EPA 340/1-77-001
JANUARY 1977
                            Stationary Source Enforcement Series
                  INSPECTION MANUAL FOR ENFORCEMENT OF
                  NEW SOURCE PERFORMANCE STANDARDS
                  SECONDARY LEAD SMELTERS
      EH!
                       U.S. ENVIRONMENTAL PROTECTION AGENCY
                              Office of Enforcement
                           Office of General Enforcement
                             Washington, D.C. 20460

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              INSPECTION MANUAL FOR

ENFORCEMENT OF NEW SOURCE PERFORMANCE STANDARDS:

             SECONDARY LEAD SMELTERS
             Contract No. 68-02-1086
              EPA Project Officer
                   Mark Antell
                  Prepared for

      U. S. ENVIRONMENTAL PROTECTION AGENCY
    Division of Stationary Source Enforcement
                Washington, D. C.
                  January 1977

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This report was prepared for the U.S. Environmental Protection
Agency by Engineering-Science, Inc. of McLean, Virginia in partial
fulfillment of Contract No. 68-02-1086.  The contents of this
report are reproduced herein as received from the contractor.  The
opinions, findings and conclusions expressed are those of the author
and not necessarily those of the U.S. Environmental Protection
Agency.
                               11,

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                          ACKNOWLEDGEMENT
     This report was prepared under the direction of Terrence A.
Li Puma, Manager of the Air Pollution Control Department of
Engineering-Science, Inc.  The principal author was Michael E.
Lukey.  The Technical Director and Editor of the manual was M.
Dean High, Vice President of Engineering-Science, Inc.

     Project Officer for the U.S. Environmental Protection Agency
was Mr. Mark Antell.  The authors appreciate the contributions
made to this study by Mr. Antell and other members of the Division
of Stationary Source Enforcement.
                              iii

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                           TABLE OF CONTENTS

                                                            Page

ACKNOWLEDGMENT                                               iii

1.0  INTRODUCTION                                            1-1

2.0  NSPS AND SIP REQUIREMENTS                               2-1

     2.1  New Sources—NSPS                                  2-1

     2.2  Existing Sources—SIP                              2-2

     2.3  Applicability of Standards                         2-3

     2.4  Hazardous Sources                                  2-4

3.0  PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS,             3-1
     AND EMISSION CONTROL METHODS

     3.1  Process Description                                3-1

     3.2  Atmospheric Emissions                              3-3

          3.2.1  General                                     3-3
          3.2.2  Blast Furnace                               3-4
          3.2.3  Reverberatory Furnace                       3-5
          3.2.4  Pot Furnace                                 3-5

     3.3  Emission Control Methods                           3-6

4.0  MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS   4-1

     4.1  Monitoring the Process, Control Device, and        4-1
          Emissions

     4.2  Recordkeeping                                      4-1

     4.3  Reporting Requirements                             4-3
                                IV

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                   TABLE OF CONTENTS (Continued)

                                                            Page

5.0  START-UP, SHUTDOWN, AND MALFUNCTIONS                    5-1

     5.1  Start-up                                           5-2

     5.2  Shutdown                                           5-2

     5.3  Malfunctions                                       5-2

6.0  INSPECTION PROCEDURES                                   6-1

     6.1  Conduct of Inspection                              6-1

     6.2  Inspection Checklist                               6-2

     6.3  Inspection Followup Procedures                     6-5

7.0  PERFORMANCE TEST                                        7-1

     7.1  Process Operating Conditions                       7-1

     7.2  Process Observations                               7-2

     7.3  Emission Test Observations                         7-4

     7.4  Performance Test Data Table                        7-5

8.0  REFERENCES                                              8-1

APPENDIX A     STANDARDS OF PERFORMANCE FOR NEW              A-l
               STATIONARY SOURCES: CODE OF FEDERAL
               REGULATIONS APPLICABLE TO SECONDARY
               LEAD SMELTERS

APPENDIX B     METHOD 9 - VISUAL DETERMINATION OF            B-l
               THE OPACITY OF EMISSIONS FOR STATIONARY
               SOURCES

APPENDIX C     S 12. - GENERAL POLICY ON THE USE OF          C-l
               SECTION 114 AUTHORITY FOR ENFORCEMENT
               PURPOSES

APPENDIX D     SUGGESTED CONTENTS OF STACK TEST REPORTS      D-l

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                           LIST OF FIGURES

Figure                                                      Page

3.1     Process Flow Sketch of Lead Blast Furnace            3-7
        or Cupola With Cooling System

3.2     Process Flow Sketch of Lead Reverberatory            3-8
        Furnace With Fabric Collector

3.3     Process Flow Sketch for Lead Reverberatory           3-9
        Furnace with Wet Scrubber

                           LIST OF TABLES

Table                                                       Page

2.1     Representative Data From Process Weight Curve         2-3

6.1     Secondary Lead Smelters Inspectors Worksheet,         6-7
        Part I - Process Data

6.2     Secondary Lead Smelters Inspectors Worksheet,         6-8
        Part II - Control Equipment Data

6.3     Secondary Lead Smelters Inspectors Worksheet,         6-9
        Part III - Startup, Shutdown,  and Malfunction

6.4     Secondary Lead Smelters Inspectors Checklist,         6-10
        Part IV - General Observation

7.1     NSPS Inspection Checklist For Secondary Lead         7-6
        Smelters During Performance Test

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                           1.0  INTRODUCTION

     In accordance with Section 111 of the Clean Air Act, the
Administrator of the U.S. Environmental Protection Agency (EPA)
promulgated particulate and opacity standards of performance for
new and modified secondary lead smelters.  The standards became
effective 8 March 1974 and apply to sources the construction
or modification of which was commenced after 11 June 1973.  The
standards are applicable to blast  (cupola) furnaces, reverberatory
furnaces, and pot furnaces of more than 250 kg (550 Ib) charging
capacity.

     Under these new source performance standards, a performance
test must be conducted on any new or modified secondary lead
smelter to ensure that control equipment is designed and installed
which will provide compliance with the standard.  After deter-
mining that the facility with its control equipment does, in fact,
comply with the standards, it is the further intent of the regula-
tions that the equipment not be allowed to deteriorate to the point
where the standards are no longer maintained.  In fact, a specific
provision of the regulations 60.11(d) provides that affected
facilities shall be operated and maintained "in a manner consistent
with good air pollution control practice for minimizing emission."

     The purpose of this manual, therefore, was to provide the air
pollution inspector with necessary information so that he could
determine whether or not a smelter was still in compliance for some
period of time after the conduct of initial performance tests.  To
provide for this continuing enforcement of emission standards, the
Division of Stationary Source Enforcement of the U.S. Environmental
Protection Agency properly anticipated the need for a series of
field inspection manuals which could be used by an air pollution
control official to assist him in determining whether a pollution
source was complying with all applicable regulations.  While this
manual was developed primarily to meet the need for enforcement
of EPA's new source performance standards, it was intended that the
information contained herein would be equally useful for enforce-
ment of state regulations applicable to all existing secondary
lead smelters.

     In both cases the regulations may be enforced by either Federal
or state air pollution control authorities.  Each state may develop
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a program for enforcing the Federal new source performance standards
applicable to sources within its boundaries.  If the proposed pro-
gram is adequate, EPA will delegate implementation and enforcement
authority to the state for all affected sources with the exception of
those owned by the U.S. Government.  Also, each state was required to
submit implementation plans to EPA in 1971 that included emission regu-
lations which would reduce emissions and ensure attainment and shadows
maintenance of the ambient air quality standards (Section 110 of the
Clean Air Act).   If the regulations are not enforced at the state
level, then EPA is legally obligated to enforce the State's Imple-
mentation Plan.   If a Federal inspector observes a violation of a
state's regulation adopted under the State Implementation Plan, he
can co-equally enforce the SIP regulation.

     The scope of this manual includes all processes normally found
in secondary lead smelters.  It should be equally applicable to
both existing and new facilities.  It does not cover primary lead
smelters which use ore concentrates as their lead source.

     This report was prepared from information previously published
on secondary lead smelters and refineries, from stack tests of
several furnaces at lead smelters, from applicable rules and regu-
lations promulgated by EPA and published in the Federal Register,
and from past experiences of the -air pollution control staff of
Engineering-Science, Inc.  The assistance of staff from the Divi-
sion of Stationary Source Enforcement was particularly helpful in
providing direction for the project.
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                   2.0  NSPS AND SIP REQUIREMENTS

2.1  NEW SOURCES—NSPS

     The Federal emission regulations applicable to new or modified
secondary lead smelters are called New Source Performance Standards
(NSPS).  They are published in the Code of Federal Regulations under
Title 40 CFR Part 60.  The standards require control at a level typical
of a well controlled existing smelter and are attainable with existing
technology.  To determine the emission level which should be selected
as the standard, extensive on-site investigations were conducted and
design factors, maintenance practices, available test data, and the
character of stack emissions were considered by EPA.  Economic analyses
were also conducted prior to promulgating the standards.  An EPA
document which provides background information on the derivation of
the standards is entitled "Background Information for Proposed New
Source Performance Standards"'^.

     Provisions of the regulation are applicable to three types of
furnaces commonly found in a secondary lead smelter-reverberatory
furnaces, blast (cupola) furnaces, and pot furnaces of more than 550
pound charging capacity.  A secondary lead smelter is defined as any
facility producing lead from a lead bearing scrap material by smelting
to the metallic form.  Included in the definition are furnaces for
melting lead alloy for newspaper linotype if such furnaces meet the
size requirements.  On and after the date on which the performance
test required to be conducted by paragraph 60.8 is initiated but no
later than 180 days after initial startup, no owner or operator subject
to the provisions of the regulations shall discharge or cause the dis-
charge into the atmosphere from a blast furnace (cupola) or reverbera-
tory furnace any gases which

     1)  Contain particulate matter in excess of 50 mg/dscm
         (0.022 gr/dscf); or

     2)  Exhibit 20 percent opacity or greater.

     Likewise, the effluent gases discharged from a pot furnace larger
than 550 pounds charging capacity shall not exhibit 10 percent opacity
or greater.

     The opacity standards exclude uncombined water vapor.  No new
emission standard was promulgated for pot furnaces since emissions were
estimated to be less than from blast or reverberatory furnaces (smelters
with pot furnaces controlled by baghouses or scrubbers were observed
to have visible emissions less than 10 percent opacity).
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2.2  EXISTING SOURCES—SIP


     Under the 1970 Clean Air Act amendments, each state in 1971
had to file with EPA a State Implementation Plan which included
emission regulations to achieve and maintain ambient air quality
standards.  EPA encouraged some uniformity and reasonable
stringency of the standards by publishing suggested standards as
Appendix B of a regulation on preparation of State Implementation
Plans (5).  In the case of particulate emissions, EPA published
a reference process weight table (Table 2-1) representative of
data from the state and local regulations.  Thus, Federal standards
are stated with respect to grain loading in the emitted gas while
the state standards are generally stated with respect to the mass
emissions from the process.

     No state or local agency now has an emission standard specifi-
cally for the secondary lead smelters.  Instead, process weight
regulations are commonly employed by many state and local jurisdic-
tions to limit particulate emissions from a variety of industrial
sources.  However, the actual limits vary from state to state so
Table 2-1 should be considered illustrative only and should not be
referenced for enforcement purposes.  Furthermore, state regula-
tions are frequently modified and may contain qualifications, ex-
ceptions or special provisions for certain source categories.

     By definition, process weight per hour means "the total
weight of all materials introduced into a special process that may
cause any emissions of particulate matter" to the atmosphere.  In
some industries this definition of process weight is somewhat com-
plicated.  In the secondary lead industry, however, the process
weight refers to the amount of charge fed to the furnace and these
quantities are normally recorded in the operator's daily log for
each furnace.

     For a typical blast furnace rated at 50 tons/day (.production
output) with an exhaust gas flow rate of 15,000 dscfm, the New
Source Performance Standards (NSPS) will allow the furnace to
emit 2.8 Ib/hr of particulate matter.  By comparison, the
reference process weight regulation  (see Table 2.1) for that size
blast furnace (83 tons/day, or 6900 Ibs/hr charge rate) would
limit particulate to only 7.6 Ib/hr.

     Therefore state and local regulations are less stringent than
the NSPS for blast and reverberatory furnaces.  The most stringent
of the state and local standards restrict particulate emissions
of 20- to 80-ton furnaces  to 4 to 8  Ib/hr, which corresponds to
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        Table 2.1  REPRESENTATIVE DATA FROM PROCESS WEIGHT CURVE
                                          Allowable
      Process weight rate,               emission rate,
             Ib/hr	Ib/hr
50
100
500
1,000
5,000
10,000
20,000
60,000
80,000
120,000
160,000
200,000
400,000
1,000,000
0.36
0.55
1.53
2.25
6.34
9.73
14.99
29.60
31.19
33.28
34.85
36.11
40.35
46.72
0.02 to 0.08 gr/dscf  (assuming exhaust gas flow rates of 12,000 to
24,000-dscfm).  Some-of these standards are based on particulate
sampling methods that differ from the EPA technique in that they
include material collected in wet impingers.  Where such testing
methods are specified the impinger particulate catch may account for
anywhere from 5 to 50 percent of the total particulate caught in the
source testing train.

     The opacity regulations of most states apply to all point sources
regardless of whether the emission is discharged from a stack.  Opacity
limitations in some states may apply to fugitive dust sources.


2.3  APPLICABILITY OF STANDARDS

     The New Source Performance Standards apply to the three major types
of furnaces used in secondary lead smelters and refineries.  The
standards do not apply to pot furnaces with less than a 550 pound
charging capacity but such furnaces should not constitute much of a
potential air pollution problem and they will still have to comply with
state emission regulations.  The standards apply after a new facility
has been started up and reached some degree of equilibrium.  For the
first performance test, the owner must give 30 days advance notice
to the Administrator of EPA.  The standards are not applicable during
startup,  shutdown and malfunction since these periods do not constitute
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representative operating conditions.   However,  as will be described later,
the owner must report all excess emissions on a quarterly basis.  Also, •
the regulations ensure that plant operators properly maintain and operate
the affected facility and control equipment between performance tests
including the periods of startup, shutdown and unavoidable malfunctions.

     One of the more difficult subject areas to determine is the
applicability of the standards to existing sources which undergo
modification.  Under the revised regulations the definition of affected
facility is limited to an apparatus to which a standard applies.
"Modification" means any physical change in, or change in the method
of operation of, an existing facility which increases the amount of
any air pollutant (to which a standard applies) emitted into the atmos-
phere by that facility or which results in the emission of any air
pollutant (to which a standard applies) into the atmosphere not previously
emitted.  The definition of modification and other questions of appli-
cability are fully discussed at 40 FR 58416 (December 16, 1975)(9) .

     The proper application of opacity regulations is difficult when
effluent plumes from sources subject to different opacity regulations
are combined.  Such a situation will occur with some frequency in  the
secondary lead smelting industry when existing and new sources, or
several different types of new sources are combined to a single control
device.  To test for opacity and mass emission compliance during a
new source performance test it may be necessary to utilize only that
percentage of baghouse capacity which a new source will use.  At other
times, emissions in violation of NSPS opacity regulations but below SIP
or applicable local regulations will have to be verified as caused
by NSPS covered process or control.  Inspection of plant operations
records should show which operations were running at the time of the
observed emission.  On-site inspection may pinpoint poor operating
procedure on a NSPS covered source.  A finding of poor operation or
maintenance is itself a violation of NSPS and may be supporting evi-
dence that a new source has discharged visible emissions to the atmos-
phere in violation of NSPS emission standards.  On-site inspection of
control devices and records should indicate whether those devices  were
maintained and operated at their performance test conditions during a
period of possible emission limit violation.


2.4  HAZARDOUS SOURCES

     Secondary lead smelters are potential sources of lead, arsenic,
cadmium, and antimony.  It is antitipated that air emissions of many
toxic substances will be controlled in the future under mechanism
prescribed by Section lll(d) of the Clean Air Act.  Under that mechanism,
emissions of a toxic agent from an industrial source category is limited
by an emission standard.  Concurrently, best available control  technology
tor existing sources is promulgated.   States must then develop  regulations
to control existing sources within the BACT guidelines.


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            3.0  PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS, ,
                     AND EMISSION CONTROL METHODS

     At the end of 1971 there were 23 firms operating approximately
45 secondary lead smelting plants in the United States.  In addi-
tion there were 10 primary lead smelters 3 of which  were  located  in
Missouri and the remaining 7 in other states all west of the
Mississippi River.  Primary and secondary lead production are
interdependent upon one another and-do compete with one another
but annual growth rates have generally tended upward at a yearly
rate of about 3 percent.  Four of the companies producing lead
at secondary smelters account for 72 percent of the total output.
The major market for secondary lead is production of lead-acid
storage batteries.  In some cases, new batteries are manufactured
at the same facility as the secondary lead smelter which, in turn,
utilizes old car batteries as a source of lead.

     The processing of secondary lead centers around the utiliza-
tion of three furnaces.  Smelting operations on the scrap lead are
carried out in the blast (cupola) furnace and/or reverberatory
furnace and the final purification steps in pot furnaces.  The
lead-acid  storage battery accounts for 85 percent of the scrap lead
used by the industry and also provides the major market for the
secondary  lead produced.  Thus, the 5 percent annual increase in
consumption of lead-acid storage batteries will result in con-
tinued growth of the secondary lead industry.

3.1  PROCESS DESCRIPTION

     Raw materials consist primarily of old batteries but other
scrap materials may also be received.  The scrap is sorted into
piles of like materials and foreign matter and impurities are
removed.   In some cases, rubber or plastic casings  of the old
batteries  are separated from the lead plates by vibrating tables
which work on the basis of the relative densities of the lead
and rubber.  Other raw materials primarily for the  blast furnace
include coke, limestone, iron, and return slags.

     The blast (cupola) furnace used in processing  secondary lead
is similar to those in the ferrous industry, cylindrically shaped
and stands vertically.  Forced air, sometimes oxygen enriched, is
introduced near the bottom of the furnace through ports called

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tuyeres.  The furnace is batch fed at the top by some type of car
or bucket.  A typical charge is made up of about 80 percent scrap
lead, generally battery plates, 8 percent coke, 2 percent iron,
10 percent limestone and 8 percent return slags.  Heat is produced
by the combustion of the coke which also provides an atmosphere for
reducing the lead oxide feed.  The lead metal collects at the
bottom of the furnace and is continually drawn off through a tap
hole.  The product is "hard" or "antimonial" lead.  A slag is
formed which floats on top of the molten lead retarding its oxida-
tion and is intermittently tapped off.  The furnace is charged
often enough to maintain a fairly constant material level in the
furnace.  A blast furnace that is being fed battery scrap will
recover 70 percent of the lead.

     Reverberatory furnaces operate by radiating heat from the gas
or oil fired burners and the surrounding hot refractory lining
onto the contents of the furnace.  The flame and products of com-
bustion come in direct contact with the charge material.   The
furnace is commonly rectangular in shape with a shallow hearth and
constructed of fire brick and refractory materials.  The principal
use of the reverberatory furnace involves the melting and purifi-
cation of lead by removal of extraneous ingredients.  This process
is called smelting.  The furnace can also be used to melt lead pigs
or ingots for casting.  In a few cases the furnace might be used as
an incinerator to remove combustibles from the scrap lead.  Some
sweating operations may also be performed, that is, separating lead
from other metals in the scrap charge.  This is accomplished by
taking advantage of the low melting temperature of lead.   In some
cases, these operations might be carried out sequentially in the
same furnace.

     The reverberatory furnace may be charged with molten lead
from the cupola on a continuous basis.  In this case, air is
blown through the bath either continuously or intermittently to
oxidize metal impurities.  The metal dross which is formed floats
on top of the lead and is removed intermittently by slagging.  The
lead product is tapped from the furnace into molds on an intermit-
tent basis.  When solid lead scrap, such as battery plates, lead
pipe or cable sheathing, is charged directly to the furnace, the
charge is normally started by slowly melting an initial amount of
solid scrap placed on the hearth.  The temperature is slowly
raised and as a molten bath is formed, additional scrap is added
on a continuous basis.  Again, the air blowing and dressing can be
intermittent or continuous and casting of product is ordinarily
intermittent.  If lead oxide drosses are charged to the furnace,
a reducing agent such as granular carbon must be added to the bath
to reduce the lead oxide to metallic lead.  The furnace operates

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at about 2300°F principally to allow the reaction between metallic
impurities and the oxygen sparged into the bath.  The high tempera-
ture also allows for afterburning in the furnace proper.  This is
accomplished by maintaining a tight furnace, that is, excessive air
leakage into the furnace is prevented and the amount of oxygen intro-
duced to the furnace is thus controlled.  The reverberatory furnace
product is a semi-soft lead which is more pure than that which the
blast furnace produces.

     Pot furnaces are used for remelting and for final alloying
and refining processes before pouring into product molds.  They
are open-top, ceramic lined kettles, hemispherically shaped and
generally range in size from 1 to 50 ton capacity.  They are
normally under-fired by natural gas burners.  Refining is a batch
operation that can vary from several hours to two or more days,
depending on the required final composition.  The most common
processes employed are for the removal of copper and antimony to
produce high purity, soft lead and for the removal of arsenic,
copper and nickel to produce hard lead.  Dressing agents or alloys
are generally added individually and the bath is normally agitated
or in some cases air is bubbled through the bath.  Drosses are
normally skimmed off the surface of the lead by hand.  Depending
on the particular process being performed, the pot furnace tempera-
ture is normally between 600° and 900°F.

     For a more complete description of the unit operations of a
secondary lead smelter please refer to:

     (1)  An Outline of Metallurgical Practice (13)
     (2)  AIME World Symposium on Mining and Metallurgy of Lead and
          Zinc (17)
     (3)  Secondary Base Metals Processing Technology (15)

3.2  ATMOSPHERIC EMISSIONS

3.2.1  General

     Emissions from secondary lead smelters are primarily particu-
lates.   However, a fairly high percentage of sulfur is present as
sulfuric acid in the junked batteries so sulfur dioxide and sulfur
trioxide concentrations are fairly high in the effluent gases from
both the blast and reverberatory furnaces.  Generally, the furnaces
are fired by natural gas or oil and therefore nitrogen dioxide,
hydrocarbons, and carbon monoxide emissions are relatively small.
These gaseous emissions from secondary lead smelters are not
regulated by the new source performance standards although some
state regulations on gaseous emissions might be applicable.  For

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example, other stack gas regulations could be applicable for limiting
sulfur dioxide emissions.  Also, carbon monoxide emission limita-
tions could be applicable to blast furnaces where exhaust gases
contain large quantities of CO.   Hydrocarbon limitations would not
be applicable to the furnaces used at secondary lead smelters.  The
National Emission Standards for Hazardous Air Pollution Sources
could be applicable in the future if lead were so regulated.  In
the interim, some states limit the ambient air concentrations of
lead around smelters and other large point sources.

     Considering particulate emissions from secondary lead smelters
the major sources are the furnaces which are regulated by the NSPS.
However, to be complete all industry sources are considered, start-
ing with the raw material handling and preparation.  Raw material
handling generally does not produce fugitive dust since most of
the scrap materials are old batteries and they contain sulfuric acid
or oil on their surface.  Raw material preparation is minimal and
generally involves separating rubber or plastic casings from the
lead plates.  Slag handling can produce some dust but it generally
is in chunks like clinkers or gravel as opposed to fine powder.
Furthermore, fuels are piped and the coke contains only minimum
amounts of dust.

3.2.2  Blast Furnace

     The lead blast furnace produces a hard or antimonial lead.  A
typical composition for hard lead is 10 percent antimony, 1 percent
or less of arsenic and tin, and traces of copper and nickel.  Com-
bustion air from the tuyeres passes vertically up through the
charge and conveys metal oxides, smoke, bits of coke fuel and other
particulates.  A typical material balance shows that about 7 per-
cent of the charge is carried out of the blast furnace with the
gaseous products of combustion.   Stack gas temperatures range from
1200° to 1350°F  and contain large quantities of carbon monoxide.
An afterburner is normally used to burn the CO and thereby prevent
potential explosions in the ductwork or in the baghouse.

     Particulate matter loadings in blast furnaces gases are ex-
ceedingly heavy but are also highly variable.  One Los Angeles
test reported 12.3 gr/scf in the untreated effluent from a blast
furnace being charged at 2,670 Ib/hr.  The particulate fume and
dust is fairly large ranging in size from 1 to 100 microns; gen-
erally the emissions contain dirt, limestone and coke dust plus
oxides or sulfides of lead.  Discharge points include the stack,
charging doors and metal tapping spout.  The slag tap is not a
major emission point since the slag contains mostly limestone and
iron compounds.  Blast furnace (cupola) emissions are limited to

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20 percent opacity by the NSPS.  Emissions will be increased with
an increase in slag fines charged to the blast furnace.  Emissions
will increase with the air blowing rate through the tuyeres.  Emis-
sions will increase with the amount of dirt or oil on the lead
scrap charged.

3.2.3  Reverberatory Furnace

     If a semisoft lead is desired, then refining takes place in
the reverberatory furnace.  Semisoft lead usually contains about
0.3 percent antimony and up to 0.05 percent copper.  The type and
condition of the scrap raw materials may affect emission rates.
Oily and dirty scrap will create considerably more smoke and
particulate emissions.  Sweating operations are usually conducted
in reverberatory furnaces.  Very often material for both sweating
and reducing such as lead scrap, battery plates, oxides, drosses,
and lead residues are charged to the reverberatory furnace.
Obviously, the type and amounts of charged materials will have a
bearing on the generation of gaseous and particulate emissions
which leave the furnace with combustion gases.  Smoke and fumes
are removed from the furnace by a slight draft which is kept to
a minimum so that the maximum heat can be maintained.  Particulate
emissions are extremely fine (0.3 microns), heavily laden with
metal oxides, and have a tendency to agglomerate.  Because the
furnace is operated near atmospheric pressure to prevent air
leaking into the furnace, all doors and ports are hooded to capture
emissions that spill out of the furnace.  The molten lead pouring
spout is generally the only exception.  If the draft is too slight
compared to the combustion firing rate, then emissions from the
doors and ports will become greater than can be handled by the
hoods and the excess will bypass the hoods to exit through the
roof monitors.

     While no reference discussed the  flux covers, it would seem
from experience with other metal smelting that the thickness of the
flux cover would affect volatilization rates of lead and other metals.
A thick layer probably is not desirable from the operator's viewpoint
since it will reduce the heat transfer to the melt.


3.2.4  Pot Furnaces

     Pot type furnaces are used to produce very soft, high purity
lead.  This soft lead may be designated as corroding, chemical, acid
copper, or common desilverized lead and contains over 99.9 percent
lead.  The refining or alloying consists essentially of adding metal
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ingots of a specific metal to the molten lead until specifications
are met.  Addition of aluminum, for example, reacts with copper,
antimony, and nickel to form complex compounds that can be skimmed
from the surface of the metal.  The only emission point is the open
top of the pot which is typically hooded to prevent emission of lead
oxide fumes into the work space.  In developing the New Source
Performance Standards, EPA did not test emissions from any pot fur-
nace but stated that emissions would be much less than from blast or
reverberatory furnaces.  This is due to the fact that pot furnaces
operate at a lower temperature and with less turbulence than blast
and reverberatory furnaces.  Primary emissions are low and present no
unusual control problems.  Therefore controlled emissions from pot
furnaces should be quite low in terms of visibility and mass.

     Further detail on emissions from secondary lead smelters may be
obtained from:

     (1)  Air Pollution Engineering Manual (19)
     (2)  Source Tests at a Secondary Lead Smelter (14)

3.3  EMISSION CONTROL METHODS

     The principal control device used to reduce particulate emis-
sions from secondary lead furnaces is the fabric filter baghouse.
In the case of controlling blast furnace emissions,  the baghouse
is generally preceded by an afterburner which incinerates oily and
sticky materials thus avoiding blinding the bag fabric.  The high
concentration of carbon monoxide, released by the blast furnace,
is converted to carbon dioxide by the afterburner.   The nature
of the reverberatory furnaces allows for this operation to be per-
formed within the furnace.  Pot furnace emissions do not require
treatment by an afterburner either.  Prior to entering the bag-
house the hot furnace gases must be passed through some type of
cooling facility so that the temperature is compatible with the
bag fabric.  Another method of controlling furnace emissions that
has proven successful is the high energy venturi scrubber.   Here
prior cooling of the gas is unnecessary.  Where battery plates,
highly contaminated with sulfuric acid, are the prime source of
scrap fed to the furnace, it-might be necessary to use a scrubber
after the baghouse to remove sulfur dioxide from the exhaust gas.
The dry collection of the metal oxide dust in the baghouse lends
itself to simple recycling of the valuable product,  as opposed to
the many steps necessary to retrieve the product from the scrubber
catch.  (Example equipment arrangements are shown in Figures 3.1,
3.2, and 3.3.)
                                 3-6

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u>
i
      NATURAL GAS
    AFTERBURNER  -
      TORCH
COOLING
 WATER
  OUT
           AIR
         BLAST

      COOLING
      WATER IN
                                  COOLING
                                   WATER
                                     SPRAY
                                                                               FLUE  GAS




~-
;


S
t *•* « •
' ' ? '
0 *•»
• ' * ^ t
o. ' » «
1 ...
. v ' '. * '

/%%/i
1
x-
•^
-^
— -v^X -4 — |
W

CHARGE
MATERIALS
- LEAD
^ PRODUCT
1 1

                                                                                   t
1

\
1
/\
^

^v

                                                             \
                                                          n   n  n
                   Figure 3.1  Process flow sketch of lead blast  furnace or cupola
                                           with cooling system

-------
             REVERBERATORY
               FURNACE
                 SETTLER -
                 COOLERS
       GAS OR
        OIL FUEL
COMBUSTION
   AIR
         AIR
        LANCE
DR05S
                    LEAD
                   PRODUCT
\>    ^
   t	
                                            LEAD OXIDE TO
                                            BLAST FURNACE
                       FABRIC
                     COLLECTOR
                                                               YY
    TO
BLAST
 FURNACE
                                                                              STACK
                                                                            DISCHARGE
          FAN
               f
                Figure 3.2 Process flow sketch of  lead reverberatory furnace
                                  with fabric collector

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                                                                  FLUE GAS
VO
                                 WATER
                                 QUENCH
        COMBUSTION AIR
     — FUEL GAS OR OIL
            AIR
 VENTURI
CONTACTOR

                        DROSS
                    LEAD
                   PRODUCT
        GAS
     ABSORPTION
       TOWER
                                                     MIST ELIMINATOR
                                                               b-CZD
                                                 SURGE
                                                 TANK
                 PUMPS
CAUSTIC
 TANK
              Figure 3.3 Process flow sketch for lead reverberatory furnace with
                                  wet scrubber

-------
     Most commonly, a pull-through type, compartmentalized baghouse
is used because it allows for easier maintenance than a single chamber
house.  Generally, the tubular bags used are constructed of dacron,
which has been found to be a good cost/life compromise, although
in some cases fiberglass material is used.  The gas temperature
must be reduced to about 300°F for dacron or about 500°F for fiber-
glass so that the bag fabric will not be destroyed.  Some type of
cooling duct system, commonly preceded by a water spray, is employed
to obtain the-necessary temperature reduction.  Also, it is fairly
common to have a thermally controlled damper which allows dilution air
into the gas stream prior to entry into the baghouse for additional
cooling.  The operator must also be careful to keep the temperature
of the gas entering the baghouse at least 50°F above the dew point
of the gas to prevent condensation within the unit.  This would cause
caking on the bags and the resulting pressure build-up would ultimately
rupture the bag fabric.  In addition to the water, acids will also
be formed from the sulfur, etc., in the gas, causing damage to the
bag fabric and corrosion to the house structure.  A gas volume to cloth
area ratio of up to 2 to 1 is commonly employed for efficient operation
of the collection system.  Most likely, the only monitoring instrument
on the baghouse will be a manometer which measures the pressure drop
across the entire system.  This will commonly range up to 4 in. tUO
gauge.  It is economically unwise for a_-plant to allow excessive
amounts of dilution air into the system or to maintain a very high
pressure drop across the bags.  The manometer will indicate a bag
rupture by the resulting drop in pressure but the obvious increase
is visible emissions emitted by the baghouse is the more common method
of establishing a malfunction in the baghouse.

     Venturi scrubbers are not utilized as commonly as baghouses in
the secondary lead industry.  Depending on the application, scrubbers
can vary between 30 and 100 in. H20 pressure drop.  In some cases,
the furnace gas temperature has to be reduced by water sprays to
prevent adverse operation of the scrubber.  A 60 in. H20 pressure
drop corresponds to a throat velocity of about 200 ft/sec and water
requirements of about 3 gallons per minute per 1,000 scfm of gas.
Almost all scrubbers will have a manometer or other gauges to indicate
the pressure drop across the unit.  To a lesser degree, the water
flow rate within the scrubber is important.  Some modern plants will
have monitoring systems that record the pressure drop, water flow
rate, and the gas flow rate to the scrubber.  If PVC coated wire or
battery housings are included in the scrap charge, hydrogen chloride
gas will be released.  Teflon coated wire in the furnace charge will
release hydrogen fluoride gas.  Normally these gaseous components are
at very low concentration, if present at all.
                                 3-10

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     No electrostatic precipitators have been utilized to control
secondary lead smelters emissions probably because of the small gas
volumes and the resistivity of the lead oxide particles.

     The Environmental Protection Agency observed 11 well controlled
secondary lead smelters.  Visible emissions at the plants were all
less than 10 percent opacity.  Stack testing was conducted on three
reverberatory furnaces and two blast furnaces.  The blast furnaces
were controlled by  (1) an afterburner and baghouse; (2) an after-
burner, baghouse, and venturi scrubber, and (3) a venturi scrubber.
Particulate emissions averaged 0.003, 0.009, and 0.015 gr/dscf.
The reverberatory furnaces were controlled by baghouses with particu-
late emissions averaging 0.004 gr/dscf in both cases.  No visible
emissions were noted in three of the furnaces tested.  Two furnaces
had visible emissions of 15 percent opacity or less.

     Earlier the Los Angeles County Air Pollution Control District
(APCD) tested three blast furnaces and one reverberatory furnace.  The
blast furnaces were controlled with afterburners and baghouses;  the
reverberatory furnace was controlled by a baghouse.  Emissions averaged
respectively 0.001, 0.005, 0.012, and 0.003 gr/dscf.

     It is common practice in the industry to manifold the exhaust
from several furnaces into a common control system thus achieving
some economy of scale.  Also it is common and necessary to cool
the exhaust gases from the furnaces prior to entering the fabric
filter.  This is accomplished by use of radiation cooling, water
sprays, and/or air dilution.  Since the fan on the end of the
system pulls a fairly constant gas volume the success of the
system depends on the radiation and water spray cooling to eliminate
the need for excessive air dilution cooling directly ahead of the
fabric filter.  If this damper opens, the bags are protected but
the collection efficiency of the hoods over the furnace will be
diminished.  Obviously the grain loading going out of the bags will
be low but more of the metal fume will be escaping the hoods and
discharging to the atmosphere through the plant's roof monitors.

     Further detail on air pollution control equipment applications
on secondary lead smelters can be obtained from:

     (1)  Air Pollution Engineering Manual (19)
     (2)  Background Information for Proposed New Source Performance
          Standards (3)
     (3)  Proceedings - The Uses and Fabric Filtration Equipment
          Specialty Conference (16)
     (4)  Sources of Air Pollution and Their Control (18)
                                3-11

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(5)   Study of Technical and Cost Information for Gas Cleaning
     Equipment in the Lime and Secondary Non-Ferrous Metal-
     lurgical Industries (12)
(6)   Control of Metallurgical  and Minal Dusts and Fumes in
     Los Angeles County (1)
(7)   Control Techniques for Particulate Air Pollutants (6)
                          3-12

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    4.0  MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS

4.1  MONITORING THE PROCESS, CONTROL DEVICE, AND EMISSIONS

     One purpose of monitoring operations and maintenance of the
furnaces at secondary smelters is to ensure that the compliance
determined by performance tests is maintained on a continuing
basis by proper operation and maintenance of all equipment.

     From an air pollution control viewpoint, the major problems
associated with secondary lead smelting are efficient capture of
particulate matter generated by the furnaces and subsequent re-
moval of the particulate by abatement equipment.  It has been
positively shown that with current air pollution control tech-
nology, particulate emissions from these plants can be reduced
to meet all applicable Federal and state emission standards.  Thus
assuming proper design of the abatement system, the problem becomes
one of proper maintenance and use of the equipment.

     At the present time, new source performance standards for new
or modified secondary lead smelters do not require any monitoring
equipment on the processes, on the control equipment, or on the
emissions discharged to the atmosphere.  However, either specific
or general monitoring requirements may be in effect under certain
State Implementation Plans, although again, EPA has not promulgated
any minimum requirements for secondary lead smelters.

4.2  RECORDKEEPING

     Since'automatic monitoring is not presently required for
secondary lead smelters, recordkeeping on a routine basis becomes
extremely important to provide a method for the air pollution con-
trol officer to determine that operating and maintenance practices
are consistent with reasonable air pollution control needs.  Records
should be kept on production processes, on control equipment and
on emissions.  Each of these parameters are described separately
although obviously there are interrelationships.

     Also, it should be clear that the suggested recordkeeping
is not now required by the NSPS and probably not by any of the
state agencies.  Section 114(a)(ii) of the Clean Air Act, as
amended, provides that the Administrator may require the owner or
operator of any source to provide information for the purpose of
                                4-1

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determining "whether any person is in violation of any such standard
'or any requirement of such a plan."  This is one of the most
important enforcement tools under the Clean Air Act, in that the
source can be required to provide the information which may be
the basis for later enforcement by EPA.

      The facility operator should maintain a description (tabula-
 tion and schematic diagrams)  of the  plant identifying major
 equipment items,  types  of furnaces,  and controls used for the
 smelting operations.  Within  a secondary lead smelter there are
 at least three different types of furnaces.   However,  the types
 of records that should  be maintained are similar.   On each furnace,
 the following information should  be  recorded and very likely will
 be available in the Company's records for each heat or batch:

      (1)  Process or  charge weight rate and quantity of  ingots
           or product produced, to nearest ton;
      (2)  Specification of the ingots or product;
      (3)  Date and time heat  began and ended,  to nearest hour;
      (4)  Fuel consumption, to nearest 100 cubic feet or 10 gallons;
      (5)  Oxygen consumption, to  nearest 100 cubic feet;
      (6)  Compressed air consumption, to nearest 100 cubic feet;
      (7)  Flux identification by  constitutents and consumption,
           to nearest 100 pounds;
      (8)  Slag handling process and  T^S emission control;
      (9)  Gas flow system data; power requirements,  exhuast flow
           rate;
     (10)  Malfunctions;
     (11)  Operating deviations for above items.

      The purpose of recording the above process data is  to be
 able to compare the batch or  heat production cycle with  the
 production at the time  of the performance test.   The emission
 rate for a given ingot  specification will increase if the heat is
 produced quicker by using more fuel, more oxygen,  more compressed
 air,  etc.   Also,  the  capture  efficiency of  the hoods  would probably
 decrease as production  rates  increased  above the performance tested
 production rate.   Since  the blast furnace (cupola)  operation is con-
 tinuous  the above information should be recorded at  the  end of each
 shift  or three times  daily.

      The exhaust  gas  collection,  venting, and emission control
 system should be  described (diagramed)  in detail.   The sequence
 of controls,  types of controls (afterburners,  cooling systems,
                               4-2

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PM collectors, baghouses, filter types) should be outlined and
described using quantitative parameters.  For each control com-
ponent or system checkpoints the respective information recorded,
at the intervals indicated, should include:

     (1)  Quantity of collected dust and fume, by month to nearest
          ton;
     (2)  Volumetric flow on inlet to collector, on first of each
          month;
    • (3)  Volumetric flow on outlet from collector, on first of
          each month;
     (4)  Pressure drop across each section of the collector after
          cleaning, on first of each month;
     (5)  Static pressure from fan through collector, gas cooling
          system and ductwork to collecting hood, on first of each
          month;
     (6)  Fan speed, on first of each month;
     (7)  Capture velocity on hood faces, on first of each month;
     (8)  Excess air data for gas exhaust system, and results of
          any Monoxor (CO detector) and Fyrite (C02 detector)
          analyzer surveys;
     (9)  Inspections, maintenance and repairs, by month;
    (10)  Malfunctions, by month.

The purpose of having the above information kept on the air pollution
control system is to ensure that air contaminants generated by the
furnaces will be collected by the baghouse or other collection
system the same as when the performance tests were conducted.  The
quantity of dust collected should remain proportional to the produc-
tion of furnaces hooked to the system.  The volumetric flow measure-
ment on the inlet and outlet will indicate leaks in the baghouse.
Pressure drop after cleaning will indicate if the bags are becoming
badly worn or blinded by dust.  Static pressure measurements will
indicate leaks in ductwork or ductwork filled with dust.  Capture
velocity at the -hoods will indicate if the capture efficiency is
changing.

     For the emissions, the owners or operator should not record
visual opacity unless the observer has been certified by EPA or a
state agency to make such opacity observations.  The plant operator
should record and report complaints and should indicate the probable
cause of the problem.

4.3  REPORTING REQUIREMENTS

     The EPA reporting requirements suggest that the owner
or operator of a source subject to continuous monitoring and
recording requirements should summarize such measurements monthly
and should submit such summaries to the state on a quarterly or
                               4-3

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more frequent basis.  As will be described later, the Federal
requirement for new facilities to report startup, malfunction or
shutdown is on a quarterly basis.  Therefore, it seems logical and
consistent to suggest the above records also be summarized on a
monthly basis and submitted to the state quarterly.

     Also, the NSPS regulation requires owners and operators to
maintain a file of all recorded information required by the re-
gulations for at least two years after the dates of such informa-
tion.

     Suggestions for formats and contents of recordkeeping tables
are indicated in Tables 6.1, 6.2, and 6.3 at the end of section
6.0.

     For further detail on monitoring, record keeping, and reporting
requirements, please refer to:

      (1)  Federal Register, October 6, 1975, page 46240 (8);
      (2)  Federal Register, October 6, 1975, page 46250 (8); and
      (3)  Guideline for the Selection and Operation of A Continuous
          Monitoring System for Continuous Emissions (11).
                               4-4

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            5.0  STARTUP, SHUTDOWN, AND MALFUNCTIONS

     The Code of Federal Regulations, Title 40, Part 60, addresses
the problem of startup, shutdown, and malfunctions.  Section 60.11
(d) states, in part, "at all times, including periods of startup,
shutdown, and malfunction, owners and operators shall, to the ex-
tent practicable, maintain and operate any affected facility
including associated air pollution control equipment in a manner
consistent with good air pollution control practice for minimizing
emissions."  As another part, Section 60.7 states, "A written report
of excess emissions as defined in applicable subparts shall be sub-
mitted by each owner or operator for each calendar quarter.  The
report shall include the magnitude of excess emissions as measured
by the required monitoring equipment reduced to the units of the
applicable standard, the date, and time of commencement and comple-
tion of each period of excess emissions.  Periods of excess emissions
due to startup, shutdown, and malfunction shall be specifically
identified.  The nature and cause of any malfunction (if known),
the corrective action taken, or preventive measures adopted shall
be reported.  Each quarterly report is due by the 30th day fol-
lowing the end of the calendar quarter.  Reports are not required
for any 'quarter unless there have been periods of excess emissions.
(Suggestions for format and content of recordkeeping on startup
and shutdown operations and malfunctions are indicated in Table
6.3 at the end of section 6.0.)

     The above provisions presently apply only to three furnace
types at new secondary lead smelters.  However, the state agencies
may well adopt similar requirements and, in fact, some states
already require existing plant upset conditions to be reported.
The principal difference, however, may be in EPA's definition of
malfunction which exclude several common causes of excessive
emissions.  The wording is as follows:  "Malfunction means- any
sudden and unavoidable failure of air pollution control equipment
or process equipment or of a process to operate in a normal or
usual manner.  Failures that are caused, entirely or in part by poor
maintenance, careless operation, or any other preventable upset
condition or preventable equipment breakdown shall not be con-
sidered malfunctions."
                               5-1

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5.1  STARTUP

     Startup operations are common practice, occurring daily, in
the secondary lead industry.   Since the pot furnaces are batch
operations, startup of these furnaces poses no particular problem
from the emission point of view.   When a furnace is being heated
up, only fuel is being burned.   A blast furnace which is a contin-
uous operation starts by heating up the furnace and it typically
takes about four hours to reach normal operating conditions.  The
reverberatory furnace is  a  continuous  operation  also but  it may
be somewhat cyclic depending on the rate of scrap addition and the
rate of lead draw-off.

5.2  SHUTDOWN

     Shutdown of the furnaces can be more of a problem than startup,
however, since several tons of molten metal cannot be allowed to
solidify in any of the furnaces.  In the event of a malfunction or
failure in the control equipment (baghouse or scrubber), the furnace
must be vented to the atmosphere for the remainder of the heat cycle
or until the furnace can be prepared or stoked for holding.  It is
not desirable to allow the firebrick to become completely cold since
damage to the firebrick may occur with frequent or extreme temperature
changes.

5.3  MALFUNCTIONS

     Concentrating then on malfunctions that could cause excessive
emissions,  two types of malfunctions may be considered.   The first
category is made up of those conditions which would create excessive
emissions into the workspace with subsequent discharge through the
roof monitors to the atmosphere.   Such a condition would very
likely be manifested by insufficient draft on the collection hoods
which could be due to:

     (1)  slippage on fan belts
     (2)  high pressure drop in the baghouse which in turn may be
          due to:

          0 improper compressed air supply
          ° improper timer operation
          0 improper solenoid valve operation
          0 leaky airlock or dust discharge valve
          0 moisture blinded bags
          0 dust in clean air plenum
          0 static electricity
          0 incorrectly installed blow tubes
          0 collector overloaded from too much air

                                5-2

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     (3)  fan rotating in the wrong direction
     (4)  leaking ductwork, access doors, explosion doors or dis-
          charge valve on air lock
     (5)  clogged ductwork or faulty damper
     (6)  duct size improper
     (7)  high temperatures and increased gas volumes of the exhaust
          gases which would cause the atmospheric damper to be
          opened excessively.  This condition in turn could be
          caused by:

          o addition of large amounts of a low boiling point alloy
            to the pot furnace charge;
          ° addition to* the blast or reverberatory furnace charge
            of scrap with large amounts of oil or other combustibles;
          0 blowing the molten bath of the blast furnace at too
            high a rate with compressed air;
          0 firing at excessive rates;
          o hardened slag cover in the reverberatory furnace;
          e slips in the blast furnace following bridging.

     The second category of malfunctions would result from control
equipment failures.  The more important examples would include:

     (1)  short bag life with frequent failures (ruptures) which in
          turn could be due to

          o high operating temperatures
          0 low dew point gas conditions with condensation of 862
            and 863
          0 acidic or basic dust that attacks fabric
          0 a high filtering velocity or air to cloth ratio with
            excessive bag shaking
          0 dust in clean air plenum from previous bag failures or
            from bridging of dust in the hopper cleanout
     (2)  motor failure
     (3)  fan unbalanced due to particulate buildup
     (4)  pump failure
     (5)  clogged or worn nozzles
     (6)  poor water distribution due to buildup of mud

     For further information on baghouse design, operation, and
maintenance, please refer to the following reference materials:

     (1)  Appendices to Handbook of Fabric Filter Technology (2)
     (2)  Proceedings-The User and Fabric Filtration Equipment
          Specialty Conference (16)
     (3)  Air Pollution Engineering Manual (19)
     (4)  Systems Study of Scrubbers (4)

                                5-3

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                       6.0  INSPECTION PROCEDURES

6.1  CONDUCT OF INSPECTION

     Before an air pollution inspector visits a facility, it is
necessary to establish the objectives of the inspection.  In this
regard, he may wish to check with his administrative, legal, or
engineering advisors prior to the inspection since some or all of
the following objectives may be important for a given plant inspec-
tion:

     (1)  Determine the scope of the facility's operation.
     (2)  Determine the applicability of standards.
     (3)  Inspect records and/or monitoring equipment.
     (4)  Evaluate visible emissions (test Method 9).
     (5)  Determine if a stack test is required.
     (6)  Conduct or observe stack tests or other field tests.
     (7)  Evaluate maintenance and operation of equipment.
     (8)  Establish compliance or non-compliance with compliance
          schedules.
     (9)  Investigate feasibility of various control methods.
    (10)  Investigate compliance with emergency episode plans.

     Section 114(a)(2) of the Clean Air Act enables the Administra-
tor or his authorized representative to enter a source so that EPA
can do its own monitoring, sampling, inspecting, or copying of
records.  Such authority may be delegated to a state and be exer-
cised by a state official.

     In preparing for the inspection, the control official should:

     (1)  Review the literature on the subject industry's process
          descriptions, inspection points, and control equipment.
     (2)  Review the NEDS file or other plant file for details of
          processes and control equipment in use including plot
          plan.
     (3)  Review applicable standards (Federal, state and local).
     (4)  Review enforcement history on the plant.

          0 administrative and court actions
          0 compliance schedules
          0 monitoring and recordkeeping requirements

                                6-1

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          " previous inspections
          o section 115 abatement actions
          o waivers, notifications, quarterly reports, registration
            (NSPS and NESHAPS)

     (5)  Finalize objectives
     (6)  If appropriate provide advance notice
     (7)  Obtain credentials and business cards (EPA has a procedure
          regarding the issuance and  control of credentials)
     (8)  If desired, obtain for handout a supply of applicable
          statutes and regulatory authority as well as EPA or state
          literature explaining the enforcement program
     (9)  Obtain or develop a supply of inspection checklists.
    (10)  Obtain personal safety equipment.  (A source owner or
          operator has no responsibility to supply EPA inspectors
          with safety equipment.)

          ° hard hat
          o safety glasses or goggles
          o steel-toed shoes
          o respirator
          o gloves
          o coveralls

    (11)  Obtain necessary inspection equipment

          o tape measure
          o flashlight
          o thermometer and gauze
          o manometer (flex-tube)
          o inclined monometer
          o RPM indicator
          o velometer
          o camera
          o Fyrite combustion analyzer - 02, CO, CO-j
          o smoke spot analyzer

6.2  INSPECTION CHECKLIST

     After preparing for the inspection by reading appropriate in-
formation and obtaining necessary equipment, the control official
is ready for the actual site visit.  Before entering the plant
property it is desirable to observe the stacks and roof monitors
for evidence of visible emissions.  If a plume is consistently
visible, opacity observations should be recorded for possible
violation.  Time should be allowed for such observations prior to
the appointment.
                               6-2

-------
     At the plant entrance, present credentials and request to see
the most senior or responsible official of the company.  Generally
this person will be the plant manager.  The control officials should
not sign the waiver forms or "visitor releases".  The inspector has
specific legal authority (Federal or state) for right of entry and sign-
ing such forms may adversely affect his Federal or state insurance or
survivors benefits.  If a source persists in its refusal, the matter
should be carried to court.  If a source simply refuses right of
entry, a request must be made through a U.S. attorney for a search
warrant.

     Upon meeting the plant manager, the inspector may be questioned
on the following items and should be prepared to discuss:

     (1)  The purpose of the inspection (NSPS, SIP, NESHAPS).
     (2)  The authority for the inspection (113, 114, State law, etc.).
     (3)  The agency's organization and responsibilities.
     (4)  Recent history of legislative and enforcement activity
          affecting the subject industry and specific plant.
     (5)  The scope, timing, and organization of the inspection.
     (6)  Information and records to be examined (self incrimination-
          see Appendix).
     (7)  The treatment of confidential data (trade secrets-see
          Appendix).
     (8)  Possible measurements to be made.
     (9)  Possible followup activity.

          o future inspections
          o section 113 or 114 letter
          ° stack tests
          o notice of violation

     After the preliminaries are completed, the control official
should request the name, title and address of the most appropriate
company officer for official contact on future inspections and
correspondence.

     Next, he should request a brief summary of the pl'ant's pro-
duction facilities and air pollution control equipment.  This in-
formation will substantiate the NEDS or other emission source data
that the agency has on file or will provide the basis for updating
or correcting such files.

     The company official should be asked to indicate which
processes, unit operations, furnaces, and control equipment
are (at the time of the discussion) operating at or near normal
operating conditions.  Likewise, the company official should be


                                6-3

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asked to indicate which facilities are not operating at or near
normal operating conditions and to indicate the reasons and  the
timing (date and hour) for shutdown or malfunctioning equipment.
The schedule for returning shutdown equipment to operation should
be indicated.  The malfunctioning equipment should be shutdown if
such malfunctioning adversely affects emission rates to the  atmos-
phere and the schedule for shutdown and correction should be
indicated.

     Next,  the  inspector  should request  a quick  rather  cursory tour
of the plant  facilities and  the company  official should point out all
of the sources  and  control equipment  indicated earlier.   Access  to the
roof and  to the stacks should be  requested and visual observations
should be made  of hood capture efficiencies,  stack effluents, sampling
ports and platforms,  ductwork conditions,  and general housekeeping in
and around  the  plant.  Evidence of dust  or fume  accumulation on  the
plant roof  or at the  stack exit should be noted.   During  this tour
the inspector should  note whether the process, furnace,  etc. is  run-
ning and  whether its  operation warrants  more  detailed analysis.

     After  getting acquainted with the plant and its facilities,
the inspector should request that the company official provide
information from his records that will, allow the inspector to
complete  the process, control equipment and malfunction record
forms which are  appended.  Records for the complete calendar month
prior to  the visit will generally suffice  to give a baseline of
the plant's operations.   With such information, comparisons  can be
iiade with future operations, with past performance test and  design
operating conditions, and with operations  at the time of  the cur-
•rent inspection.  In the  event the company identified certain data
as confidential, a company official must make a request for  such
confidentiality  in writing to EPA.

     Next,  the  control official should request the company official's
assistance  in verifying the real-time operating conditions and
actual production rate of each process, furnace, etc. in  the plant.
This plant  inspection may take several hours and the records or
data which  the official cites—weights, fuel  flow measurements,
temperatures, etc.—should be seen and verified by the air pollu-
tion inspector.  After verifying  that certain equipment is operating,
the inspector should be prepared  to take  his own data on  fan speeds,
gas velocity and duct flow rates, static  pressure, pressure  drops,
hood capture velocities,  and temperatures  (both dry bulb  and wet
bulb).  On  equipment that is not  operating, especially baghouses
or other control equipment, the opportunity should be taken  to
open access doors to check ductwork,  fabric bags,  clean air  plenum,
                                6-4

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valves and dampers, fan drive belts, collection hoppers, etc.  The
inspector should take note of those conditions cited in Chapter 5.0
which can lead to malfunctions and check the equipment accordingly.

6.3  INSPECTION FOLLOWUP PROCEDURES

     Upon completion of the inspection, the inspector should sign
and date all notes and inspection forms making certain that all
blanks are completed.  He should advise the company official that
he will review his findings with his legal and technical advisors
prior to making recommendations for any necessary action.  The
inspector should not advise the company official of specific viola-
tions.  The conclusion of all inspections will be:  (1) affected
facilities are in violation of standards; (2) affected facilities
are in compliance with standards; or (3) affected facilities are
not being operated or maintained precisely in accordance with the
performance tests but violations are not clearly evident.  Where
operating conditions have a high probability of producing greater
emissions than those recorded during the performance tests, a new
performance test may be required of the source by the Administrator.
Also, poor maintenance and housekeeping is a violation of NSPS
regulation 60.11(d).

     In the first case for new secondary lead smelters subject to
the NSPS, the only violations which could be cited at the present
time under Section 113 are opacity violations or failure to record
or report malfunctions.  The mass loading limitation on blast
or reverberatory furnaces could not be determined without isokinetic
particulate tests.  In the case of existing facilities, state
opacity limitations or reporting requirements for upset conditions
would seem to be the only possible violations.  Obviously, the
agency whose regulation is being violated should be advised.

     In the second case, the plant will be found to be operating
and maintaining its facilities in a manner consistent with good
air pollution control practice for minimizing emissions.  Also the
affected facilities will be found to be operating essentially at
the production rates and under the conditions recorded at the
time of the performance tests.

     In the third case, which will be the most common and the most
difficult, inspections will be concluded with a need for recommenda-
tions to improve specific operating or maintenance procedures so
as to be consistent with the performance test conditions and with
good air pollution control practice for minimizing emissions.  If
such recommendations are not followed and the inspector feels that
emissions may be excessive, a performance test would be required
to substantiate or refute compliance with the regulations.  On
the matter of what conditions constitute a significant deviation
                                6-5

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so as to require a new performance test, the inspector should not
make a decision in the field.  Instead he should record field data
from which technical and legal advisors can draw such a conclusion.

     Regardless of the findings, the designated company officer
should be notified in writing of the inspection results and any
required action on the company's part should be spelled out in
detail with a time schedule to bring the facilities back into com-
pliance.  Section 113 of the Act should be cited.  At the conclu-
sion of the designated time period for compliance, a followup in-
spection should be made to verify conformance with the recommenda-
tions and applicable -standards.

     For further information on inspection procedures refer to:

     (1)  Field Surveillance and Enforcement Guide for Primary
          Metallurgical Industries (10)
     (2)  Workshop on Stationary Source Inspections (21)
     (3)  Air Pollution Control Field Operations Manual (20)
     (4)  S12.-General Policy on the Use of Section 114 Authority
          for Enforcement Purposes (Appendix)
                                6-6

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                          Table 6.1   SECONDARY  LEAD SMELTERS  INSPECTORS  WORKSHEET
                                           Part I - Process Data
          Company
                                           Report for Period
                            Year
       Street Address
City
State
 Official Providing Information
     Title  of Official
                                           Furnace - Company Designation
Furnace Permit Number or NEDS  Number
                                           Furnace Type
                                           Furnace Rated Capacity (Charge Rate)
PERK
legin day
hour














D OF RECO
end day
hour














ID
total
hours
•













PRODUCT SPECIFICATIONS - PERCENT
Pb As Sb Cu Ni Hi Ag Fe














PRODUCT
tons
hour














POUR
TEMP.














RAW MATERIALS
fuel oxygen air flux
Iflfibtu ft3 ft3 lb.














                                                          date
                                                           Inspector

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                            Table  6.2  SECONDARY LEAD  SMELTERS  INSPECTORS WORKSHEET

                                           Part II - Control Equipment  Data
I
oo
                 Company
                                                                        Report for  Period
                            Year
            Street Address
      City
                           State
        Official Providing Information

          Title of Official

     Process equipment ducted to this control equipment
                                                                        Control  Equipment Co. Designation
State Permit  Number or NEDS Number
                                                                        Control  Equipment Type


Quantity of dust collected
Gas flow rate
Gas flow rate
Temperature. @
Temperature @
@ collector inlet
@ collector outlet
collector inlet
collector outlet

tons
acfm
acfm
op
OF

Static pressure in collection system
stack
before fan
collector outlet
collector inlet
before radiant coolers
before water sprays
duct after hood
"H20
"H20
"H20
"H20
"H20
"H20
"H20
                                             rpm
Fan speed                       	

Capture velocity  of hoods
       over furnace               *"
       charging doors            	
       pouring spout             	

Pressure drop across each section of clean collector  1_

Remarks concerning inspections, maintenance and  repairs
                                            _fpm
                                            _fpm
                                             fpm
                                                                      date
                                                                                       Inspector

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                           Table 6.3   SECONDARY LEAD  SMELTERS INSPECTORS WORKSHEET
                               Part III - Startup, Shutdown,  and Malfunction
             Company
         Street Address
City
                            State
   Official Providing Information

      Title of Official
 Excess emissions occurred
      Began _
              date
                                      time
                 date                 time
 Detailed explanation of reasons for excess emissions
                                                                       Record for Period
                                                                                                      Year
Were excess emissions due to startup,  shutdown, or mal-
function	
Describe the magnitude of the excess emissions 	
,Corrective action taken to halt excess emissions
 Preventative measures adopted  to prevent recurrence
 Further comments
                                                           date
                                                                                           Inspector

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                                               Table 6.4  SECONDARY LEAD SMELTERS INSPECTORS WORKSHEET


                                                           Part IV - General Observations
                                 Company
                             Street Address
                      City                  State
                        Official Providing Information
                             Title of Official
                    Process
 I                          Charging procedure - weights,  frequency	
M

                           Charge quality - oil, dirt,  percent lead_


                           Capture efficiency of hoods	
                    Control equipment


                           Cleaning cycle
                           Structural integrity


                           Clean air plenum
                           Testing facilities
                    Emissions

                           Visible emissions from stack Method 9
                           Visible emissions around hoods Method 9
                                                                                  Date                        Inspector

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                        7.0  PERFORMANCE TEST

     The Code of Federal Regulations, Title 40, Part 60 provide in
Section 60.8 for performance tests of new secondary lead smelters.
The test calls for three separate runs using standard EPA test
methods and procedures. The Administrator, however, can modify the
testing requirement; he can even waive it.  If tests are to be con-
ducted, the owner or operator must give EPA 30 days notice.  EPA
must then specify the operating conditions of the tested furnace.
At present, only new reverberatory and blast furnaces have a mass
emission rate which requires performance testing; pot furnaces have
only an opacity standard.  At the time of the test, the inspector
should be present to observe process and control device operation
so that subsequent inspections can be correlated with the per-
formance test "baseline" operating conditions.  Also at the time
of the tests, the inspector should check certain of the source
testing procedures to ensure that the tests are conducted properly.
Each of these three requirements is considered separately in the
ensuing discussion.

7.1  PROCESS OPERATING CONDITIONS

     The purpose of :the performance test is to determine whether the
emission standards will be met when the furnace is operating at nor-
mally encountered conditions that create the maximum emission rate.
The operating conditions that should be specified for the tests are
as follows:

     (1)  The production rate should be the maximum rated capacity
          of the furnace;
     (2)  The period of the heat should be the minimum possible to
          achieve the specification of the melt;
     (3)  The specification of the lead ingots or product (alloy)
          to be produced should be typical of the product produced
          by the affected facility to be tested;
     (4)  If oxygen is used at all, the consumption rate should be
          the maximum rate anticipated;
     (5)  If compressed air is used at all, the consumption rate
          should be the maximum rate anticipated;
     (6)  The fuel consumption rate should be the maximum rate
          anticipated;


                                7-1

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     (7)  The flux addition rate should provide a slag and flux -cover
          depth typical of the operation to be tested;
     (8)  The pouring temperature should be the maximum anticipated
          for the metal alloy being produced.

7.2  PROCESS OBSERVATIONS

     For the pot furnaces the most important process observation is
the amount, time period, and type of alloy of flux added to the
molten lead.  Since it is a batch-type operation, the only signifi-
cant emissions will occur during this period.  During the alloy
addition observation should be made of the capture efficiency of
the hood over the top of the pot furnace.

     For the reverberatory furnace, the first major observation is
whether the tested conditions are for batch-type or continuous
operation of the furnace.  If it is to be operated on a continuous
basis, then observations should ensure that charging, heating,
fluxing, and tapping are, in fact, fairly uniform and that the
furnace has reached a normal operating level near design capacity.
These same observations should be noted on a blast furnace since
it also is a continuous operation.

     If the reverberatory furnace is to be operated on a batch-type
basis, it will require several hours to produce a heat of lead.  In
this case, care needs to be exercised to source test during periods
which produce maximum emission rates.  Also different phases of the
heat should be covered by the testing to ensure compliance over the
entire heat.

     Some of the observations that should be noted during the testing
and in between the tests are described below for blast furnaces
and for reverberatory furnaces (both batch and continuous) since
the method of operating can affect emission rates.

     The method of charging is important.  If essentially all of
the charge is added at the beginning of the heat, emissions will
be lower than if material is subsequently or intermittently charged
to a hot operating furnace.  If subsequent charging is practiced,
emissions will be reduced if the fuel rate is decreased or stopped
while charging.

     The amount of the total charge will have some effect on emissions.
However, the production rate, quality and method of charge, charging
rate, fuel rate, oxygen rate, and slag cover are probably more closely
related to emissions than total charge.
                                7-2

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     The duration of the heat is important in that the quantity
of impurities to be removed from the old batteries and other
scrap remains constant regardless of the duration of the heat.
There is effective dilution and lowering of the grain loading with
longer than normal refining times.

     The approximate lead content of the scrap which is charged
should be noted and the lead content of the ingots should be
noted.  If the charge is high in impurities and the final product
is very low in impurities, then more refining will be necessary to
remove impurities and most of this material will go to the baghouse.

     The oxygen, compressed air, and fuel consumption rates all
relate to the speed with which the impurities in the molten metal
are removed.  If the rates are low and the time longer, emission
rates will be less than if the rates are high and the time shorter.
If the source test is conducted for only one hour or so, care
should be exercised to include representative smelting conditions.

     The thickness of the slag cover may be important since the
slag cover reduces the loss of lead due to oxidation.  A thick
layer may harden and cause excessive lead oxide emissions.  Until
the slag layer hardens, however, a thicker layer than normal
during a performance test will reduce mass emissions and increase
the quantity of heat needed, thus giving a lower grain loading
during the performance test.

     If the pouring temperature is higher than necessary, the fume
emission will be increased.

     If a baghouse is the selected control equipment, it may be
designed to meet the standard with one section off line for cleaning.
If this is the case, the testing may be desirable with one section
dampened off.

     Also, since it is common practice to vent two or more furnaces
to the same baghouse, it may be necessary to operate other
equipment simultaneously or to bypass a portion of the baghouse
and a portion of the production equipment to try to get air to
cloth ratio and inlet grain loading that will be experienced under
normal operating conditions of the blast or reverberatory furnaces.
Whatever final procedure is determined for operating the control
equipment, the control official should note all conditions and should
complete the Inspection Checklist Forms relating to the control
equipment.
                                  7-3

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7.3  EMISSION TEST OBSERVATIONS

     Emission tests and opacity determinations should be conducted
by qualified emission testing personnel.  The inspector is respon-
sible for ensuring that all pertinent data are collected, that the
field procedures and equipment meets CFR, and that the smelter is
run at representative performance during all sampling runs.  A
qualified technician or engineer reads visible emissions during the
three particulate runs.  The approved visible emission data form
appears in Appendix B.

     The inspector's degree of surveillance of the stack sampling
team depends on the confidence of the inspector and qualifications
of the test personnel.  Even if the inspector has complete trust
in the sampling crew, the following tasks should always be performed:

     (1)  Record duct dimensions (both inside and outside) and
          locations of sample ports.
     (2)  Check the number of ports at the sampling site and
          examine the ducting for the nearest upstream and down-
          stream obstructions.  Ask the crew leader how many total
          points will be traversed and check with Figure 1.1 in
          40 CFR 60 to determine whether the stream will be properly
          sampled.
     (3)  Note whether the crew runs a preliminary traverse, and
          if so, inquire what nozzle diameter is selected.
          (Isokinetic sampling is a function of nozzle size.)
     (4)  Check to ensure that the moisture content of the gas
          stream is determined by Method 4 or an equivalent method
          such as drying tubes or volumetric condensers; assumption
          of the moisture content is not allowed.  Note, however, that
          EPA has proposed a method for the estimation of the moisture
          content for the purpose of determining isokinetic sampling
          rate settings.  The proposed method appears at 41 FR 23060
          (June 8, 1976).
     (5)  Observe the leak test of the sampling train.  The allow-
          able leak rate is given in Method 5.  Leakage results
          in lower concentrations than are actually present.  Be
          next to the dry gas meter during the leak check, note
          whether the meter hand is moving.  (The more the hand
          is moving, the greater the leakage.)  Leak checks must
          be made if the train is disassembled during the run to
          change a filter or to replace any component.
     (6)  Record dry gas meter reading before and after test.
     (7)  Record average velocity head and temperatures in duct
          during test.
                               7-4

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     (8)  If impingers are used during test, observe whether
          they are bubbling.  If they are not, the sampling train
          is either plugged or disconnected from the pump.
     (9)  Check the cleaning procedure for the front half of the
          train.  Careless removal of filters or cleaning of
          probes will result in lower calculated emissions.  Look
          for broken glass from probes or connectors.  Test is
          void if glass probe is broken during test.  If glass
          connectors are broken in transport from sampling site
          to clean-up area, test is still valid.  Be sure identi-
          fication labels are properly attached to collection
          containers.  The probe should be brushed and rinsed with
          acetone thoroughly to remove all particulates.  The probe
          should be visually inspected after cleaning to ascertain
          that all particulates have been removed.
    (10)  Observe gas analysis procedure for determining C02-
          Technician should take at least three samples before
          averaging readings.  Variations greater than 0.5 percent
          (grab sample) or 0.2 percent (integrated sample) indicate
          gas mixture was not thoroughly bubbled in reagents.  Ask
          technician or crew leader when new reagents were added
          to apparatus.
    (11)  Check percent isokinetic.
    (12)  Inquire about the calibration history of the flow volume
          recorder.  The flow measuring device is required to
          maintain an accurate of ±5 percent over its operating
          range.

7.4  PERFORMANCE TEST DATA

     The inspector must observe smelter operation and emission
tests simultaneously to ensure that valid data are used in deter-
mining plant performance.  The performance test checklist shown in
Table 7.1 is based upon the observations described in Sections
7.1, 7.2, and 7.3.  Suggested contents for stack test reports are
given in Appendix E.

     The reasons for having the inspector observe the test and
complete the inspection sheet are twofold.  First, smelter and
control device parameters will serve as guidelines for future
NSPS recordkeeping requirements; and second, the inspector's
observation of a few major parameters ensures that the tests were
properly conducted.

     The emission testing firm is required to submit test reports
to the facility and the control agency.  Results from the testing
firm must be carefully checked and compared with data from the in-
spector's form.
                                7-5

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                             Table 7.1

       NSPS INSPECTION CHECKLIST FOR SECONDARY LEAD SMELTERS

                        DURING PERFORMANCE TEST

Facility Name 	
Facility Address
Name of Plant Contact

Source Code Number
Unit Identification (To be tested)
Design Input Capacity	tons/day

Initial Start-up Date 	

Test Date
A. FACILITY DATA

   Type             DFurnace             No. of Furnaces
                    QOther               Specify	
   Charging Method  QBatch    n Continuous

   Control Devices  QFabric Collector    Specify Type 	
                    DScrubber            Specify Type 	
                    DOther
   Operating Schedule	hrs/day 	days/wk 	wks/yr

B. OPERATING PARAMETERS
   Data to Obtain During Performance Test3
                                            Clock Time
           Parameter
   Charge Capacity
   Charge Rate
   Charge Lead Content
   Product Lead Content
   Period of Heat
   Oxygen Rate
   Compressed Air Rate
   Fuel Rate
   Pouring Temperature
    Data should be recorded every 20 minutes

                                7-6

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Table 7.1 (continued).  NSPS INSPECTION CHECKLIST FOR SECONDARY

                LEAD SMELTERS DURING PERFORMANCE TEST
    PRETEST DATA (OBTAIN FROM TEST TEAM FIELD LEADER)

    Test Company	

    Field Leader
    Duct Dimensions
      in.  x
in.;  Area
    Nearest Upstream Obstruction
    Nearest Downstream Obstruction

    No. of Sampling Ports 	
                             _ft

                              ft
    No. of Sampling Points
    No of Sampling Points Required From 40 CFR 60

    PARTICULATE PERFORMANCE TEST
    Test No.
Start Time
    Preliminary Traverse Run (Method 1)
    Chosen Nozzle Diameter 	in.

    Train Leak Check

    Opacity Readings Taken

    Moisture Determination (Method 4)
    Percent Moisture
 Finish Time 	
      D Yes    D No
ft
        Volume Sampled
Volume ml ft
.b readings)
lalyzer 00 %
CO. %
3
iding Before Test ft at
iding After Test ft at
(time)
(time)
>.d ft3
                               7-7

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  Table 7.1 (continued).  NSPS INSPECTION CHECKLIST FOR SECONDARY
                 LEAD SMELTERS DURING PERFORMANCE TEST

D.  PARTICULATE PERFORMANCE TEST (continued)
    Test Duration                  minutes
    Average Meter Orifice Pressure Drop
    Average Duct Tejnperature 	°F
    Velocity Head at Sampling Point  	
    Meter AH@*                       	
    Repetition Start Time            	
    Repetition Finish Time           	
E.  CLEAN-UP PROCEDURE
    Filter Condition
    Probe Status
    Glass Connectors
    Clean-up Sample Spillage
                                                inches
                                               inches HO
                              QDry                  QWet
                              DUnbroken             QBroken
                              D Unbroken             Q Broken
                              QNone    D Slight     CJMajor
Sample Bottle Identification  QYes                  QNo
Acetone Blank Taken           D Yes                  Q No
                              7-8

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                          8.0  REFERENCES

 (1)   Allen,  Glen L.  "Control of Metallurgical and Mineral Dusts and
      Fumes in Los Angeles County,  California," U.S.  Department of
      the Interior, Washington, D.C.  (April 1952)

 (2)   Appendices to Handbook of Fabric Filter Technology, Vol II.
      GCA Corporation for NAPCA Division of Process Control Engi-
      neering.  Reserach Triangle Park, N.C. (December 1970)

 (3)   Background Information for Proposed New Source Performance
      Standards; Vol 1, Main Text.   Environmental Protection Agency,
      Research Triangle. Park, N.C.  (June 1973)

 (4)   Calvert, S. Systems Study of  Scrubbers, Environmental Protec-
      tion Agency, Research Triangle  Park,  N.C.  (1972)

 (5)   Code of Federal Regulations.  Title 40, Part 51 Revised as of
      July 1, 1976, General Services  Administration,  Washington, D.C.
      (1976)

 (6)   "Control Techniques for Particulate Air Pollutants,"  U.S.
      Department of Health, Education, and Welfare, Washington,  D.C.
      (January 1969)

 (7)   Emission Testing Compliance Manual EPA 68-02-0237.   Environ-
      mental Protection Agency, Washington, D.C.  (1974)

 (8)   Federal Register, Vol. 40,  No..194.   General Services Administra-
      tion, Washington, D.C. (October 6,  1975)

 (9)   Federal Register, Vol. 40,  No.  242.   General Services Admin-
      istration, Washington, D.C.  (December 16,  1975)

(10)   Field Surveillance and Enforcement Guide for Primary Metal-
      lurgical Industries.  Engineering-Science,  Inc., Washington,
      D.C. (December 1973)

(11)   Guideline for the Selection and Operation of a  Continuous
      Monitoring System for Continuous Emissions.   Division of
      Stationary Source Enforcement,  Environmental Protection Agency,
      Washington, D.C. (1974)

                                8-1

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(12)   Hardison,  L.C.,  "Study of Technical and Cost Information for Gas
      Cleaning Equipment in the Lime and Secondary Non-Ferrous Metal-
      lurgical Industries," Industrial Gas Cleaning Institute, N.Y.
      (December  1970)

(13)   Hayward, C.R.,  "An Outline of Metallurgical Practice," D. Van
      Nostrand Company,  N.Y. (1952)

(14)   High,  M.D.,  et  al. Source Tests at a Secondary Lead Smelter,
      Engineering-Science,  Inc., Washington,  D.C. (1969)

(15)   McDermid,  J.,  "Secondary Base Metals Processing Technology,"
      Information  Circular, U.S. Department of Interior, Washington,
      D.C.  (1961)

(16)   Proceedings:   The  User and Fabric Filtration Equipment
      Specialty Conference.  Edited by the Air Pollution Control
      Association.   Pittsburgh, Pa.  (October 1973)

(17)   Rausch,  D.O.  and Mariacher, B.C., "AIME World Symposium on
      Mining and Metallurgy of Lead and Zinc," The American Institute
      Of Mining, Metallurgical, and Petroleum Engineers, Inc. (1970)

(18)   Stern, A.C.,  "Air  Pollution, Volume III, Sources of Air Pol-
      lution and Their Control," Academic Press,  N.Y. (1968)

(19)   "Air  Pollution  Engineering Manual," U.S. Department of Health,
      Education, and  Welfare,  Cincinnati, Ohio (1967)

(20)   Weisburd,  Melvin I.,  "Air Pollution Control Field Operations
      Manual," U.S.  Department of Health, Education, and Welfare,
      Washington,  D.C. (December 1962)

(21)   Workshop on  Stationary Source Enforcement,  Engineering-Science,
      Inc.,  Washington,  D.C. (December 1974)
                                 8-2

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         APPENDIX A

STANDARDS OF PERFORMANCE FOR
   SECONDARY LEAD SMELTERS
              A-l

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              Chapter 1 - Environmental Protection Agency

                      SUBCHAPTER C - AIR PROGRAMS

                 PART 60 - STANDARDS OF PERFORMANCE
                     FOR NEW STATIONARY SOURCES

                Subpart L - Standards of Performance for
                        Secondary Lead Smelters


§60.120  Applicability and designation of affected facility.

     The provisions of this subpart are applicable to the following
affected facilities in secondary lead smelters:  Pot furnaces of more
than 250 kg (550 Ib) charging capacity, blast (cupola) furnaces, and
reverberatory furnaces.

§60.121  Definitions.

     As used in this subpart, all terms not defined herein shall have
the meaning given them in the Act and in Subpart A of this part.

     (a)  "Reverberatory furnace" includes the following types of reverbera-
tory furnaces:  stationary, rotating, rocking, and tilting.
     (b)  "Secondary lead smelter" means any facility producing lead
from a lead-bearing scrap material by smelting to the metallic form.
     (c)  "Lead" means elemental lead or alloys in which the predominant
component is lead.

§60.122  Standard for particulate matter.

     (a)  On and after the date on which the performance test required
to be conducted by §60.8 is completed, no owner or operator subject
to the provisions of this subpart shall discharge or cause the discharge
into the atmosphere from a blast (cupola) or reverberatory furnace
any gases which:
     (1) Contain particulate matter in excess of 50 mg/dscm (0.022 gr/dscf).
     (2) Exhibit 20 percent opacity or greater.

     (b)  On and after the date on which the performance test required to
be conducted by §60.8 is completed, no owner or operator subject to the
provisions of this subpart shall discharge or cause the discharge into


                                   A-2

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the atmosphere from any pot furnace any gases which exhibit 10 percent opacity
or greater.

§60.123  Test methods and procedures.

     (a)  The reference methods appended to this part, except as provided
for in §60.8 (b), shall be used to determine compliance with the standards
prescribed in §60.122 as follows:

     (1) Method 5 for the concentration of particulate matter and the
associated moisture content,
     (2) Method 1 for sample and velocity traverses,
     (3) Method 2 for velocity and volumetric flow rate, and
     (4) Method 3 for gas analysis.

     (b)  For method 5, the sampling time for each run shall be at least
60 minutes and the sampling rate shall be at least 0.9 dscm/hr (0.53 dscf/
min) except that shorter sampling times, when necessitated by process
variables or other factors, may be approved by the Administrator.  Particu-
late sampling shall be conducted during representative periods of furnace
operation, including charging and tapping.
                                  A-3

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                 APPENDIX B

  METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FOR STATIONARY SOURCES
                   B-l

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                     METHOD  9  -  VISUAL  DETERMINATION OF  THE
                 OPACITY  OF EMISSIONS  FROM STATIONARY SOURCES
METHOD  9—VISUAL  DSTESlCQTATrOJr  OF  TH3
  OPACITY OP SIOSSIONS  FEOM  STATIONARY
  SOTCCES •
  Many stationary sources discharge visible
emissions Into the atmosphere; these emis-
sions  are  usually in the shape of a. plume.
This method Involves the  determination of
plume opacity  by qualifled  observers.  The
method includes procedures for the training
and certification of observers, and procedures
to be used In the field, for determination of
plume opacity. The appearance of a plume as
viewed by an observer depends upon a num-
ber of variables, some of which may be con-
trollable  and some  of  which  may not be
controllable In the field. Variables which can
be controlled to an extent  to which they ao
longer  exert a  significant influence  upon
plume appearance include: Angle of the ob-
server with respect to the plume: angle of the
observer with respect to the sun;  point of
observation  of attached and detached staam
plume; and angle of the observer  with re-
spect to a plume emitted from a rectangular
stack with a large length to-wldth ratio. Tha
 method includes specific criteria applicable
 to these variables.
   Other variables which may not be control-
lable, in the field are luminescence and color
contrast between the plume and the  back-
ground against which the plume Is viewed.
These variables exert an Influence  upon the
 appearance  of a plume as viewed by'an ob-
server, and  can affect the  ability of the ob-
server  to accurately assign opacity  values
 to the observed plume. Studies of the theory
of plume opacity and field studies have dem-
onstrated that a plume 13 most visible and
presents the greatest apparent opacity when
viewed against a  contrasting background. It
follows from this, and is confirmed by field
trials, that  the opacity  of a plume, viewed
under conditions where  a  contrasting back-
ground is present can be assigned  with the
greatest degree of accuracy. However, the po-
tential for a positive error is also the greatest
when a plume Is viewed  under such contrast--
tog conditions. Under conditions presenting
a less  contrasting background,  the  apparent
opacity of a plume is  less and approaches
zero as the color and luminescence 'contrast
decrease toward zero. As a result, significant
negative  bias and   negative errors can be
made  when  a plume Is viewed  under less
contrasting  conditions.  A negative  bias de-
creases rather than  increases the possibility
that a plant operator will be cited for a vio-
lation of  opacity standards due to observer
error.
  Studies have been undertaken to determine
the magnitude of positive errors which can
be made  by  qualifled observers while  read-
Ing plumes under contrasting conditions and
using   the  procedures   sat  forth  In  this
method. The results of  these studies  (field
trials)  which involve a  total of 759 seta of
25 readings each are as fallows:
   (1) For black plumes (133 sets at a smoka
generator),  100  percent  of the  sets  were
read with a positive arror1 of less than  7.5
percent opacity; 99 percent were read  wltli
a positive error of less than 5 percent opacity.
   (2) For white plumes (170 sets at a smoka
generator, 168 sets at a coal-fired power plant,
298 sets at a sulrurtc acid plant), 99 percent
of the sets were read with a positive error of
less than 7.5 percent opacity; 95 percent were
read with a positive error of less than 5 per-
cent opacity.
  Tha positive observational error associated
with  an average of twenty-five readings is
therefore  established. The accuracy of the
method must be taken Into account when
determining  possible  violations of  appli-
cable opacity standards.

  1. Principle and applicability.
  1.1  Principle.  The  opacity of  emissions
from  stationary sources  Is  determined  vis-
ually by a qualifled observer.
  1.2  Applicability.  This method  Is appli-
cable tor  the determination of the opacity
of emissions  from  stationary sources  pur-
suant to  ! 60.11 (b) and for qualifying ob-
servers for visually determining  opacity  of
emissions.
  2.  Procedures.  Tha observer qualified  In
accordance with, paragraph 3 of this method
shall  use  the following procedures for vis-
ually determining the opacity of emissions:
  2.1  Position. The qualifled observer shall
stand at a distance sufficient to provide a
clear  view of the emissions with  the sun
oriented in the 140* sector to his back. Con-
sistent with maintaining the above require-
ment;, the observer shall, as much as possible,
make his  observations from a position such
that  his  line  of vision is approximately
perpendicular to the plume direction, and
when observing  opacity of emissions from
rectangular outlets  (e.g. roof monitors, open.
baghouses,  noncircular   stacks),  approxi-
mately  perpendicular to the longer axis  of
the outlet. The observer's line of sight should
not Include more than one plume at a  time
when multiple  stacks ara involved, and  In
any case  the observer should make his ob-
servations with his line of sight perpendicu-
lar to the longer axis  of such a sat of multi-
ple stacks (e.g. stub  stacks on baghouses).
   2.2 Field records. The  observer  shall re-
cord the  name of the plant, emission loca-
tion,  type  facility,  observer's  nam«  and
affiliation, and the date on a field data sheet
 (Figure 9-1). The time, estimated distance
to the emission  location, approximate  wind
direction, estimated wind speed,  description
of the sky condition  (presence and color of
clouds), and plume background'are recorded

   *For  a  set, positive error=average opacity
determined by  observers' 25  observations —
average opacity  determined from transmis-
someter's 25  recordings.
                                                 B-2

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on a field data sheet at the time opacity read-
Ings are initiated and completed.
  23  Observations.  Opacity  observations
shall be made at the point of greatest opacity
In that portion of the  plume  where con-
densed water vapor la not present. The ob-
server shall not  look continuously at the
plume, but Instead shall observe the plum*-
momentarily at 15-second Intervals.
  2.3.1  Attached steam plumes. When con-
densed water  vapor  la present within the
plume as it emerges from the emission out-
let, opacity observations nhan be  made be-
yond tha point In the plume at which con-
densed water vapor la no longer visible. The
observer ahuii  record the approximate  dis-
tance from the emission outlet to the point
In the plume at which, the observations are
made.
  2.3.2  Detached steam plume. When water
vapor in the plume condenses and becomes
visible at a distinct distance from the emis-
sion outlet, the opacity of emissions should
be evaluated at the emission outlet prior  to
the condensation of water vapor and the for-
mation of the steam plume.
  2.4  Recording  observations. Opacity ob-
servations shall be recorded to the nearest 5
percent at  15-second Intervals on an ob-
servational record sheet. (See Figure 9-2 for
an example.) A minimum of 24 observation*
shall b« recorded. Each, momentary observa-
tion recorded  shall be deemed to represent
the average opacity of emissions for a> 15-
second period.
  13  Data Reduction. Opacity ***n be de-
termined  as an  average  of  24 consecutive
observations recorded at 15-second intervals.
Divide the observations recorded on the rec-
ord sheet into sets or 24 consecutive obser-
vations. A set Is composed of any 24 con-
secutive observations. Sets need not be con-
secutive In time and In no case shall two
sets overlap. For each set of 24 observations,
calculate the average by summing the opacity
of the 24 observations and dividing this sum
by 24. I£ an applicable standard specifies  an
averaging time requiring more than 24 ob-
servations, calculate  the average for all ob-
servations  made during  the  specified time
period. Record the average opacity on a record
sheet. (See Figure 9-1 for an example.)
  3. Qualifications and testing.
  3.1  Certification requirements. To receive
tertlflcatioa as a qualified observer, a  can-
•didate must be tested and demonstrate the
•ability to assign opacity readings in 5 percent
Increments to  23 different black plumes and
25  different white plumes,  with  an error
 not to exceed 15 percent opacity on any one
 reading and an average error not  to exceed
 7.5 percent opacity in each category. Candi-
 dates shall be tested according to the pro-
 cedures described  In paragraph 3.2. Smoke
 generators  used  pursuant to paragraph  32
 shall be equipped with a smoke meter which
 meets the requirements of paragraph 3.3.
   The certification shall be valid for a period
 of 8 months, at which time the qualification
 procedure must be repeated by any observer
 in order to retain certification.
  3.2  Certification procedure. The certifica-
tion test consists of showing the candidate a
complete run of 50 plumes—25 black plumes
and 25 white plumes—generated by a smoke
generator. Plumes within each set of 23 blaclc
and 25 white runs shall be presented in ran-
dom order. The candidate assigns an opacity
value to each plume and records hla obser-
vation on a suitable form. At  the completion
of each run of 50 readings, the score of the
candidate la determined. If a  candidate fails
to qualify, the complete run of 50  readings
must  be repeated  In any retest. The smoke
test may be administered as part of a smoke
school or training program, and may be pre-
ceded by training or familiarization runs of
the smoke generator during which candidates
are shown black and white plumes of known
opacity.
  3.3  Smoke  generator  specifications. Any
smoka generator used for  the purposes of
paragraph 3.2 shall be equipped with a smoke
meter  Installed  to measure  opacity across
the diameter of the smoke generator stack.
The smoke meter output shall display In-
stack opacity based upon a pathlength equal
to the stack exit diameter, on a full 0 to 100
percent  chart  recorder  scale.  The smoke
meet  the specifications shown la Table 9-1.
The smoke meter shall be calibrated as pre-
scribed  In  paragraph 3.3.1 prior to the con-
duet  of each smoke reading  test.  At the
completion of each test, the  zero and  span
drift shall be checked and if the drift ex-
ceeds ±:1 percent opacity, the  condition shall
ba corrected prior to conducting any subse-
quent test runs. The smoke  meter  shall be
demonstrated, at the time of  Installation, to
meet  the specifications listed in Table 9-1.
This demonstration shall be repeated fol-
lowing any subsequent repair  or replacement
of the photocell or associated electronic cir-
cuitry Including the chart recorder or output
meter, or every  5 months, whichever occurs
first.

    TABM 9-1—3MOK3
Parameter:
a. Light source	
b. Spectral  response
     of photocell.
c. Angle of view_.

d. Angle  of  projec-
     tion.
e. Calibration error.

f. Zero  and  span
     drift.
y. Response  time__
       DESIGN AND
sfecancixiotta

     Specification
 Incandescent   lamp
   operated at nominal
   rated voltage.
 Photoplc    (daylight
   spectral response of
   the human  eye-
   reference 4.3).
 15"  maTlrrmm  total
   angle.
 15*  ma.*1rmTm  total
   angle.
 ±3 %  opacity,  maxi-
   mum.
         opacity,   30
   minutes.
   5  seconds.
 . 3.3.1  Calibration.  The  smoke  meter  Is
 calibrated  after allowing a minimum of  30
 misutss warniup  by alternately producing
                                                B-3

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simulated, opacity of 0 percent and 100 per-
cent. When, stable respouse at 0  percent or
100 percent is noeed, eta smoke meter Is ad-
justed to produce an output of 0 percent or
100 percent, as appropriate. This  calibration
shall be  repeated until stable 0 percent and
100 percent readings are produced without
adjustment.  Simulated  0  percent  and 100
percent opacity values mat? be produced by
alternately switching the power to  the light
source on and off while the smoke generator
Is not producing smoke.-
   3.3.2  Smoke meter evaluation. The smoke
meter design  and  performance  are to be
evaluated as follows:
   3.3.2.1  Light source.  Verity from  manu-
facturer's  data and from voltage  measure-
ments made at the lamp, as  Installed, that
the lamp  Is operated within  ±3 percent of
the nominal rated voltage.
   3.3.2.2  Spectral   response  of  photocell.
Verily  from manufacturer's data  that  the
 photocell has  a photonic  response; I.e., the
 spectral sensitivity  of  the call shall closely
 approximate the standard spectral-luminos-
 ity curve for photoplc vision which Is refer-
 enced In (b)  of Table 9-1.
   3.3.2.3  Angle of view. Check construction
 geometry to ensure that  the total angle of
 view of the smoke plume, as seen  by the
 photocell, does not exceed 13*. The  total
 angle of view  may be calculated from: 0=2
 tan-1  d/2L, where  )=s total angle- of view;
 d=the sum of the photocell diameter+the
 diameter  of  the  limiting aperture;  and
 Lathe  distance from  th« photocell to the
 limiting aperture. Th»  limiting  aperture  is
 the point In the path between the photocell
 and  the smoke plume  where the angle of
 view Ls  most restricted. In smoke  generator
 smoke meters  this  is  normally an orifice
 plate.
   3.3.2.4 Angle of projection. Check  con-
 struction geometry to ensure that the total
 angle of  projection of the  lamp on  the
 smoke plume does not exceed 15*. The total
 angle of projection may be calculated from:
 4=2 tan-' d/2L, where 0= total angle of pro-
 jection; d= the sum of the  length of the
 lamp filament + the diameter of the limiting
 aperture; and L= the distance from the lamp
 to the limiting aperture.
   3.3.2.3 Calibration error. Using neutral-
 density filters of known opacity, check the
 error  between the actual response »n*l tha
 theoretical  Hnw  response of  tha smoke
 meter. This- check  is accomplished by first
 calibrating the smoke  meter according  to
 34.1 and then Inserting a series of three
 neutral-density filters of nominal opacity of
 20, 30, and 73  percent  in the smoke meter
 pathlength, Filters callbarted within ±3 per-
cent  «b»n  be  used.  Care should be taken
when  Inserting the filters  to prevent stray
light from affecting the meter. Make  a total
of five  nonconsecuttve readings  for each
filter. The maTimiTm error on any one read-
 Ing shall be 3 percent opacity.
   3.3.2.8  Zero  and  span drift.  Determine
the zero and span drift by calibrating and
operating the  smoke generator In  a normal
manner over a 1-hour  period. The drift la
 measured by checking the zero and span at
 the end of this period.
  3.3.2.7  Response time. Determine the re-
sponse time by producng the series of five
simulated 0 percent and 100 percent opacity
values and observing the time  required to
 reach stable  response. Opacity values of 0
percent and 100 percent may be simulated
by alternately' switching the  power to the
light  source  off and on  while the smoke
generator is not operating.
  4. References,
  4.1  Air Pollution Control District Rules
and  Regulations,  Los Angeles County Air
Pollution Control  District,  Regulation IV,
Prohibitions, Rule 50.
  4.2  Welsburd, MelYln L, Field Operations
and Enforcement Manual for Air, "US. Envi-
ronmental Protection Agency, Research Tri-
angle Park, N.C.,  AFTD-1100, August 1973.
pp. 4-1-4.38.
  4.3  Condon. 3.7., and Odlahaw, H., Hand-
book of Physics, McGraw-Hill Co., X.T.. N.T,
19S3, Table 3.1. p. 6-32.
                                               B-4

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                                             9-1
                          jncotD or YXSUU. DETEMUNATIOW or OPACITT
 caauiT
 LOCATION
 awe
                       HOOTS Or OKOL7ATION
                   ..  OBSERVE*	
 TtfS MCXUXY__
 coraoL DEVICE.
                                          OSS BUYER CERTIFICATION DATE
                       WWT or EMISSIONS	
                       HEIGHT Or DISCHARGE POINT
    Iteeord th« following Infonutlon prior to ind uoon conpltcloa of obi«rv»etoni it «ach iourco.
    If obiarwcioai «r« ud* ov«c ia «t«nd«d period of tin*, tddUioiul recordings ihould b< nidi
 CLOCK TIMC
                            aanAC _!_•.«.
                                                     HMAI  _•,_ •...
                                                        '   ™"~"
 astxnn LOCATION
   DUtanc* la Diich«rt*

   5«l|he of Obi«r»»cloa Jelne

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   Vtad Direction
   Wad :
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 ntms
   Color
   Bliuaet 7i»ibl»   .

        or HoscoKn.iA»c2
COMPANY
LOCATION
TEST NUMBlT
DATE	
 FIGURE  9-2   OBSERVATION RECORD

	         OBSERVER
                                                                   PAGE	OF
                         TYPE FACILITY     ~
                         POINT  OF EMISSTOW
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                                          B-5

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FIGURE 9-2  OBSERVATION  RECORD
          (Cont.)

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                                                      PAGE
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                    TYPE  FACILITY
                    POINT OF  EMISS7W
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.
                                    B-6

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                    APPENDIX C

        S 12. - GENERAL POLICY ON THE USE
OF SECTION 114 AUTHORITY FOR ENFORCEMENT PURPOSES'
                       C-l

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S 12. - GENERAL POLICY ON THE USE OF SECTION 1.14 AUTHORITY FOR
        ENFORCEMENT PURPOSES

INTRODUCTION

     The purpose of this guideline is to provide guidance relating
to the exercise of the authority set forth in Section 114 of the
Clean Air Act, as amended, for enforcement purposes.—'

USES OF SECTION 114

Use in Determining Status of Compliance

    Section 114(a)(ii) provides that the Administrator may require
the owner or operator of any source to provide information for the
purpose of determining "whether any person is in violation of any
such standard or any requirement of such a plan."  This is one of
the most important enforcement tools under the Clean Air Act, in
that the source can be required to provide the information which may
be the basis for enforcement action by EPA.  Regions are urged to
make extensive use of §114 for enforcement purposes since this is
usually the most effective method of obtaining "the necessary informa-
tion to begin an enforcement action.

Uses During Emergency Episodes

    Section 114(a)(iii) of the Act enables EPA to obtain informa-
tion necessary to implement Section 303 authority (emergency
episodes).  During an emergency episode, it may be necessary to
obtain recordkeeping by such owner or operator to ensure that he
is taking appropriate action.  This section can also be used to
develop Section 303 emergency episode action plans, as discussed
in General Enforcement Guideline S.15.
_!/ Section 114(a)(l) enables the Administrator to require owners or
   operators of emission sources "to (A) establish and maintain such
   records, (B) make such reports, (C) install, use, and maintain
   such monitoring equipment or methods, (D) sample such emissions
   (in accordance with such methods, at such locations, at such
   intervals, and in such manner as the Administrator shall pre-
   scribe) , and (E) provide such other information, as he may
   reasonably require." Section 114(a)(2) authorizes right of entry
   for certain purposes and the right of the Administrator to
   sample emissions.
                                C-2

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REQUEST FOR INFORMATION

Section 114 Letter Format

    The letter to an owner or operator should recite expressly  that
it is being sent pursuant to Section 114(a)(ii) or  (iii), state
specifically the information required, recite the penalties for
non-compliance, and specify a reasonable time to answer.  Generally
it should be sent certified mail, return receipt required, to
document receipt.  In the letter, the Regional Office may require
the source owner or operator to appear at a designated time and
place to discuss the information required to be provided to
EPA.

    During an emergency episode a Section 114 letter should be
delivered personally to the source owner or operator and a receipt
should be obtained upon delivery.

Privilege Against Self-Incrimination

    A problem may arise in the case of an individual who refuses to
provide information on the grounds of the Fifth Amendment privilege
against self-incrimination.  This is not a problem with respect to
a corporation, since a corporation does not have this privilege.
However, except as discussed in the following, an individual, as
opposed to the corporation, may refuse to answer any request for
information under Section 114 if the information might tend to
incriminate him.   (See OGC memo dated 8/7/72).  If an individual re-
fuses to comply with the request for information on this ground, the
Regional Office should consider itself on notice of a probable viola-
tion and should gather the information by other  methods.

    If the information needed from the source owner or operator is
required to be kept under a recordkeeping provision of a State
Implementation Plan, then the privilege may not be invoked, even
by an individual. U  Thus, if an individual raises an objection
on Fifth Amendment grounds, the State Implementation Plan should be
checked to determine whether the plan requires such information to
be kept by the source, and if it does, Fifth Amendment objections
are not valid and the information must be provided.
2J According to the Shapiro Doctrine, "the privilege which exists as
   to private papers cannot be maintained in relation to  'records re-
   quired by law to be kept in order  that there may be suitable in-
   formation of transactions which are the subject of governmental
   regulations and the enforcement of restrictions validly estab-
   lished'".
                               C-3

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    The Section 114 letter need not call to the attention of the
source owner or operator that he may have a right to invoke the
privilege against self-incrimination nor need this be done at an
onsight investigation.  The Miranda warning is required only where
a person is "in custody".

Federal Reports Act

    Section 114 letters sent to persons suspected of being in viola-
tion of an implementation plan requirement or Section 303 are not
subject to the Federal Reports Act.  Identical letters may be
sent to multiple sources without the need for securing OMB approval
since this use of Section 114 is an enforcement function rather than
the gathering of technical data for standard setting purposes.

    Before sending out a Section 114 letter, check the NEDS data
bank to determine whether EPA already has such information.  How-
ever, where immediate enforcement action is contemplated, the
Regional Offices should direct a Section 114 letter to the source
regardless of the results secured from the data bank.  Duplication
of reported information can be avoided by advising the source of the
information in our possession and affording the source the opportunity
to confirm such information as responsive to the Section 114 inquiry.
This practice will be necessary because information employed for en-
forcement purposes must constitute reliable evidence on the present
status of compliance and be so represented by the source under pain
of penalty for any misrepresentation.  To proceed otherwise presents
the prospect that a source may repudiate information in our possession
on which we base a finding of violation, and we then would be forced
to gather further proof to verify and substantiate our determination
before commencement of any judicial proceedings.

Trade Secrets

    It is anticipated that some of the information required by
Section 114 letters will contain trade secrets.  Although the infor-
mation asked for must be provided, the source owner or operator can
designate certain portions of his response confidential'and EPA
must treat it as such unless and until the Administrator determines
that it is not entitled to protection as a trade secret.  This de-
termination should be made after the information has been submitted,
if either the source owner or operator requires that such a deter-
mination be made or if someonw else requests the information from
SPA.  Regional Offices can also make these determinations on their
own initiative to keep down the amount of material which must be
afforded confidential treatment.  No determination or agreement will
be made concerning trade secrets status prior to receipt of the


                                C-4

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Section 114 information.  The regulations  in  40  CFR Part  2
outline the EPA procedures for making  this determination.

ENTRY AND INSPECTION   '

     Section 114(a)(2) enables the Administrator or his authorized
representative to enter a source so  that EPA  can do its own
monitoring, sampling, inspecting or  copying of records.   This
authority also can be used to determine whether  a source  is carrying
out any obligations imposed on it by EPA under Section 114(a)(l).

     The term "authorized representative" would  include specific
individuals from each Regional Office, preferably permanently de-
signated to give a  sense of continuity and familiarity with the
tasks.  This does not mean that other Regional Office or  EPA employees
cannot perform such tasks on an ad hoc basis  when necessary to
achieve EPA objectives.

     A contractor for EPA or other person  assisting EPA in carrying
out its functions may be designated  as an  "authorized representative"
for specific purposes which should be stated  in  a letter  granting
such representative status to the contractor.  However, if the con-
tractor is refused  entry by the source owner  or  operator  despite
this letter, it is not advisable to  request a U.S. Attorney to obtain
a search warrant to gain entry for the contractor, since  a judge
would most likely refuse to issue one.  EPA personnel should perform
the task themselves if such a situation arises or accompany the EPA
contractor performing the work.

     Where a state has been delegated Section 114 authority from
EPA, the same authority EPA has to monitor, sample, inspect or
copy records, and any other authority under Section 114(a)(l) and
(2) of the Clean Air Act can, in like manner  be  exercised by the
State.  No representative of EPA need accompany  the state officials.

     Section 114(a)(2) requires that the person  exercising the right
of entry should have credentials.  EPA has established a  procedure
governing the issuance and control of credentials.  Regional Offices
may obtain such credentials in accordance with the procedures.   The
Regional Offices can still issue their own credentials to carry out
Section 114 in the period until the  procedures in the EPA order can
be implemented or in unusual circumstances.   If  the Regional Office
chooses to issue its own credentials in such  instances, such credentials
should contain the agency name; the  bearers name, signature, and
photograph;  the division in the agency with thich he is employed; the
quotation of Section 114 authority under which entry is sought; and a
                                 C-5

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citation of the penalties for noncompliance with  Section  114.   The
credentials should be signed by  the Regional Administrator.   Credentials
can also be issued by the Regional Office  in the  form  of  a  letter on
an ad hoc basis where there is not sufficient time to obtain more
permanent credentials.   'The letter should contain all of the in-
formation that is in the permanent credentials except the photograph
and signature of the bearer.

     Entry for Section 114  purposes  should  be confined, except in
emergencies,  to normal business hours to minimize inconvenience to
the source.

Safety Equipment

     A source owner or operator has no responsibility to supply EPA
inspection teams exercising Section 114 authority with safety equip-
ment such as hard hats or shoes.  EPA should provide whatever equip-
ment is necessary for an inspection team to safely perform those
duties entrusted to them by law.

Visitors Releases

     Members of inspection teams exercising Section 114 authority
should not sign waivers or "visitors releases" that would absolve
the company of responsibility of injury due to negligence.  In a
memo to all Regional Counsels dated November 8, 1972, from John
Quarles, it is stated that "Inasmuch as the Clean Air Act .  . .
grant(s) EPA employees a right of entry to corporate facilities,
a company may not lawfully condition the exercise of this right
upon the signing of a release or indemnity agreement."  "When
a firm refuses entry to an EPA employee performing his function
under the Clean Air Act, the employee may appropriately cite
the statute and remind the company of EPA's right to seek judicial
enforcement.   If the company persists in its refusal, EPA should
go to court in preference to signing a 'Vistors Release1".

Search Warrants

     If a  source owner  or operator refuses to admit EPA authorized
representatives attempting  to exercise Section 114 responsibilities,
entry cannot be made until  a search warrant is obtained.  Appro-
priate Regional personnel should be notified so that they can  request
that the U.S. Attorney  obtain a  search warrant.   (DSSE is developing
a model application for a search warrant and a model search warrant
for use by the Regional Offices).  If any  delay is anticipated  from
a source in permitting  the  exercise of Section 114 authority  and such
delay is unacceptable to the successful completion of  EPA tasks, a

                                 C-6

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search warrant should be obtained.  If delay is anticipated even
with a search warrant, it can be requested that the search warrant
be written so that immediate entry be granted.

ENFORCEMENT PROCEDURES

     Section 113(a)(3) provides that if the Administrator finds that
any person is in violation of any requirement of Section 114, he may
bring a civil action or issue an administrative order.  Guideline S4.
outlines procedures relevant to the commencement of a civil action
or issuance of an administrative order.

     In cases of failure to comply with Section 114, issuance of an
administrative order is more appropriate.  However - in most cases
regional enforcement personnel will want to phone the source prior
to the issuance of such an order to determine the reasons for the
source owner or operator's failure to comply.  If the source owner
or operator continues his refusal to comply after the phone call,
issuance of the order should proceed.  The order should include a
final date for compliance, and should specify a date for an oppor-
tunity to confer pursuant to Section 113(a)(4) prior to the effective
date of the order.  If the source owner or operator violates the
order, civil and criminal action will then be appropriate.

     While there are no criminal penalties for refusing to comply
with Section 114 per se, a knowing failure to comply with any order
issued under Section 113 relating to a Section 114 violation would
subject the violator to criminal penalties of up to $25,000 per
day or imprisonment for not more than one year, or both, for the
first offense.  Criminal penalties are also appropriate in the case
of any person who knowingly makes any false statement or tampers with
any monitoring device.  The criminal penalties specified in Section
113(c)(2) for a violation of this type are a fine not to exceed
$10,000 or imprisonment for not more than six months, or both.  (See
Guideline S.O, General Policy on Commencement of Criminal Actions
Pursuant to Section 113(c)).
                                  C-7

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               APPENDIX D




SUGGESTED CONTENTS OF STACK TEST REPORTS
                    D-l

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CONTENTS OF STACK TEST REPORTS

     In order to adequately assess the accuracy of any test report
the basic information listed in the following suggested outline is
necessary:

     (1)  Introduction.  Background information pertinent  to  the
          test is presented in this section.  This information shall
          include, but not be limited to, the following:
          (a)  Manufacturer's name and address.
          Cb)  Name and address of testing organization.
          (c)  Names of persons present, dates and location of
               test.
          (d)  Schematic drawings of the process being tested showing
               emission points, sampling sites, and  stack  cross-
               section with the sampling points labeled arid dimen-
               sions indicated.
          (e)  Brief Process Description

     (2)  Summary.  This section shall present a summary of test
          findings pertinent to the evaluation of the process
          with respect to the applicable emission standard.   The
          information shall include, but not be limited to, the
          following:
          (a)  A summary of emission rates found.
          (b)  Isokinetic sampling rates achieved if applicable.
          (c)  The operating level of the process while the tests
               were conducted.

     (3)  Procedure.  This section shall describe the procedures
          used and the operation of the sampling train and process
          during the tests.  The information shall include, but not
          be limited to, the following:
          (a)  A schematic drawing of the sampling devices used
               with each component designated and explained in a
               legend.
          (b)  A brief description of the method used to operate the
               sampling train and procedure used to  recover samples.

     (4)  Analytical Technique.  This section shall  contain a brief
          description of all analytical techniques used to determine
          the emissions from the source.

     (5)  Data and Calculations.  This section shall include  all
          data collected and calculations.  As a minimum,  this
          section shall contain the following information:
          (a)  All field data collected on raw data  sheets.
          (b)  A log of process and sampling train operations.
                                D-2

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     (c)  Laboratory data including blanks, tare weights, and
          results of analysis.
     (d)  All emission calculations.

(6)  Chain of Custody.  A listing of the chain of custody of
     the emission test samples.

(7)  Appendix:

     (a)  Calibration work sheets for sampling equipment.
     (b)  Calibration or process logs of process parameters.
                            D-3

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                                     TECHNICAL REPORT DATA
                             (Please read InslnKtions on the reverse before completing)
t. =SPORT NO.
  EPA 340/1-77-001
                                                              3. RECIPIENT'S ACCESSION-NO.
-. TITLE AND SUBTITLE

     Inspection Manual for Secondary Lead Smelters
              5. REPORT OATS
                   February f977
                                                              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                M.D.  High
                M.E.  Lukey
                T.A.  Li  Puma
                                                              8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS

     Engineering-Science,  Inc.
     7903 Westpark Drive
     McLean,  Virginia  22101
                                                              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.

                      68-02-1086
12. SPONSORING AGENCY NAME AND ADDRESS

    Environmental Protection Agency
    DSSE
    Washington, B.C.
              13. TYPE OP REPORT ANO PERIOD COVERED
                       Final
              14. SPONSORING AGENCY CODE
IS. SUPPLEMENTARY NOTES

    One  of  a series of NSPS Enforcement Inspection Manuals
16. ABSTRACT


    This document presents  guidelines to enable  enforcement personnel to determine
    whether  new or modified secondary lead smelters comply with New Source Performance
    Standards  (NSPS).  Key  parameters identified during the performance test are used
    as a comparative base during subsequent  inspections to determine the facility's
    compliance status.  The secondary lead smelter process, atmospheric emissions from
    this process, and emission control methods are described.  Inspection methods and
    types of records to be  kept are discussed in detail.
17.
                                 KEY WORDS ANO DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.lOENTIFIERS/OPEN ENDED TERMS
                              COSATI Field/Group
    Lead Alloys
    Smelters and Air Pollution
    Secondary Lead  Smelter
                                    13B
                                    14D
                                    11F
13. DISTRIBUTION STATEMENT

    Release unlimited
19. SECURITY CLASS (This Report]
        Unclassified
21. NO. OP PAGES
         75
                                                20. SECURITY CLASS (Thispage)
                                                         Unclassified
                                                                            22. PRICE
EPA Form 2220-1 (9-73)

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