAD OXIDE MANUFACTURING
New Construction - Second quarter 1988 dollars
Control device and basic equipment
Fabric filter 2/1 A/Cb
Incremental cost fabric filter
Incremental freight, taxes, instruments
Incremental purchased equipment cost
Incremental capital investment6
Cartridge collector 1.5/1 A/Cb
Incremental cost cartridge collector
Incremental freight, taxes, instruments
Incremental purchased equipment cost
Incremental capital investment6
Fabric filter 3/1 A/CC
Fabric filter
Fan and Motor
Ductwork
Freight, taxes, Instruments
Purchase equipment cost
Total capital investment6
Secondary HEPA filterd
HEPA filter
Freight, taxes, instruments
Purchased equipment cost
Total capital investment6
Medium
31.0
5.6
IO
79.5
(27.4)
(4.9)
T32737
(70.2)
72.8
20.7
12.2
19.0
124.7
270.8
10.7
1.9
12.6
27.4
Cost (thousand
Plant size
Large, Seven
Linklater
Systems
70.1
12.6
8277
179.5
(45.9)
(8.3)
T54727
(117.5)
103.9
43.0
15.3
29.2
191.4
415.3
14.8
2.7
17.5
37.9
$)a
Large, Two
Barton
Systems
16.8
3.0
19.8
42.9
(12.7)
(2.3)
TifTo)
(32.5)
44.2
7.6
9.4
11.0
72.2
156.8
6.2
1.1
773
15.9
See footnotes on following page
6-19
-------
TABLE 6-4. CAPITAL COST: FOR CONTROL OF LEAD OXIDE MANUFACTURING (cont.)
aNumbers 1n parenthesis are credits.
bThe uncontrolled case 1n lead oxide manufacture 1s a pulse-jet fabric filter
with a 3/1 A/C ratio which will provide economical product collection but will
not meet NSPS emission requirements. Substituting either a pulse-jet fabric
filter with a 2/1 A/C ratio or a cartridge collector for the 3/1 A/C ratio
pulse-jet filter will provide both product collection and emissions that meet
NSPS standards at these incremental capital costs.
cThis is the uncontrolled case which will provide economical product collection
but will not meet NSPS emission requirements, see footnote b.
dCosts shown are those for Installing a HEPA filter downstream of either a 2/1
A/C pulse-jet fabric filter or a cartridge collector.
eThe installation cost, which 1s the difference between the purchased equipment
cost and the total capital Investment, was calculated as the sum of factors of
the purchased equipment cost, as described 1n Reference 32 and shown in
Appendix 8.
6-20
-------
TABLE 6-5. CAPITAL COST: FOR CONTROL OF THREE PROCESS OPERATION
New Construction - Second quarter 1988 dollars
Cost (thousand $)
Plant size
Control device and basic equipment Small Medium Large
Fabric filter
Fabric filter
Fan, motor
Ductwork
Freight, taxes, Instruments
Purchased equipment cost
32.0
9.4
11.4
9.5
"6273
130.0
32.5
23.3
33.4
2TO
206.1
55.2
29.3
52.3
34279
Total capital Investment3 135.3 475.6 774.1
Cartridge collector
Cartridge collector 41.7 126.0 177.9
Fan and motor 9.4 32.5 55.2
Ductwork 11.4 23.3 29.3
Freight, taxes, Instruments 11.3 32.7 47.2
Purchased equipment cost 73.8 214.5 309.6
Total capital Investment3 160.1 465.5 671.9
Secondary HEPA filter
HEPA filter
Freight, taxes, Instruments
Purchased equipment cost
Total capital Investment3
5.9
1.1
7.0
15.1
30.9
5.6
3675
79.2
43.5
7.8
5T73
111.3
3The Installation cost, which 1s the difference between the purchased
equipment cost and the total capital Investment, was calculated as the
sum of factors of the purchased equipment cost, as described 1n
Reference 32 and shown 1n Appendix B.
6-21
-------
TABLE 6-6. CAPITAL COST: FOR CONTROL OF LEAD RECLAMATION3
New Construction - Second quarter 1988 dollars
Control device and basic equipment Cost (thousand $)
Wet scrubber
Scrubber, fan, motor 17.4
Ductwork 7.3
Freight, taxes, instruments *'5
Purchased equipment cost 29.2
Total capital investment15 36.5
Fabric filter
Fabric filter, fan, motor 23.1
Ductwork 7.3
Freight, taxes, Instruments 5.5
Purchased equipment cost 35.9
Total capital investment13 44.9
Cartridge collector
Cartridge collector 24.8
Fan, motor 5.2
Ductwork 7.3
Freight, taxes, instruments 6.8
Purchased equipment cost 44.1
Total capital investment0 95.7
Secondary HEPA filter
HEPA filter 3.6
Freight, taxes, Instruments 0.7
Purchased equipment cost 4.3
Total capital investment0 9.3
aAll plant sizes are assumed to have the same size reclamation
facility.
^Installation costs are low for these devices because they can be
obtained as packaged units.
cThe installation cost, which 1s the difference between the purchased
equipment cost and the total capital Investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown in Appendix B.
6-22
-------
TABLE 6-7. CAPITAL COST: FOR CONTROL OF PASTE MIXING
PLUS THREE PROCESS OPERATION BY SAME DEVICE
New Construction - Second quarter 1988 dollars
Control device and basic equipment Sinai
Cost (thousand $)
Plant size
Medium
Large
Fabric filter
Fabric filter
Fan, motor
Duct
Freight, taxes, Instruments
Purchased equipment cost
Total capital Investment3
Cartridge collector
Cartridge collector
Fan and motor
Freight, taxes, Instruments
Purchased equipment cost
Total capital investment
Secondary HEPA filter
HEPA filter
Freight, taxes, Instruments
Purchased equipment cost
Total capital Investment
48.6
33.0
22.4
18.7
122.7
266.5
51
33
274.3
9.8
1.8
11.6
25.1
240.1
53
40
60
39-
854.1
184.0
53.5
40.1
50.0
327.6
710.6
45.2
8.1
5373
115.6
370.0
82.0
63.5
92.8
10873
1,319.9
276.0
82.0
63.5
75.9
49774
1,079.2
69.3
12.5
81.8
177.4
aThe Installation cost, which 1s the difference between the purchased
equipment cost and the total capital Investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown 1n Appendix B.
6-23
-------
TABLE 6-8. CAPITAL COST: FOR CONTROL OF GRID CASTING
PLUS LEAD RECLAMATION BY SAME DEVICE
New Construction - Second quarter 1988 dollars
Control device and basic equipment
Wet scrubber
Scrubber, fan, motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment4
Fabric filter
Fabric filter
Fan, motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Cartridge col lector
Cartridge collector
Fan and motor
Ductwork
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Secondary HEPA filter
HEPA filter
Freight, taxes, instruments
Purchased equipment cost
Total capital investment3
Small
21.4
13.3
6.2
4O
78.2
28.4
b
13.3
7.5
4O
106.7
26.2
6.6
13.3
8.3
~5O
118.2
4.9
0.9
O
12.7
Cost (thousand $)
Plant size
Medium
56.0
20.3
13.7
SO
172.0
37.6
22.0
20.3
14.4
"9473
204.7
45.4
22.0
20.3
15.8
103.5
224.7
10.7
1.9
T2T3
27.4
Large
66.0
22.2
15.9
10TTT
198.8
47.6
40.0
22.2
19.8
12976
281.0
57.0
40.0
22.2
21.5
140.7
305.2
14.8
2.7
17.5
37.9
3The installation cost, which is the difference between the purchased
equipment cost and the total capital investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown in Appendix B.
bFilter price includes the fan and motor.
6-24
-------
TABLE 6-9. CAPITAL COST: FOR CONTROL OF FORMATION
New Construction - Second quarter 1988 dollars
Control device and basic equipment Small
Cost (thousand $)
Plant size
Medium
Large
M1st eliminator
M1st eliminator, fan, motor
Ductwork
Stack
Caustic storage tank
Caustic pump
Freight, taxes, Instruments
Purchased equipment cost
Total capital Investment3
59.1
19.3
1.0
50.0
5.1
24.2
158.7
302.9
224.0
60.2
3.1
66.5
0.7
63.8
4TO
798.8
363.6
107.4
7.7
77.5
0.7
100.2
657.1
1,255.2
aThe installation cost, which 1s the difference between the purchased
equipment cost and the total capital Investment, was calculated as the
sum of factors of the purchased equipment cost, as described in
Reference 32 and shown 1n Appendix B.
6-25
-------
TABLE 6-10. CAPITAL COST: FOR CONTROL OF CENTRAL VACUUM SYSTEM
New Construction - Second quarter 1988 dollars
Control device and basic equipment
Cost (thousand $)
Plant Size
Small
Medium
Large
Fabric filter
Fabric fil
Ductwork
Stack
ten,
Freight, taxes
Purchased
Total capi
equi
tal
fan,
motor
, instruments
pment
cost
investment2
7.
0.
1.
1.
10.
13.
2
7
0
6
5
2
18.
2.
1.
3.
25.
31.
3
0
2
9
4
7
22.
3.
1.
4.
J X •
39.
6
0
2
8
6
4
alnstallation costs are low because the filter can be obtained as a
packaged unit.
6-26
-------
TABLE 6-11. UNIT COSTS USED FOR ESTIMATING
CONTROL SYSTEM ANNUAL COSTS
Second quarter 1988 dollars
Annual cost item
Unit cost (credit)
Direct Annual Costs3
Operating laborb
Supervision
Maintenance labor0
Maintenance materials01
Electricity6
Compressed airf
Scrubber waterS
Caustic soda, 50% liquidh
Indirect Annual Costs
Overheadf
Property taxes1'
Insurance^
Administration^
Capital recovery1
Recovery Credits
LeadJ
Fuel gask
$11.33/hour
15 percent of operating labor
$12.46/hour
Equal to maintenance labor
$0.07/kwh
$0.16/1,000 scf
$0.25/1,000 gal
$225.00/ton
60 percent of the sum of
operating, supervisory, and
maintenance labor plus
maintenance materials
1 percent of total capital
investment
1 percent of total capital
investment
2 percent of total capital
Investment
CRF x (total
capital investment)
($0.37/lb)1
($3.80/106 Btu)
aAnnual control costs are based on 6000 annual operating hours for all
facilities with the exception of lead reclamation where 2000, 4000, and
6000 annual operating hours were used for the small, medium and large
facilities respectively.
bReference 35.
cComputed as 10 percent over Operating Labor - Reference 20.
Computed as 100 percent of Maintenance Labor - Reference 20.
Reference 36.
^Reference 20.
9Reference 37.
6-27
-------
TABLE 6-11. UNIT COSTS USED FOR ESTIMATING
CONTROL SYSTEM ANNUAL COSTS (cont.)
hReference 49; cost is on a 100% caustic soda basis; 73%
iCRF . mini.
where i = interest rate. Ten percent was used in this study in
accordance with Office of Management and Budget guidelines,
n = the economic life of the installation in years.
^Reference 38.
kReferences 39, 40.
lumbers in parenthesis are credits.
6-28
-------
parts, utilities, and supervision. Indirect charges are overhead,
taxes, insurance, administrative charges, and capital recovery. Unit
annual costs and their sources are listed in Table 6-11. Examples of
the calculation of annual costs are given in Appendix C. All annual
cost charges are current.
Information on the number of operating and maintenance man-hours
required to operate fabric filters and wet scrubbers was obtained from
Section 114 letters (References 2 through 7). The ranges given in
the response letters and the values chosen for use in this study are
given below:
Man-hours/week
Operating
Used in
Range this Study
0-2 1
0-3 2
2.5
2
Maintenance
Used in
Range this Study
2-6 4
0.5-5 5
4
2
Wet scrubber
Fabric filter
Cartridge collector
HEPA filter
Reference 7 provided the values for operating and maintenance man-
hours for cartridge collectors; the estimates for the HEPA filters
were from data in References 2, 4, and 5. It was estimated that 100
percent of the HEPA filter media would have to be replaced annually
(Reference 41) and that 50 percent of the cartridge collector
cartridges would be replaced annually. Data in References 2 through 7
also provided the estimate that 30 percent of the fabric filter bags
would be replaced annually. HEPA filter disposal costs were not
included in the annual cost calculation. For disposal in a hazardous
waste landfill the cost could be 1 to 3c/(cfm)(yr) (References 50 and
51). For a typical filter for a medium-sized plant handling 20,000 acfm
the annual disposal cost would be $200 to $600, small in comparison
with the other HEPA filter costs (and credits).
Capital recovery is the series of equal annual payments spread
over the economic life of the control system which return the capital
6-29
-------
investment plus Interest. It 1s calculated as the product of the
Capital Recovery Factor (CRF) and the total capital Investment, I.e.,
where
1 = the interest rate
n » the economic life
For this study all control systems were estimated to have an
economic life of 10 years. An interest rate of 10 percent was used in
accordance with Office of Management and Budget (OMB) guidelines.
Lead recovered by the control devices 1s recycled to a smelter;
the unit annual cost for lead shown on Table 6-11 was used to
calculate the credit for the recovered lead when calculating the
annual costs. Similarly, the unit cost for fuel gas was used to
determine the credit for the energy recovered when heated exhaust air
was recycled via a HEPA filter (see below).
The annual costs calculated using the unit costs described above
are approximately as accurate as the capital costs, that is + 30 percent.
6.5 ANNUAL CONTROL COSTS
Annual control costs are detailed by emitting facility and control
device 1n Tables 6-12 through 6-20. All costs were based on 24 hours/day,
5 days/week, 50 weeks/year operation, which is equivalent to
6,000 hours per year.
Comparing fabric filters' annual costs with those for cartridge
collectors shows that 1n the smaller sizes (Grid casting, Table 6-12)
the costs are comparable within study estimate accuracy. The lower
electric power cost resulting from the lower pressure drop offered by
the cartridge collector versus a fabric filter partially offsets the
higher capital recovery charges resulting from the cartridge
collector's higher Installation cost. In the larger sizes cartridge
collectors have a somewhat lower capital cost than fabric filters (see
Table 6-5). The lower capital recovery cost combined with the lower
energy consumption provides a significantly lower annual cost (e.g.,
see Three-Process Operation, Table 6-16).
6-30
-------
TABLE 6-12. ANNUAL COST: FOR CONTROL OF GRID CASTING FURNACE AND MACHINE
New Construction - Second quarter 1988 dollars
Wet scrubber
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity3
Scrubber water0
Compressed a1rc
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
small
0.6
0.1
2.5
2.5
3.3
0.1
3.4
0.3
0.3
0.5
4.1
med 1 urn
0.6
0.1
2.5
2.5
11.3
0.5
3.4
0.9
0.9
1.7
14.1
large
0.6
0.1
2.5
2.5
16.0
0.8
3.4
1.6
1.6
3.1
25.2
Cost (thousand dollars)
Fabric filter
Cartridge col
Plant size
small
1.1
0.2
3.1
3.1
0.1
3.9
0.4
4.5
0.3
0.3
0.6
5.0
medium
1.1
0.2
3.1
3.1
0.6
14.6
2.0
4.5
1.3
1.3
2.7
21.6
Targe
1.1
0.2
3.1
3.1
0.9
20.9
3.0
4.5
2.0
2.0
3.9
32.1
small
1.4
0.2
2.5
2.5
0.5
2.8
0.4
4.0
0.5
0.5
1.1
8.8
med i urn
1.4
0.2
2.5
2.5
2.0
8.7
2.0
4.0
1.4
1.4
2.9
23.5
lector
large
1.4
0.2
2.5
2.5
2.9
12.1
3.0
4.0
2.0
2.0
4.1
33.3
Secondary HEPA
small
1.1
0.2
1.2
1.2
0.5
0.5
2.3
d
d
0.1
0.7
medium
1.1
0.2
1.2
1.2
2.4
2.6
2.3
0.1
0.1
0.3
2.4
"large
1.1
0.2
1.2
1.2
3.8
3.9
2.3
2.4
2.4
4.9
4.0
Recovery Credit
Lead
Fuel6
Total Annual Costf
(0.1)
17.4
(0.6)
37.8
(0.9)
56.5
(0.1)
22.7
(0.6)
55.5
(0.9)
76.0
(0.1)
25.1
(0.6)
51.9
(0.9)
69.0
d
(8.2)
(0.2)
d
(41.1)
(27.1)
d
(61.7)
(34.1)
aPressure drops used to calculate electric power consumption were, In Inches of water: ductwork 7.5, 3.6, and 3.1
for small, medium, and large plants respectively, wet scrubber 5.0, fabric filter 7.5, and cartridge collector 3.0.
Secondary HEPA electric power consumption costs were based on the pressure drop (2 In H20) through the filter only!
bScrubber water consumption estimated at 1.5, 5.7, and 9.3 gpm for small, medium, and large facilities respectively*
from manufacturers' literature -- see Reference 42.
cCompressed air usage estimated at 2 scfm/1,000 acfm fed to the filter -- Reference 20.
dAmount Is less than $50.00.
eFuel credits resulting from recirculatlng heated air via HEPA filter from October through April.
fCo)umns may not add exactly to totals due to rounding.
-------
cr»
i
OJ
ro
TABLE 6-13. ANNUAL COST: FOR CONTROL OF PASTE MIXING
New Construction - Second quarter 1988 dollars.
Cost (thousand dollars)
Fabric fil
ter
Cartridge col
lector
Secondary HEPA
Plant size
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity3
Compressed a1rb
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Recovery Credit
Lead
Fueld
Total Annual Cost6
small
1.1
0.2
3.1
3.1
0.4
10.0
1.3
4.5
1.2
1.2
2.3
18.9
(3.7)
43.7
medium
1.1
0.2
3.1
3.1
1.8
46.9
6.5
4.5
2.9
2.9
5.8
48.2
(18.1)
108.9
large
1.1
0.2
3.1
3.1
2.4
65.8
9.7
4.5
4.2
4.2
8.5
68.8
(26.9)
149.0
small
1.4
0.2
2.5
2.5
1.2
6.2
1.3
4.0
1.1
1.1
2.3
18.3
(3.7)
38.4
medium
1.4
0.2
2.5
2.5
6.2
26.0
6.5
4.0
2.9
2.9
5.8
47.5
(18.1)
90.3
large
1.4
0.2
2.5
2.5
9.6
37.0
9.7
4.0
3.8
3.8
7.7
62.6
(26.9)
118.0
sma
1.
0.
1.
1.
1.
1.
2.
0.
0.
0.
1.
(13.
(1.
1 1
1
2
2
2
6
7
3
1
1
2
7
c
4)
9)
medium
1.
0.
1.
1.
7.
8.
2.
0.
0.
0.
7.
(0.
(66.
(35.
1
2
2
2
7
5
3
5
5
9
4
3)
9)
8)
large
1.1
0.2
1.2
1.2
11.5
12.8
2.3
0.6
0.6
1.3
10.8
(0.7)
(100.3)
(57.2)
aPressure drops used to calculate power consumption were, 1n Inches of water: ductwork 4.3,
3.1, and 2.8 for small, medium, and large plants respectively, fabric filter 7.5, and car-
ridge collector 3.0. Secondary HEPA electric power consumption costs were based on the
pressure drop (2 In ^0) through the filter only.
^Compressed air usage estimated at 2 scfm/1,000 acfm fed to the filter -- Reference 20.
cAmount is less than $50.00.
dFuel credits resulting from recirculating heated air via HEPA filter from October through April
eColumns may not add exactly to totals due to rounding.
-------
TABLE 6-14. ANNUAL COST ANALYSIS: FOR CONTROL OF LEAD OXIDE MANUFACTURING
New Construction - Second quarter 1988 dollars
Ol
OJ
Incremental Cost (thousand $)a
Fabric
filter
,b
Cartridge collector
Cost
(thousand
$)C,d
Secondary HEPA
Plant size
medium
large
Seven
Llnklater
Systems
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity6
Compressed air
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Recovery Credit
Lead oxide
Fuel gas9
Total Annual Costh
0
0
0
0
0
(7
0
0
0
1
2
9
.8
.1)
.8
.8
.6
.9
f
-
.8
0
0
0
0
1.
(10.
0
1.
1.
3.
29.
(0.
26.
2
7)
8
8
6
2
1)
9
Two
Barton
Systems
0
0
0
0
0.4
(3.8)
0
0.4
0.4
0.9
7.0
(0.1)
5.3
medium
large
Seven
Llnklater
Systems
0.3
f
(0.6)
(0.6)
(1.3)
(15.5)
0.4
(0.6)
(0.7)
(0.7)
(1.4)
(M.4)
f
(32.1)
0.3
f
(0.6)
(0.6)
(2.0)
(23.3)
0.9
(0.6)
(1.2)
(1.2)
(2.4)
(19.1)
f
(49.8)
Two
Barton
Systems
0.3
f
(0.6)
(0.6)
0.8
(8.3)
(0.6)
(0.3)
(0.3)
(0.7)
(5.3)
(0.1)
(15.6)
medium large
1.1
0.2
1.2
1.2
5.6
3.7
2.3
0.3
0.3
0.5
4.5
f
(87.6)
(66.7)
Seven
Linklater
Systems
1.1
0.2
1.2
1.2
8.4
5.6
2.3
0.4
0.4
0.8
6.2
(0.1)
(131.4)
(103.6)
Two
Barton
Systems
1.1
0.2
1.2
1.2
3.4
2.0
2.3
0.2
0.2
0.3
2.6
(0.1)
(47.0)
(32.4)
aCosts shown are the incremental annual costs Incurred when replacing a 3/1 A/C pulse-jet filter selected for
economical product collection with either a 2/1 A/C shaker pulse-Jet or a cartridge collector, either of which
will both collect product and control emissions to NSPS requirements.
DCosts in parenthesis Indicate a negative Incremental cost.
cCosts shown are the total annual costs for operating a HEPA filter.
dCosts in parenthesis are credits
ePressure drops used to calculate power consumption were, in Inches of water: ductwork 3.0, 2.7. and 3.2 for the
medium, large seven Linklaters and large two Bartons cases respectively, cartridge collector 3.0. 3/1 A/C
pulse-Jet filter 11.3, 2/1 A/C pulse-jet filter 7.5. Secondary HEPA electric power consumption costs were
based on the pressure drop (2 in H2<>) through the filter only.
fAmount is less than $50.00.
9Fuel credits resulting from recirculatlng heated air via HEPA filter from October
through Apr 11.
"Columns may not add exactly to totals due to rounding.
-------
CO
-p*
TABLE 6-15. ANNUAL COST: FOR CONTROL OF THREE-PROCESS OPERATION
New Construction - Second quarter 1988 dollars
Fabric fll
ter
Cost (thousand
Cartridge col
Plant
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter med 1am
Utilities
Electricity3
Compressed a1rb
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Recovery Credit
Lead
Fuelc
Total Annual Costd
small
1.1
0.2
3.1
3.1
0.6
16.6
2.2
4.5
1.4
1.4
2.7
22.0
(2.0)
56.8
medium
1.1
0.2
3.1
3.1
3.3
73.9
10.9
4.5
4.8
4.8
9.5
77.4
(9.9)
186.6
large
1.1
0.2
3.1
3.1
4.9
111.0
16.3
4.5
7.7
7.7
15.5
125.9
(14.5)
286.7
small
1.4
0.2
2.5
2.5
2.4
10.2
2.2
4.0
0.2
0.2
0.3
26.1
(2.0)
50.0
dollars)
lector
Secondary HEPA
size
medium
1.
0.
2.
2.
11.
41.
10.
4.
4.
4.
9.
75.
(9.
158.
4
2
5
5
0
6
9
0
7
7
3
7
9)
5
large
1.4
0.2
2.5
2.5
8.6
62.5
16.3
4.0
6.7
6.7
13.4
109.3
(14.5)
219.7
small
1.
0.
1.
1.
2.
2.
2.
0.
0.
0.
2.
(0.
(16.
(1.
1
2
2
2
6
9
3
2
2
3
5
1)
2)
7)
medium
1.1
0.2
1.2
1.2
12.8
14.4
2.3
0.8
0.8
1.6
12.9
(0.5)
(80.8)
(32.0)
Targe
1.1
0.2
1.2
1.2
19.2
21.5
2.3
1.1
1.1
2.2
18.1
(1.2)
(121.2)
(53.0)
aPressure drops used to calculate power consumption were, In Inches of water: ductwork 4.1,
2.8, and 2.8 for the small, medium, and large plants respectively, fabric filter 7.5, and
cartridge collector 3.0. Secondary HEPA electric power consumption costs were based on the
pressure drop (2 1n H20) through the filter only.
bCompressed air usage estimated at 2 scfm/1,000 acfm fed to the filter -- Reference 20.
cFuel credits resulting from reclrculatlng heated air via HEPA filter from October through April,
^Columns may not add exactly to totals due to rounding.
-------
I
10
en
TABLE 6-16. ANNUAL COST: FOR CONTROL OF LEAD RECLAMATION
New Construction - Second quarter 1988 dollars
Cost (thousand
Wet scrubber
Fabric filter
dollars)
Cartridge collector
Secondary HEPA
Plant size
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity3
Scrubber waterb
Compressed a1rc
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Recovery Credit
Lead
Fuel6
Total Annual Costf
small
0.2
d
0.8
0.8
1.2
0.1
1.1
0.4
0.4
0.7
5.9
(0.1)
11.6
medium
0.4
0.1
1.7
1.7
2.3
0.2
2.3
0.4
0.4
0.7
5.9
(0.5)
15.4
large
0.6
0.1
2.5
2.5
3.5
0.3
3.4
0.4
0.4
0.7
5.9
(0.8)
19.5
small
0.4
0.1
1.0
1.0
0.2
1 5
0.3
1.5
0.4
0.4
0.9
7.3
(0.1)
14.9
medium
0.8
0.1
2.1
2.1
0.3
2.9
0.5
3.0
0.4
0.4
0.9
7.3
(0.5)
20.4
large
1.1
0.2
3.1
3.1
0.5
4.4
0.8
4.5
0.4
0.4
0.9
7.3
(0.8)
25.9
small
0.4
0.1
0.8
0.8
0.4
1.2
0.3
1.3
1.0
1.0
1.9
15.6
(0.1)
24.7
med i urn
0.9
0.1
1.7
1.7
0.8
2.3
0.5
2.6
1.0
1.0
1.9
15.6
(0.5)
29.6
large
1.4
0.2
2.5
2.5
1.2
3.5
0.8
4.0
1.0
1.0
1.9
15.6
(0.8)
34.8
small
0.4
0.1
0.4
0.4
0.6
0.4
0.8
0.1
0.1
0.2
1.5
d
(8.3)
(3.5)
medium
0.8
0.1
0.8
0.8
1.1
0.7
1.5
0.1
0.1
0.2
1.5
d
(16.6)
(8.9)
large
1.1
0.2
1.2
1.2
1.7
1.1
2.3
0.1
0.1
0.2
1.5
d
(24.9)
(14.2)
aPressure drops used to calculate power consumption were In Inches of water: ductwork 3.6, wet scrubber 5.0,
fabric filter 7.0, and cartridge collector 3.0. Secondary HEPA electric power consumption costs were based on the
pressure drop (2 In H20) through the filter only.
^Scrubber water consumption estimated at 3.2 gpm from manufacturer's literature -- see Reference 42.
cCompressed air usage estimated at 2 scfm/1,000 acfm fed to the filter — Reference 20.
dAmount 1s less than $50.00.
eFuel credits resulting from reclrculatlng heated air via HEPA filter from October through April.
^Columns may not add exactly to totals due to rounding.
-------
TABLE 6-17. ANNUAL COST: FOR CONTROL OF PASTE MIXING PLUS THREE-PROCESS
OPERATION CONTROLLED BY SAME FILTER
New Construction - Second quarter 1988 dollars
i
co
cr>
Fabric fil
Direct Annual Costs
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity3
Compressed a1r*>
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Recovery Credit
Lead
Fuelc
Total Annual Costd
small
1.1
0.2
3.1
3.1
0.9
31.6
3.4
4.5
2.7
2.7
5.3
43.4
(5.7)
96.4
med 1 urn
1.1
0.2
3.1
3.1
4.9
120.6
17.3
4.5
8.5
8.5
17.1
139.0
(28.0)
300.0
Cost (thousand dol
ter
Cartridge col
large
1
0
3
3
7
179
26
4
13
13
26
214
(41
450
.1
.2
.1
.1
.3
.4
.0
.5
.2
.2
.4
.8
•4)
.9
lector
Plant size
small
1.4
0.2
2.5
2.5
3.4
21.5
3.4
4.0
2.7
2.7
5.5
44.6
(5.7)
88.8
medium
1.4
0.2
2.5
2.5
8.8
69.2
17.3
4.0
7.1
7.1
14.2
115.6
(28.0)
221.9
large
1.4
0.2
2.5
2.5
25.2
102.3
26.0
4.0
10.8
10.8
21.6
175.6
(41.4)
341.4
lars)
Secondary HEPA
small
1.1
0.2
1.2
1.2
4.0
4.6
2.3
0.3
0.3
0.5
4.1
(0.1)
(29.6)
(9.9)
medium
1.
0.
1.
1.
20.
22.
2.
1.
1.
2.
18.
(0.
(147.
(76.
1
2
2
2
2
8
3
2
2
3
8
8)
7)
0)
large
1.1
0.2
1.2
1.2
30.7
34.3
2.3
1.8
1.8
3.5
28.9
(1.9)
(221.5)
(116.3)
aPressure drops used to calculate power consumption were, In Inches of water: ductwork 6.4,
3.0, and 3.0 for small, medium, and large plants respectively, fabric filter 7.5, cartridge
collector 3.0. Secondary HEPA electric power consumption costs were based on the pressure
drop (2 1n H20) through the filter only.
bCompressed air usage estimated at 2 scfm/1,000 acfm fed to the filter -- Reference 20.
cFuel credits resulting from redrculatlng heated air via HEPA filter from October through April,
dColumns may not add exactly to totals due to rounding.
-------
TABLE 6-18. ANNUAL COST: FOR CONTROL OF GRID CASTING PLUS LEAD RECLAMATION CONTROLLED BY SAME DEVICE
New Construction - Second quarter 1988 dollars
I
OJ
Cost (thousand dollars)
Wet scrubber
Fabric filter
Plant size
Cartridge collector
Secondary HEPA
small medium large small medium large smallmedium large small medium Targe
Direct Annual Costs
Operating labor 0.6 0.6 0.6 1.1 1.1 1.1
Supervision 0.1 0.1 0.1 0.2 0.2 0.2
Maintenance labor 2.5 2.5 2.5 3.1 3.1 3.1
Maintenance materials 2.5 2.5 2.5 3.1 3.1 3.1
Filter media 0.4 0.8 1.1
Utilities
Electricity3 5.7 18.5 28.6 6.8 22.7 34.8
Scrubber waterb 0.2 0.5 0.6
Compressed a1rc 0.7 2.5 3.8
Indirect Annual Costs
Overhead 3.4 3.4 3.4 4.5 4.5 4.5
Property tax 0.8 1.7 2.0 1.1 2.0 2.8
Insurance 0.8 1.7 2.0 1.1 2.0 2.8
Administration 1.6 3.4 4.0 2.1 4.1 5.6
Capital recovery 12.7 28.0 32.3 17.4 33.3 45.7
Recovery Credit
2.5
1.2
4.8
0.7
4.0
1.2
1.2
2.4
19.2
1.4
0.2
2.5
2.5
2.9
1.4
0.2
2.5
2.5
4.1
15.7 23.6
2.5 3.8
4.0
2.2
2.2
4.5
36.6
4.0
3.1
3.1
6.1
49.7
1.1
0.2
1.2
1.2
2.5
1.6
2.3
0.1
0.1
0.3
2.1
1.1
0.2
1.2
1.2
5.6
3.7
2.3
0.3
0.3
0.5
4.5
1.1
0.2
1.2
1.2
8.4
5.0
2.3
0.4
0.4
0.8
6.2
Lead
Fuel6
Total Annual Costf
(0.2)
30.6
(1.1)
61.8
(1.7)
76.9
(0.2)
41.3
(1.2)
78.4
(1.8)
106.9
(0.2)
41.0
(1.1) (1.8)
76.1 102.1
d
(16.5)
(3.8)
d
(57.7)
(36.8)
d
(86.6)
(59.5)
aPressure drops used to calculate power consumption were, In Inches of water: ductwork 8.0, 6.1, and 6.4 for the
small, medium, and large plants respectively, wet scrubber 5.0, fabric filter 7.0, and cartridge collector 3.0.
Secondary HEPA electric power consumption costs were based on the pressure drop (2.0 1n H20) through the filter
only.
bScrubber water consumption estimated at 4.7, 5.6, and 7.1 gpm for the small, medium, and large units respectively
from manufacturer's literature -- see Reference 42.
cCompressed air usage estimated at 2 scfm/1,000 acfm fed to the filter -- Reference 20.
dAmount Is less than $50.00.
eFuel credits resulting from reclrculating heated air via HEPA filter from October through April.
^Columns may not add exactly to totals due to rounding.
-------
TABLE 6-19. ANNUAL COST: FOR CONTROL OF FORMATION
New Construction - Second quarter 1988 dolTars
Cost (thousand dollars)
Mist elIminator
Plant size
smal 1
medium
large
Direct Annual Cost
Operating labor 1.7
Supervision 0.3
Maintenance labor 3.1
Maintenance materials 3.1
Sodium hydroxide3 414.0
Utilities
Electricity13 20.0
Scrubber water0 1.4
Indirect Annual Costs
Overhead 4.9
Property tax 3.0
Insurance 3.0
Administration 6.1
Capital recovery 49.3
Total Annual Costd 509.8
2.36
0.36
5.66
5.66
1,980.0
84.0
10.8
8.3
8.0
8.0
16.0
130.0
2,258.8
3.46
0.56
9.3*
9.36
2,680.0
131.3
18.0
13.6
12.6
12.6
25.1
204.2
3,119.9
j*As 50 percent solution (Reference 49).
^Pressure drops used to calculate power consumption were, in inches of
water: ductwork 3.6, 2.7, and 2.9 for the small, medium, and large plants
respectively, scrubber 2.0.
GScrubber water consumption per manufacturer's recommendation -- see
Reference 26.
dColumns may not add exactly to total due to rounding.
eLarge model facility required two scrubbers in parallel; operating and
maintenance labor were thus increased.
6-38
-------
TABLE 6-20. ANNUAL COST: FOR THE CONTROL OF CENTRAL VACUUM SYSTEM
New Construction - Second quarter 1988 dollars
Cost (thousand dollars)
Fabric filter
Plant Size Small Medium Large
Direct Annual Cost
Operating labor
Supervision
Maintenance labor
Maintenance materials
Filter media
Utilities
Electricity3
Compressed air0
1.1
0.2
3.1
3.1
c
1.3
0.1
1.1
0.2
3.1
3.1
0.1
3.8
0.3
1.1
0.2
3.1
3.1
0.2
5.7
0.5
Indirect Annual Costs
Overhead
Property tax
Insurance
Administration
Capital recovery
Total Annual Costd
4.5
0.1
0.1
0.3
2.1
16.1
4.5
0.3
0.3
0.6
5.2
22.7
4.5
0.4
0.4
0.8
6.4
26.4
aPressure drops used to calculate power consumption were, in inches of
water: ductwork 21.2, 9.7, and 9.7 for the small, medium, and large
plants respectively, filter 7.5.
^Compressed air.usage estimated at 2 scfm/1,000 acfm fed to the filter
see Reference 20.
cAmount is less than $50.
dColumns may not add exactly to total due to rounding.
6-39
-------
Lead oxide manufacturing facilities include a pulse-jet fabric
filter operating at 3/1 A/C ratio for product recovery. In this study
this represents the uncontrolled case. Emission control can be
achieved by switching to a 2/1 A/C ratio pulse-jet filter (or to
arcther control device of similar efficiency) for use as the product
recovery filter. Table 6-14 shows the annual incremental cost for
operating either a 2/1 A/C pulse-jet filter or a cartridge collector
rather than 3/1 A/C pulse-jet filter as the product recovery filter.
Note that nearly all of the individual annual costs for the cartridge
collector are less than those of the 3/1 A/C ratio pulse-jet fabric
filter. This results in net annual incremental credits for the
cartridge collector. However, because they are more expensive to
purchase and operate, the 2/1 A/C ratio fabric filters show net
incremental costs in Table 6-14. Table 6-14 also shows the total
annual cost (a credit in this case) of adding a HEPA filter downstream
of the primary control device in lead oxide manufacturing.
It can be seen from Table 6-1 that lead-add battery plants
exhaust a great deal of air to maintain the workplace atmosphere
within OSHA contaminant guidelines. This air must be replaced with
fresh outside air which must -be heated during the winter months. By
removing virtually all the contaminants from the air (see Table 6-1),
HEPA filters placed downstream of the primary filter allow the
exhausted air to be recirculated during the winter months. This
minimizes the need to heat replacement outside air and recovers
process heat to warm the building. For this study, it was assumed
that the HEPA filters would be operated all year although this is not
necessarily industry practice. During the summer the HEPA filter
exhaust would be vented to the atmosphere. When a HEPA filter is used
the total capital and annual costs for air pollution control is the
sum of the costs for the primary control device and the HEPA filter.
For instance, the total incremental annual credit for controlling the
medium lead oxide manufacturing facility with a 2/1 A/C baghouse and a
secondary HEPA would be $9,800 + ($66,700) = ($56,900). An example of
the calculations used to establish the credit for recirculation is
given in Appendix C.
6-40
-------
Using HEPA filters to recover heat by recycling exhausted air Is
clearly a cost saving innovation. For all model facilities the fuel
credits exceed the sum of all other costs, resulting in a net savings.
The savings increase with the size of the air stream and with its
temperature.
The cost of controlling sulfuric add mist during formation is
given in Table 6-19. The major cost Item by a factor of approximately
10 for each model facility is the cost of 50 percent sodium hydroxide
solution to treat the mist eliminator discharge.
Lead-acid battery plants have one or more central vacuum systems
used for general cleaning. Typically, these discharge to a small
fabric filter. Estimated annual costs for such a system are shown
in Table 6-20.
6.6 COST EFFECTIVENESS
Cost effectiveness, as calculated for this study, is the annual
cost per unit mass of pollutant removed. Annual cost is defined as
the annual cost of operating the control device and includes direct
operating charges such as operating and maintenance labor, maintenance
materials and utilities, and Indirect charges such as overhead, taxes,
insurance, administrative charges, and capital recovery.
Recovered material and fuel credits are Included and reduce the
annual cost. Total annual costs are given 1n Tables 6-12 through
6-20. The mass of pollutant removed by each control system Is listed
1n Table 6-1.
Cost effectiveness was obtained by dividing the total annual cost
for a control device by the mass of pollutant removed, e.g., for a
fabric filter controlling a grid casting furnace and machine 1n a
large model facility:
Cost Effectiveness = $76,000/yr (Table 6-12) = $3Q/lb
2565.3 Ibs/yr (Table 6-1)
This definition allows alternative control devices for each model
facility to be compared. Cost effectiveness ratios are tabulated in
Tables 6-21 and 6-22.
6-41
-------
Study of Tables 6-21 and 6-22 shows that wet scrubbers are
somewhat more cost-effective than either fabric filters or cartridge
collectors. Consistent with the annual costs, cartridge collectors
are slightly less cost-effective than fabric filters in the smaller
sizes (<10,000 acfm) and slightly more cost-effective in the larger
sizes. The negative cost-effectiveness ratios for the HEPA filters
reflect the cost savings resulting from installing a HEPA filter and
recirculatlng the heated air during the winter months. To obtain the
overall control cost effectiveness for a model facility employing a
HEPA filter the total annual costs for the fabric filter or cartridge
collector must be added to the credit (usually) for the HEPA filter
and this sum divided by the total lead emissions captured by the two
devices.
6.7 COMPARISON WITH SECTION 114 LETTER DATA
Total installed capital Investment costs for fabric filters
obtained from industry in response to the EPA's request (References 2
through 8, 43, 44, 45) for cost information are compared in Figure 6-1
with the capital costs developed for this study. The Industry costs
were for both shaker and pulse-jet filters, although most of the
filters were pulse-Jets. The costs from this study are for the fabric
filters described 1n Table 6-1. A log-log plot was used to allow all
size fabric filters to be compared on the graph. Where required, the
industry data was escalated to second quarter 1988 costs using the
Chemical Engineering plant cost Index. In the few cases where the
date of installation was not specified, the data were plotted as
received. The solid line on Figure 6-1 is a regression line
calculated using all of the plotted points. The two dashed lines
enclose the + 30 percent region above and below the regression line.
The data shows considerable scatter. This 1s not surprising since
each installation is different and not necessarily in accordance with
the assumptions made for this study. Nevertheless, the data show that
the capital cost data developed for this study are consistent with
industry experience and are not strongly biased one way or the other.
6-42
-------
TABLE 6-21. COST EFFECTIVENESS: CONTROL OF GRID CASTING,
LEAD OXIDE MANUFACTURE, LEAD RECLAMATION, AND GRID CASTING
PLUS LEAD RECLAMATION
Second quarter 1988 dollars
Pollution control cost effect1venessd«Q
Facil1ty and
Plant Size
Wet scrubber Fabric filter
Cartridge
collector
5/kg $/lb $/kg $/lb $7kg $/lb
Secondary
HEPA&
T/kg
$7lb
Grid Casting
Small
Medium
Large
Lead Oxide Manufacture
114
51
53
52
23
24
Medium
Large, Seven Llnklater Systems
Large, Two Barton Systems
Lead Reclamation
Small
Medium
Large
Grid Casting Plus
Reclamation
Lead
91
24
20
41
11
9
145
71
65
114
31
26
66
32
30
193C 88C
352° 16QC
69C 31C
52
14
12
161
67
59
73
30
27
(632)c (287)C
(652)C (296)C
(204)C
188
45
35
85
20
16
(339) (154)
(4,490) (2,040)
(2,570) (1,160)
(1,300)
(1,355)
(424)
(1,150)
(608)
(646)
(592)
(615)
(192)
(523)
(276)
(293)
Small
Medium
Large
109
45
38
50
20
17
144
55
50
65
25
23
143
53
48
65
24
22
(1,050)
(1,780)
(1,690)
(475)
(807)
(765)
positioned downstream of fabric filter or
filter discharge recirculated during winter
aAll values except those for the HEPA filter are calculated from a no control
baseline.
bValues calculated for HEPA filter
cartridge collector and with HEPA
months (October through April).
cFor lead oxide manufacture the no control base
A/C ratio. Values shown are Incremental costs
and a cartridge collector, respectively.
dFigures in parenthesis indicate a credit.
was
for
a pulse-jet filter with a 3/1
a 2/1 A/C pulse-jet filter
6-43
-------
TABLE 6-22. COST EFFECTIVENESS: CONTROL OF PASTE MIXING, THREE-PROCESS
OPERATION, FORMATION, AND PASTE MIXING PLUS THREE-PROCESS OPERATION
Second quarter 1988 dollars
Pollution control cost eTtectiveness0'1-
Facility and
Plant Size
Mist
imlnator
Fabric filter
Cartridge
col lector
$/kg $/lb $/kg $/lb 5/kg $/lb
Secondary
HEPAb
TTkg £7Tb~
Paste Mixing
Small
Medium
Large
Three-Process Operation
Small
Medium
Large
Formation
Small
Medium
Large
Paste Mixing Plus
Three-Process
Operation
10
5
5
23
15
16
4
2
2
10
7
7
9
4
4
20
13
13
0.26
0.23
0.24
0.12
0.11
0.11
4
2
2
9
6
6
(50)
(94)
(67)
(27)
(50)
(37)
(23)
(43)
(30)
(12)
(23)
(17)
Small
Medium
Large
14
9
9
6
4
4
12
6
7
6
3
3
(97)
(74)
(51)
(44)
(34)
(23)
aAll values except those for the HEPA filter are calculated from a no control
baseline.
bValues calculated for HEPA filter positioned downstream of fabric filter or
cartridge collector and with HEPA filter discharge recirculated durin.g
winter months (October through April).
cFigures in parenthesis indicate a credit.
6-44
-------
Figure 6- 1
Fabric Filter Total Installed
Capital Investment Costs, Second Quarter, 1988
en
i
1,000,000
500,000
0)
(C
2 200,000
_i
0
D
H
J? 100,000
o
60,000
20,000
Seco
nd Quar
o This S
a Respo
X
X
x x7^
x"^ x
fer /98fi i
tudy
nses to Sec
a
X
x-
X x
X xO
X X
/D rXo xx
xX x
xX /
/ X
X
/ n
x u
x
dollars
:tion 114
x
/C
X xX
/^ X
-^ X
0
x
x a
Letters
o/B J*
X
X
C
xx
x
X
X
" a
a
X «
X x*'
x^ /
X
^
t!^
X
x
,Xx
C^'
500 1000 2000
5000 10,000 20,000 50,000 100,000200,000 50O.OOO
ACFM
-------
6.8 REFERENCES
1. "Characterization and Control of Rad1onucl1de Emissions from
Elemental Phosphorus Production," EPA-450/3-89-020, U.S.
Environmental Protection Agency, Research Triangle Park, NC,
February 1989.
2. James R. Meverden (Johnson Controls Inc., Milwaukee, WI) to Jack
R. Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Letter response for St. Joseph, MO Plant, August 9, 1988.
3. James R. Meverden (Johnson Controls Inc., Milwaukee, WI) to Jack
R. Fanner (U.S. EPA, Research Triangle Park, NC). Section 114
Letter response for Tampa, FL Plant, August 9, 1988.
4. James R. Meverden (Johnson Controls, Inc., Milwaukee, WI) to Jack
R. Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Letter response for Holland, OH Plant, August 9, 1988.
5. James R. Meverden (Johnson Controls, Inc., Milwaukee, WI) to Jack
R. Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Letter response for Winston-Salem, NC Plant, August 9, 1988.
6. Ron Townsend (Gates Energy Products, Warrensburg, MO) to Jack R.
Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Response, August 5, 1988.
7. James R. Minor (GNB Inc., St. Paul, MN) to Jack R. Farmer (U.S.
EPA, Research Triangle Park, NC). Section 114 Response for
Zanesville, OH Plant, July 27, 1988.
8. Gerald A. Beaky (Exide Corporation, Allentown, PA) to Jack R.
Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Response, July 26, 1988.
9. Todd Ainsworth (Tri-Mer Corporation, Owosso, MI) to Debra
Michelitsch (U.S. EPA, Research Triangle Park, NC). Facsimile
message, April 11, 1989.
10. Deborah M. Michelitsch (Standards Documentation Section, ISB/ESD,
U.S. EPA) to Kenneth R. Durkee (Standards Documentation Section,
ISB/ESD, U.S. EPA), "Model Plant Revisions - Lead-Acid Battery
NSPS Review (ESD #88/03), April 20, 1988.
11. "Industrial Ventilation, A Manual of Recommended Practice,"
Committee on Industrial Ventilation, American Conference of
Governmental Industrial Hygienists, Cincinnati, OH, 19th ed.,
1986.
12. "Price and Data Catalog 1988." Wer-Coy Metal Fabrication Co.,
Warren, MI.
6-46
-------
13. Mid-State Tubeforming, Inc., Eau Claire WI - Tubing, Fitting and
Price Catalog.
14. Dennis E. Woll (A1r Plastics, Inc., Cincinnati, OH to Lynn Fujli
(JACA Corp., Fort Washington, PA). Facsimile message, August 15,
1988.
15. Jim Llllethun (Process Equipment Sales Company, Gibbsboro, NO) to
Roger R. Ellefson (JACA Corp., Fort Washington, PA ). Facsimile
message, July 25, 1988.
16. William M. Vatavuk and Robert B. Neveril, "Estimating Costs of
Air-Pollution Control Systems, Part VII: Estimating Costs of Fans
and Accessories," Chemical Engineering, May 18, 1981, p. 171.
17. Richard S. Hall, William M. Vatavuk, and Jay Matley, "Estimating
Process Equipment Costs," Chemical Engineering, November 21, 1988,
p. 66.
18. Bob Snipe (American A1r Filter, King of Prussia, PA) to Roger R.
Ellefson (JACA Corp., Fort Washington, PA). Facsimile message,
July 6, 1988.
19. Bob Shipe (American Air Filter, King of Prussia, PA) to Roger R.
Ellefson (JACA Corp., Fort Washington, PA), Facsimile message, May
19, 1989.
20. "EAB Control Cost Manual," Third Edition, EPA 450/5-87-001A, U.S.
Environmental Protection Agency, Research Triangle Park, NC,
February 1987.
21. Michael J. Faron (Croll Reynolds Co., Inc., Westfleld, NJ) to
Roger R. Ellefson (JACA Corp., Fort Washington, PA). Facsimile
message, July 12, 1988.
22. Paul Horrox (APM Corp., Darby, PA) to Roger R. Ellefson (JACA
Corp., Fort Washington, PA). Telecon, May 25, 1989.
23. Paul Horrox (APM Corp., Darby, PA) to Roger R. Ellefson (JACA
Corp., Fort Washington, PA). Facsimile Message, January 9,
1989.
24. V1nce Salla (APM Corp., Darby, PA) to Roger R. Ellefson (JACA
Corp., Fort Washington, PA). Facsimile message, November 14,
1988.
25. Paul Horrox (APM Corp., Darby. PA) to Roger R. Ellefson (JACA
Corp., Fort Washington, PA). Memorandum, June 5, 1989.
6-47
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26. Todd Alnsworth (Tr1-Mer Corporation, Owosso, MI) to Roger R.
Ellefson (JACA Corp., Fort Washington, PA). Facsimile message,
November 17, 1988.
27- Todd Alnsworth (Tr1-Mer Corporation, Owosso, MI) to Roger Ellefson
(JACA Corp., Fort Washington, PA), Teleeon, May 31, 1989.
28. Max S. Peters and Klaus D. Tlmmerhaus, "Plant Design and Economics
for Chemical Engineers," McGraw H111 Book Co., New York, Third
Edition, 1980, p. 572.
29. Donald E. Garrett, "Chemical Engineering Economics," 1989, Van
Nostrand Reinhold, New York, NY, p. 303.
30. T.B. Thomas (R.W. Fox Company, Newtown Square, PA) to Roger R.
Ellefson (JACA Corp., Fort Washington, PA). Quotation, November
18, 1988.
31. Richard S. Hall, Jay Matley and Kenneth J. McNaughton, "Current
Costs of Process Equipment," Chemical Engineering, April 5, 1982,
p. 80.
32. William M. Vatavuk and Robert B. Neverll, "Estimating Costs of
Air-Pollution Control Systems, Part II: Factors for Estimating
Capital and Operating Cost," Chemical Engineering, November 3,
1980, p. 157.
33. "Price List Model 390," Chessell Corporation, Newtown, PA., June
1988.
34. Joanne Kusko (Rosemount, Malvern, PA) to Roger R. Ellefson (JACA
Corp., Fort Washington, PA). Facsimile message, November 10,
1988.
35. Employment and Earnings, U.S. Department of Labor, Bureau of
Statistics, Table C-2, Storage Batteries, SIC 3691, April 1988.
36. "Rank of Electricity Prices to Commercial Users," Energy Users
News Magazine, March 1988, p.22.
37. William M. Vatavuk (U.S. EPA, Research Triangle Park, NC) with
Roger R. Ellefson (JACA Corp., Fort Washington, PA). Teleeon,
July 24, 1987.
38. "Chemical Prices", Chemical Marketing Reporter. November 7, 1988,
p. 38.
39. John Stevens (Suburban Propane, Exton, PA) with Roger R. Ellefson
(JACA Corp., Fort Washington, PA). Teleeon, November 22, 1988.
6-48
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40. Fred Kaczor (UGI Corp., Reading, PA) with Roger R. Ellefson (JACA
Corp. Fort Washington, PA). Telecon, November 22, 1988.
41. Deborah M. Michelitsch (Standards Documentation Section, ISB, U.S.
EPA), to William M. Vatavuk, (Cost and Economic Impact Section,
SDB, U.S. EPA), Memorandum, Lead-Add Battery Model Plant
Revisions (ESD #88/03) May 10, 1989.
42. "AAF Type N. Rotoclone , CAD-1-511L," Brochure published by
American A1r Filter, Louisville, KY, p.4.
43. Lee Norman (West Kentucky Battery, Benton, KY) to Jack R. Fanner
(U.S. EPA, Research Triangle Park, NC). Section 114 Response,
November 18, 1988.
44. James R. Miner (GNB Incorporated, St. Paul, MN) to Jack R. Farmer
(U.S. EPA, Research Triangle Park, NC). Section 114 Response for
Zanesville, OH Plant, July 27, 1988.
45. James Honshk (Battery Builders, Inc., Napervllle, IL) to Jack R.
Farmer (U.S. EPA, Research Triangle Park, NC). Section 114
Response, August 16, 1988.
46. "Flow of Fluids Through Valves, Pipes and Fittings," Crane
Technical Paper 410, 17th printing, Crane Co., 300 Park Avenue,
New York, New York, 1978.
47. "CUmatologlcal Data, Pennsylvania, July 1988," Volume 93, Number 7,
National Oceanic and Atmospheric Administration.
48. Deborah R. Michelitsch to Kenneth R. Durkee, Memorandum, "Trip
Report: Survey of an Exide Corporation Lead-Acid Battery
Manufacturing Facility (ESD #88/03)," November 1, 1988.
49. "Chemical Prices," Chemical Marketing Reporter. May 16, 1988,
p. 39.
50. Mark Ishihara (Johnson Controls) with Deborah Michelitsch (U.S.
EPA, Durham, NC), Telecon, September 6, 1989.
51. Steve Burgert (East Penn Manufacturing Co.) with Deborah
Michelitsch (U.S. EPA, Durham, NC), Telecon, September 7, 1989.
6-49
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Facility
Plant
I
cn
O
Paste Mixing plus
Three-Process
Operation
Small
APPENDIX A
DUCTWORK DESCRIPTION
Duct Diameter
Inches Duct Description
Grid Casting
Furnace and Machine
Paste Mixing
Lead Oxide
Manufacturing
Three-Process Operation
Lead Reclamation
Small
Medium
Large
Small
Medium
Large
Medium
Large
Small
Medium
Large
Small
Medium
Large
11
26
32
21
47
58
31
28
27
62
75
18
200 feet straight run
10 elbows
1 blast gate
200 feet straight run
10 elbows
1 blast gate
200 feet straight run
10 elbows
200 feet straight run
10 elbows
2 blast gates
200 feet straight run
10 elbows
1 blast gate
21
27
34
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
-------
Facility
Paste Mixing plus
Three-Process
Operation
(continued)
Plant __
Med1 urn
Paste-Mixing
Three-Process
Duct Diameter
Inches
47
62
Duct Description
250 feet straight run
10 elbows
250 feet straight run
10 elbows
Each facility
would be ducted
individually to
control device.
Large
Paste-Mixing 58
Three-Process 75
250 feet straight run
10 elbows
250 feet straight run
10 elbows
Each facility
would be ducted
individually to
control device.
Grid Casting Plus Lead Small
Reclamation
cr>
en
Med1 urn
11
18
20
26
18
31
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
-------
Facility
Grid Casting Plus
Lead Reclamation
(continued)
Plant
Large
Duct Diameter
Inches
18
32
36
Duct Description
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
100 feet straight run
10 elbows
1 blast gate
cr>
i
en
Formation
Small
Medium
Large
43
97
60, 4 parallel
runs
250 feet straight run
250 feet straight run
250 feet straight run
Vacuum System
Small
Medium
Large
2 branches each 150 feet
long containing:
10 elbows
2 blast gates
4 branches each 100 feet
long containing:
10 elbows
4 blast gates
6 branches each 100 feet
long containing:
10 elbows
4 blast gates
-------
Duct Pressure Drop
Example Calculation
Grid Casting and Machine - Small Facility
As mentioned in Section 6.4.1, the ductwork is sized to achieve a
velocity of 4,500 ft/min to keep the entrained lead particles in
suspension. For the small grid-casting and machine facility, the size
of the duct would be:
Duct area, in sq ft = * = 0.769 ft?
where 3,460 is the actual cubic feet per minute carried by
the duct
Duct diameter in inches = x 4 x 12 = 11.87 inches
IT
To avoid custom fabrication, round this to 11 inches. The actual
velocity in 11 inch duct is:
11 inches = 0.9167 feet
Duct area » (0.9167) TT m 0>gg0 ft2
Velocity • u • I4IS = 5,242 ft/min = 87.4 ft/sec
U. 000
The gas density is calculated from the gas law:
PV » nRT
where
P = Pressure in atmospheres = 1
V » Gas volume = 1 ft^
density
n * Number of moles = 28 g—
R =. Gas constant » 0.7302 >\^\^
T = Temperature in degrees Rankine
= 459.7 + temperature in degrees Fahrenheit
' °'0629
0.73o(4597l70
where 28.9 is the molecular weight of air
6-53
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The friction factor 1s obtained from a Moody, Reynolds number versus
friction factor chart in Reference 46, page A-24. The Reynolds number
1s calculated as
where
Re = Reynolds number
D = Duct diameter in feet » 0.9167
u = Gas velocity in ft/sec
f » Gas density in lbs/ft3
u = Gas viscosity - 1.426 x 10'5 lbs/(ft) (sec) from Reference 46
_ (0.9167)(87.4)(0.0629) , Q3
1.426 x 10-5
From page A-23 1n Reference 46 the wall roughness to pipe diameter
ratio (E/D) 1s 0.00017 for 11 1n duct. Using the Moody friction
factor chart on page A-24 of Reference 46
f ' 0.0158
The pressure loss due to friction for straight pipe 1s then calculated
from the Darcy formula:
hL - fl f°r straight pipe
and from p 2-8 of Reference 46
u2
h * K for a lon9 radius
where
h|_ > Frlctional head loss 1n the duct in feet of gas
0 » Duct diameter 1n feet - 0.9167
L = Duct length in feet = 200
u * Gas velocity 1n duct = 87.4 feet/sec
g = Mass/force conversion factor » 32.17
K = Resistance coefficient for long radius elbow = 0.18 from
Reference 46
6-54
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The total fractional loss then 1s
rr
where 10 1s the number of elbows.
Converting feet of gas to inches of water
1n H20 » 623.0 x 0.0629 x 0.1923 » 7.54 - 7.5
where 0.1923 converts lbs/ft2 to In
* I0
6-55
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Appendix B
Capital Cost Estimation Example
Cartridge Collector
Three Process Operation - Small Facility
Purchased equipment costs
Cartridge collector (Reference 23) 40,700
Gate and drum kit (Reference 23) 1.000
Fan, motor, drive (Reference 15) 9.400
Ductwork (Reference 2 and description 1n 11.434
Appendix A)a
Total basic equipment (BE) 6Z,5J4
Instruments and controls, 0.1 (BE) =
Taxes, 0.03 (BE)
Freight 0.05 (BE)
Total purchased equipment (PE)
Direct installation costs
Foundation and supports, 0.04 (PE) 2,952
Erection and handling, 0.50 (PE) 36,895
Electrical , 0.08 (PE)
Piping, 0.01 (PE)
Insulation for ductwork 0.07 (PE)
Painting 0.02 (PE)
Total direct Installation costs
Total direct costs
Indirect costs
Engineering and supervision, 0.1 (PE) 7,379
Construction and field expense, 0.2 (PE) 14,758
Construction fee, 0.1 (PE)
Startup fee, 0.01 (PE)
Performance test, 0.01 (PE)b
Contingencies, 0.03 (PE)
Total indirect costs
Total capital investment 160,124
say 160,000
aDuctwork costs were estimated as follows:
Cost from Reference 12
Description from Appendix A $
200 feet, 27 in, straight run, 16 ga $25.45/ft x 200 =
10, 27 in elbows, 16 ga $355.00/ea x 10 =
2 blast gates $172/gate x 2
70 connectors $35/ea x 70
Total ductwork
bThis performance test is to demonstrate that the equipment operates
properly, not that the emission limits will be met.
6-56
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Appendix C
Line Item Annual Cost Examples
Example 1
Three-Process Operation - Small Facility - Fabric Filter
Direct Costs
Operating Labor at 2 hr/week
2 x 50 x 11.33 1,133
Supervision at 15% of Operating Labor
0.15 x 1,133 170
Maintenance Labor at 5 hr/week
5 x 50 x 11.33 x 1.1 3,116
Maintenance Material at 100% of Maintenance Labor 3,116
Filter Media, replace 30% per year 615
0.3 x 2,050a
Utilities
Electricity 39.6b x 6,000 x 0.07 16,632
Compressed A1rc 2.175
Total Direct Cost 26,957
Indirect Costs
Overhead at 60% of the SUIT of Operating Labor,
Supervision, Maintenance Labor and Maintenance
Material
0.6 (1,133 + 170 + 2 x 3,116) 4,521
Property Tax at 1% of Total Capital Investment
0.01 x 135,300d 1,353
Insurance at 1% of Total Capital Investment
0.01 x 135,300d 1,353
Administration at 2% of Total Capital Investment
0.02 x 135,300d 2,706
Capital Recovery, 10 year life and 10% Interest
O-lfl-1?1 x 135,300 22,013
(1.1)10-1
Total Indirect Cost 31,946
Recovery Credit
Lead 5,511.3e x 0.37f
Total Annual Cost
6-57
-------
Notes - Example 1
aData 1n References 18 through 24 was used to estimate that 30% of the
bags would be replaced annually. Bag costs were estimated from data
and procedures 1n Reference 20:
At 6/1 A/C ratio, net cloth area » 13,880 , 3,147 ft2
6
Cost of 5-1/8 1n dia. pulse jet bags made of polyester felt 1s
$0.59/ft2 m 3Q86.
Bag cost » 3,147 x 0.59 x IZiil . $2,050; $2,050 x 0.3 =• $615
336.6
Where 371.6 and 336.6 are the Chemical Engineering equipment cost
indices for June '88 and September '86 respectively.
bPressure drop in the ductwork was calculated to be 4.1 in water.
Pressure drop in the filter was estimated to be 7.5 in water for a
total of 11.6 in water. Power requirement is then from equation 5-15
1n Reference 20:
kw = 0.000181(18,880) (11.6) = 39.6 kw
where 18,880 is the acfm gas handled by the fan - see Table 6-1.
°Reference 20 recommends estimating compressed air usage at 2 scfm per
1,000 acfm gas handled by the filter.
Compressed air cost » 2 x I8*880 x 60 x6,000 x ^^- > $2,175
1,000 1,000
Where $0.16 1s the cost of 1,000 scfm of compressed air from Table
6-11.
dTotal capital Investment of $135,300 is given 1n Table 6-5 for a
small three-process operation model facility.
eLead recovered by the filter is 5,511.3 Ibs/yr, see Table 6-1.
fThe cost of lead 1s $.37/lb - See Table 6-11.
6-58
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Example 2
HEPA Filter
Three-Process Operation - Small Facility
Direct Costs
Operating Labor at 2 hr/week
2 x 50 x 11.33 1,133
Supervision at 15% of Operating Labor
0.15 x 1,133 170
Maintenance Labor at 2 hr/week
2 x 50 x 11.33 x 1.1 1,246
Maintenance Material at 100% of Maintenance Labor 1,246
Filter Media, replace 100% per year3 2,560
Utilities
Electricity 6.8b x 6,000cx 0.07 2,856
Total Direct Cost 9,211
Indirect Costs
Overhead at 60% of the sum of Operating, Labor,
Supervision, Maintenance Labor, and Maintenance
Material
0.6 (1,133 + 170 + 2 x 1,246) 2,277
Property Tax at 1% of Total Capital Investment
0.01 x (15,100)d 151
Insurance at 1% of Total Capital Investment
0.01 x (15,100)d 151
Administration at 2% of Total Capital Investment
0.02 x (15,100)d 302
Capital Recovery, 10 year life and 10% Interest
l)10 X 15,100 2,457
(1.1)0-1
Total Indirect Cost 5,338
Recovery Credits
Lead 141.2586 x 0.37f (52)
Fuel9 (16,162)
Total Annual Cost (1,665)
6-59
-------
Notes - Example 2
capacity of a standard 24 x 24 x 1114 1n HEPA was estimated to be
1,200 acfm. The number of standard filters required then 1s:
18.880 acfm (Table 6-1) a 15
1,200
From Reference 25, the cost of a standard filter 1s $160; based on
100 percent replacement the cost of filter media 1s 16 x $160 =
$2,560.
bHEPA filter pressure drop 1s estimated in vendors' literature to
be 1.5 to 2.0 1n water. This study used 2.0 1n.
Kw = 0.000181 (18,880) (2.0) = 6.8 kw
Where 18,880 acfm Is the gas handled by the filter.
cThe HEPA filter 1s operated the entire year or 6,000 hours. Heated
air 1s recirculated through the HEPA filter only during the heating
season of October through April or for 3,500 hours of operation.
During the remainder of the year HEPA exhaust 1s vented to the
atmosphere.
dThe total capital Investment can be found 1n Table 6-5 for a small
three-process operation Facility.
eLead recovered by the filter 1s 141.258 Ibs/yr, see Table 6-1.
fThe cost of lead 1s $.37/lb - See Table 6-11.
9Fuel credit 1s calculated 1n two parts. First, the cost of heating
outside air to 65°F is calculated using the degree days. Degree days
vary by region. For this study degree days typical of the Mid-
Atlantic were used, first because it is a heavily populated area where
a number of battery manufacturing plants are located and second
because it 1s midway between north and south and thus represents a
median.
I Cost Savings « 18,880 x 60 x 24 x 0.018 x 5,200 x 3.80 x IQ"6
0.85
» $11,376
Where
18,880 » the acfm recirculated
60 » minutes/hour
24 » hours/day
0.018 * heat capacity of air 1n Btu/(°F)(acfm)
5,200 = degree days from Reference 47
3.80 x 10-6 » cost of fuel 1n $/Btu - Table 6-11.
0.85 * air heater efficiency (Reference 48)
6-60
-------
The second part of the calculation develops the value of the heat
returned above 65°F:
II m«i- ^u
-------
7.0 ENFORCEMENT ASPECTS
Based on data gathered during this NSPS Review, there have been no
major, widespread problems within the industry in meeting the NSPS
requirements. There are, however, some concerns over the interpretation of
the definition of affected facility, and the required emission testing.
7.1 DEFINITION OF AFFECTED FACILITY
There have been uncertainties in interpretation of affected facilities,
and, therefore, inconsistencies in enforcement of the NSPS among the
regulatory agencies. Some agencies have determined that the affected
facility is all equipment performing a particular operation (i.e., all grid
casting machines, or all three-process equipment, whether new or old),
whereas others have determined that individual units are the affected
facility. When the entire operation is determined as subject, some
agencies require that each emission point from the operation meet the
applicable standard, while others require that the weighted average of
emissions meet the standard.
The choice of affected facility interpretation can have a significant
effect upon a plant's compliance status. For example, assume a plant
installs two new Barton oxide mills. Taken as individual facilities, one
unit's emissions may meet the NSPS limits, while the other may not.
However, taken as one affected facility, the weighted average emissions may
meet the allowable NSPS limit.
It appears that the original intent of the regulation was for all
equipment performing an operation to be the affected facility, as evidenced
by the following paragraph from the preamble to the proposed rule:
7-1
-------
"Selection of Affected Facilities
Lead emitting process operations selected as affected
facilities are lead oxide production, grid casting, paste mixing,
three-process operation, lead reclamation, and other lead emitting
operations. These process operations often consist of several
machines or production lines which perform the same function and
which are located in the same area and ducted to the same control
device. Therefore, for each of the process operations mentioned
above, the affected facility is the entire operation. For example,
at a plant with more than one three-process line, all of the lines
together would be the affected facility."1
However, during this review, it has been determined that these units are
often not located in the same area, and often are ducted to several,
separate control devices (especially in cases of modification/
reconstruction).
The Stationary Source Compliance Division has issued a compliance
determination to at least one EPA Regional Office as follows:
Several new grid casting machines were constructed at an
existing plant, and therefore increased the facility's overall
emission rate. It was determined that the addition of the new
casters would constitute a modification of the entire casting
facility (both new and old casting equipment), and the emission
standard would be applied to the weighted average sum of emissions
from all discharge points within the entire facility.2
This particular Regional Office has subsequently made several compliance
determinations of the same nature, applying to any type of affected
facility.3
Several members of the industry have expressed some concerns with the
"entire department affected facility" approach. One concern is that it is
often difficult or extremely costly to duct the emissions from the various
7-2
-------
individual sources in an affected facility to a common stack or control
device (especially in modification/reconstruction cases). This then
results in the also costly need to test many separate stacks. Another
industry opinion is that including existing equipment in an affected
facility is requiring retrofit control, which they feel is not the intent
of an NSPS, and is creating a form of "bubble" policy. Another common
occurrence in the industry is that often, when an entire "department" is
determined as the subject facility, the plant will control only selected
sources within the facility to bring the weighted sum of emissions to just
below the allowable limit. The individual units that are controlled are
not necessarily the new units, and the control technique is often not the
best technology.
7.2 EMISSION TESTING
Several industry representatives have expressed concerns dealing with
emissions testing at lead-acid battery plants. The first area deals with
the difficulty of performing Method 12, and the variability of results.
Comments were received that Method 12 is very time consuming and difficult
to perform. This often makes it hard to complete three runs in one day
(thus increasing cost), and the runs are for the minimum length of one
hour. This, in turn, results in very small quantities of lead being
collected, and increases the effect of small process variations on the test
results.4 There was also some concern expressed over variability of the
test results between testing firms.
Two tests on the same facility, but from different testing firms, were
submitted for review. The Emission Measurement Branch evaluated both
reports, and found that each one had been correctly performed according to
the parameters of Method 12. Since the tests were not performed
simultaneously, it was not possible to assess the precision of Method 12.
It is believed that the variability between emission test results was due
to process fluctuations within normal operating conditions. Method 12,
Section 2.3 states that, "The within-laboratory precision, as measured by
the coefficient of variation ranges from 0.2 to 9.5 percent relative to a
7-3
-------
run-mean concentration." However, longer sampling times are more
representative of process conditions and should be used, if possible.5'6'7
One solution suggested by industry representatives was to use Method 17
in lieu of Method 12. However, Method 17 is an in-stack filter method
(does not include impinger catch), and would not catch lead fume. Also,
the collection efficiency of Method 17 is very dependent upon the stack
temperature. Furthermore, the standard is based upon Method 12 data; in
order to use Method 17, a correlation between the results of the two
Methods would have to be developed.8 Therefore, Method 17 is not a viable
option.
Several of the industry representatives felt that opacity readings were
meaningless at the grain loadings required by the mass standards.
Approximately 50 percent of the test data received during this review
included opacity readings, all of which were 0 percent.
There are some sources at lead-acid battery plants with very small
stacks (3 inches in diameter), low flow rate (200 scfm), low velocities(400
fpm), or intermittent operation and emissions that are being determined as
subject to the standard (i.e., lead oxide storage; emissions occur only
during filling of the silo). The industry stated that testing of these
sources at proper flowrates and velocities, and for the proper length of
time is difficult.8 However, EPA Reference Methods 1A, 2C, and 2D,
describing procedures for testing small stacks, were promulgated on
March 28, 1989, and address such situations as noted by the industry.9
7-4
-------
7.3 REFERENCES
1. U.S. Environmental Protection Agency. Standards of Performance for New
Stationary Sources; Lead-Acid Battery Manufacture: Proposed Rules.
Federal Register. 45(9)-.2790-2802. January 14, 1980.
2. Materials from Farrell, S., EPArSSCD, to Michelitsch, D.M., EPA:ISB.
December 6, 1988. Compliance determinations on Subpart KK.
3. Materials from Reinermann, P., EPA:Region IV, to Michelitsch, D.M.,
EPA:ISB. February 2, 1989. Compliance determinations on Subpart KK.
4. Memo from Michelitsch, D.M., EPA:ISB, to Durkee, K.R., EPA:ISB.
November 2, 1988. Report on June 22, 1988, meeting with Battery Council
International.
5. U.S. Environmental Protection Agency. Method 12 - Determination of
Inorganic Lead Emission from Stationary Sources. 40 CFR 60, Appendix A,
Method 12. Washington, D.C. Office of the Federal Register. July 1,
1984.
6. Letter and attachments from Meverden, J.R., Johnson Controls
Incorporated, to Farmer, J.R., EPArESD. August 9, 1988. Response to
Section 114 Information Request.
7. Memo from Toney, M.L., EPA:EMB, to Michelitsch, D.M., EPA:ISB. June 1,
1989. Response to questions about variability of EPA Method 12.
8. Reference 4.
9. U.S. Environmental Protection Agency. Standards of Performance for New
Stationary Sources; Methods 1A, 2C, 2D: Final Rule. Federal Register.
54(58):12621-12626. March 28, 1989.
7-5
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