EPA 340/1-77-003
JANUARY 1977
Stationary Source Enforcement Series
INSPECTION MANUAL FOR ENFORCEMENT OF
NEW SOURCE PERFORMANCE STANDARDS
SECONDARY BRASS AND
BRONZE INGOT PRODUCTION
PLANTS
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 BRASS AND BRONZE INGOT PRODUCTION PLANTS
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 furnished to 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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ACKNOWLEDGMENT
This report was prepared under the direction of Mr. 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 contribution made
to this study by Mr. Antell and other members of the Division of
Stationary Source Enforcement.
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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 2-4
2.4 Hazardous Sources 2-5
3.0 PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS, AND 3-1
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, Rotary and Crucible Furnace 3-5
-3.3 Emission Control Methods 3_g
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 4-4
5.0 STARTUP, SHUTDOWN, AND MALFUNCTIONS 5-1
5.1 Startup 5-2
5.2 Shutdown 5-2
5.3 Malfunctions 5-2
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TABLE OF CONTENTS (Continued)
Page
6.0 INSPECTION PROCEDURES 6-1
6.1 Conduct of Inspection 6-1
6.2 Inspection Checklist 6-3
6.3 Inspection Followup Procedures 6-5
7.0 PERFORMANCE TEST 7-1
7.1 Process Operating Conditions 7-1
7.2 Process Observation 7-2
7.3 Emission Test Observations 7-3
7.4 Performance Test Data 7-5
8.0 REFERENCES 8-1
APPENDIX A STANDARDS OF PERFORMANCE FOR SECONDARY A-l
BRASS AND BRONZE INGOT PRODUCTION PLANTS
APPENDIX B METHOD 9 - VISUAL DETERMINATION OF THE B-l
OPACITY OF EMISSIONS FOR STATIONARY SOURCES
APPENDIX C S 12. - GENERAL POLICY ON THE USE OF SECTION C-l
114 AUTHORITY FOR ENFORCEMENT PURPOSES
APPENDIX D SUGGESTED CONTENTS OF STACK TEST REPORTS D-l
APPENDIX E BRASS AND BRONZE INGOT INSTITUTE LIST OF E-l
STANDARD COPPER BASE ALLOYS
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LIST OF FIGURES
Figure Page
3.1 Air Pollution Control System in the Brass and 3-12
Bronze Industry
LIST OF TABLES
Table Page
2.1 Representative Data From Process Weight Curve 2-3
3.1 Air Pollution Control Equipment in Use in the 3-9
Industry
6.1 Brass and Bronze Industry Inspectors Worksheet. 6-7
Part I - Process Data
6.2 Brass and Bronze Industry Inspectors Worksheet 6-8
Part II - Control Equipment Data
6.3 Brass and Bronze Industry Inspectors Worksheet 6-9
Part III - Startup, Shutdown and Malfunction
6.4 Brass and Bronze Industry Inspectors Worksheet 6-10
Part IV - General Observations
7.1 NSPS Inspection Checklist For Secondary Brass 7-6
and Bronze Smelters
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1.0 INTRODUCTION
In accordance with Section 111 of the Clean Air Act, the Admin-
istrator of the Environmental Protection Agency promulgated particu-
late and opacity standards of performance for new and modified secondary
brass and bronze ingot production plants. The standards became effective
March 8, 1974 and apply to sources the construction or modification of
which was commenced after June 11, 1973. The standards are applicable
to reverberatory and electric furnaces with a production capacity of
1,000 kg (2,205 Ib) or greater and blast (cupola) furnaces with a pro-
duction capacity of 250 kg/hr (550 Ib/hr) or greater.
Under these new source performance standards, a performance test
must be conducted on any new or modified secondary brass and bronze
ingot production plant to ensure that control equipment is designed
and installed which will provide compliance with the standard. After
determining that the facility with its control equipment does, in
fact, comply with the standards, it is the further intent of the
regulations that the equipment not be allowed to deteriorate to the
point where the standards are no longer maintained. A specific pro-
vision, 60.11 (d), provides that affected facilities shall be operated
and maintained "in a manner consistent with good air pollution con-
trol practice for minimizing emissions."
The purpose of this manual, therefore, was to provide the air
pollution inspector with necessary information so that he could
determine whether or not an ingot plant was still in compliance for
some period of time after the conduct of initial performance tests.
To provide for this continuing enforcement of the emission standards,
the Division of Stationary Source Enforcement of the Environmental
Protection Agency 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 EPA1s new source per-
formance standards, it was intended that the information contained
herein would be equally useful for enforcement of state regulations
applicable to all existing brass and bronze facilities.
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In both cases the regulations may be enforced by either Federal
or State air pollution control authorities. FJach state may develop
a program for enforcing the Federal new source performance standards
applicable to sources within its boundaries. If the proposed program
is adequate, EPA will delegate implementation and enforcement authority
to the state for all affected sources with the exception of those Downed
by the U.S. Government. Also, each state was required to submit imple-
mentation plans to EPA in 1971 that included emission regulations
which would reduce emissions and ensure attainment and 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 Implementation Plan.
If a Federal inspector observes a violation of a state's regulation
adopted under the State Implementation Plan, he can co-equally en-
force the SIP regulation.
The scope of this manual includes all processes normally found
in the secondary brass and bronze smelting and refining industry.
It should be equally applicable to both existing and new facilities.
It does not cover primary copper smelters which use ore concentrates
as their copper source.
This report was prepared from information previously published
on the brass and bronze industry, from stack tests of several brass
and bronze plants, from applicable rules and regulations promulgated
by EPA and published in the Federal Register, and from past experi-
ences of the air pollution control staff of Engineering-Science, Inc.
The assistance of staff from the Division of Stationary Source En-
forcement 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 brass and
bronze industry sources 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 plant 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. 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."(4)
Provisions of the regulation are applicable to reverberatory
and electric furnaces of 1000 kg (2,205 Ib) or greater production
capacity per heat and continuous blast (cupola) furnaces of 250 kg/
hr (550 Ib/hr) or greater production capacity. To eliminate re-
peated reference to the Federal Register, the definitions and
standards are paraphrased in the ensuing discussion. Reverberatory
furnaces include stationary, rotating, rocking, and tilting types.
An electric furnace is one that uses electricity to produce over 50
percent of the required heat. A blast furnace is any furnace used
to recover metal from slag.
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 discharge
into the atmosphere from a reverberatory furnace any gases which:
0 Contain particulate matter in excess of 50 mg/dscm
(0.022 gr/dscf); or
0 Exhibit 20 percent opacity or greater.
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Likewise, after a performance test has been conducted, the
effluent gases from any blast furnace (cupola) or electric furnace
shall not exhibit 10 percent opacity or greater.
The opacity standards exclude uncombined water vapor. No mass
standard was proposed for electric and blast furnaces primarily be-
cause (1) 95 percent of the production is carried out in reverberatory
furnaces and (2) the visible emission standard is an adequate enforce-
ment criterion and can be met only by well controlled units.
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 (SIP) 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. (6)
In the case of particulate emissions, EPA published a reference
process weight table (Table 2.1) representative of data from state
and local regulations.
The Federal standard is 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. However, no
state or local agency now has an emission standard specifically for
the brass and bronze industry. Instead, process weight regulations
are commonly employed by many state and local jurisdictions 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 regulations are frequently
modified and may contain qualifications, exceptions 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 complicated.
In the secondary brass and bronze 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.
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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
The equivalent concentration restrictions that now appear in
process weight tables limit emissions to between 0.05 and 0.3 gr/scf.
Some regulations, by definition of particulate matter, do include
material collected in the wet impingers thus making compliance more
difficult. Wet impingers use high velocity impingement in water thereby
increasing the amount of particulate matter caught. In general, the
NSPS of 0.022 gr/dscf is more restrictive than any process weight curve
for furnaces of the size used in the brass and bronze industry. Specifi-
cally, the NSPS will limit emissions to between 1.0 and 1.5 Ib/hr
whereas a typical 25-ton brass furnace (24-hour cycle) would be allowed
3.6 Ib/hr under the process weight table shown above. 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 6,900
Ibs/hr charge rate) would limit particulate emissions to only
7.6 Ib/hr.
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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 8Ib/hr, which corresponds to 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 only to the three
major types of furnaces used in the brass and bronze industry—
reverberatory, electric, and blast. The standards do not apply to
very small furnaces—below the indicated cut-off size but such small
furnaces will not often be encountered. The standards apply after
the 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 representative operating conditions.
However, as will be described later, the owner must report all ex-
cess 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 malfunction.
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 applied) emitted
into the atmosphere by that facility or which results in the emission
of any air pollutant (to which a standard applied) into the atmos-
phere not previously emitted. The definition of modification and
other questions of applicability are fully discussed at 40 FR 58416
(December 16, 1975).
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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 viola-
tion 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 evidence that
a new source has discharged visible emissions to the atmosphere 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 conditiqns
during a period of possible emission limit violation.
2.4 HAZARDOUS SOURCES
Under Section 112 of the Clean Air Act the Administrator of
EPA has promulgated National Emission Standards for Hazardous Air
Pollution Sources (NESHAPS). The first set of standards was applied
to emissions of asbestos, mercury, and beryllium. On occasion the
brass and bronze smelting and refining industry may use beryllium as
an alloy so air pollution officials should inquire of the owner or
operator about its use.
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3.0 PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS,
AND EMISSION CONTROL METHODS
There are approximately 60 producers of brass and bronze ingots
in the United States. In addition, there are several thousand found-
ries and about a dozen primary smelters. The foundries basically just
melt the copper alloys for subsequent molding into various consumer
products and the air pollution potential is therefore quite small.
The primary smelters, on the other hand, use mineral ores from the
mines as their main source of copper; they may use some scrap. These
primary copper smelters are located in Arizona and other western
states. Their air pollution potential is very great both from par-
ticulates and from sulfur dioxide emissions.
The brass and bronze smelting and refining industry is concen-
trated in our Nation's population centers, primarily in the north-
eastern, midwestern and Pacific coast states. The reason for the
location is that their basic raw material is not ore or virgin metal
but copper-base alloy scrap which is collected by commercial scrap
dealers. Thus the term secondary smelters refers to the source or
origin of the copper and not to the quality of the ingots produced.
The annual ingot production is about 300,000 tons, so with 60
producers, an average facility would pour somewhere around 5,000
tons per year. Brass and bronze are generally considered to be
copper-base alloys with zinc and tin respectively as the largest
secondary components. However, there are many more possible alloys
as illustrated by the fact that the Brass and Bronze Ingot Institute
produce 31 standard copper-base alloys (see Appendix E).
3.1 PROCESS DESCRIPTION
Raw materials consist of copper bearing scrap, i.e., faucets,
telephone or electric cable, radiators, brass turnings, etc. The
scrap is sorted into piles of like materials (similar alloys) and
foreign matter and impurities are removed. Scrap cleaning may in-
clude several different unit operations. Burning oil or paint
off the scrap surfaces is often required for oil covered turnings.
Plastic coated copper wire may be burned, hand stripped or run through
a hammer mill to separate the coating material from the copper. Large
scrap items may be heated in a sweat furnace to remove specific metals
such as lead by melting at predetermined temperatures. Iron materials
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can be magnetically removed and light materials by gravity separation
in a water medium. None of the above described processes are covered
by EPA's NSPS.
One major scrap preparation process, which is covered by the
NSPS, is the blast furnace (cupola). The blast furnace (cupola) used
in processing secondary copper is similar to those in the ferrous in-
dustry, cylindrically shaped and vertically standing. This furnace
is a continuous process that accepts slag skimmings and other metal
oxides which are the byproducts of the ingot production furnaces.
Coke, copper oxides and other materials are charged into the top
of this furnace and combustion air, sometimes enriched with oxygen, is
blown in through tuyeres at the bottom. The resulting metal (black
copper) settles to the bottom and is drawn off for subsequent refining
in the ingot production furnaces.
After the scrap is sorted and cleaned or reduced by the blast
furnace, it is melted in a batch type furnace, impurities are
burned out with help from fluxes, alloys are added to bring the batch
up to specification, and the refined metal is poured into ingots and
sold. Brass and bronze ingots are produced from three types of fur-
naces—revaxberatory, rotary or crucible. In the industry, 95 per-
cent of the brass and bronze ingots are produced by direct oil or gas-
fired reverberatory furnaces. Probably the second most commonly used
furnace is the direct-fired rotary furnace but, by EPA definition,
it is classified as a reverberatory and must meet the same new source
performance standard. Reverberatory furnaces operate by radiating
heat from the gas or oil fired burners and the surrounding hot re-
fractory lining onto the contents of the furnace. The flame and
products of combustion 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 crucible furnace is very small, indirectly fired by gas,
oil, or electricity, and used primarily for refining special alloys.
Only the electric crucible furnaces are covered by EPA's NSPS; gas
or oil-fired crucible furnaces are not.
In the furnace operation there are five fairly distinct steps
to producing a batch of brass or bronze of the desired specification.
First, the scrap materials are charged into the preheated furnace
(charging). Second, oil or gas is fired directly into the charge
to melt the materials (melting). Third, the charge is brought to
the desired temperature and fluxes are added to remove impurities
such as carbon, metal oxides, gases, etc. (refining or smelting).
Fourth, after the impurities are removed, metal is added to bring
the alloy to the proper metallic composition (alloying). Fifth, when
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analysis indicates the correct grade has been achieved and the melt
is at the proper temperature, the metal is poured into ingots
(pouring).
A typical weekly schedule at one plant consisted of lighting
the furnace Sunday afternoon, melting and smelting on a" continuous
basis from Sunday through Friday, with pouring normally completed
during the morning hours. Furnaces were turned off on Saturday.
For a more complete description of the unit operations utilized
by the secondary brass and bronze industry, refer to:
° Air Pollution Engineering Manual (8).
° Air Pollution Aspects of Brass and Bronze Smelting and
Refining Industry (14).
3.2 ATMOSPHERIC EMISSIONS
3.2.1 General
Emissions from the brass and bronze industry are primarily
particulates. Most of the furnaces are fired by natural gas or oil
so sulfur dioxide, nitrogen dioxide, hydrocarbons, and carbon
monoxide emissions are not too important. These gaseous emissions
are not regulated by the new source performance standards although
some state regulations on gaseous emissions might be applicable. For
example, sulfur-in-fuel regulations could limit sulfur dioxide emis-
sions. Nitrogen dioxide emission limitations might apply to the
larger reverberatory furnaces. Carbon monoxide emission limitations
might be applicable to the blast furnace where exhaust gases con-
tain large quantities of CO. Hydrocarbon limitations might be
applicable to the removal of cutting oils from chips, borings, or
turnings with heat or combustion. The National Emission Standards
For Hazardous Air Pollution Sources might be applicable in a few
isolated cases if beryllium is used as an alloy.
Considering particulate emissions from the brass ana bronze
industry, the major sources are the furnaces which are regulated by
the NSPS. However, to be complete all industry sources are considered,
starting with the raw material handling and preparation.
Raw material handling generally does not produce fugitive dust
since most of the scrap materials are large or contain some oil on
their surface. 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.
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Raw material preparation can be done mechanically such as wire
stripping with the only potential pollution problem being solid waste.
It can be done with water and the potential is water pollution. If
heat is used (pyrometallurgical processes) then a potential air pol-
lution problem exists to some degree. Sweat furnaces are operated
at medium to low temperature to melt materials such as solder from
old car radiators. Principal emissions are particulates from anti-
freeze residue, soldering salts and hose connections; metal fumes
are minimal. Of five sweat furnaces surveyed in 1968, four had no
control equipment and one was served by an afterburner and baghouse
(14).
Burning of insulation on copper wire produces large quantities
of smoke and other particulates (up to 29 gr/scf) as well as large
amounts of gases. If plastic coatings are being burned the effluent
gases will contain high concentrations of chlorides or fluorides.
One such facility in Maryland measured halogens of several ppm in
the stack gases (5). From the BBII survey in 1968, only one wire
burning furnace was listed and it was served by an afterburner (14).
Drying oil from copper chips, turnings or borings creates con-
siderable amounts of smoke and hydrocarbons. The emissions generated
obviously relate to the quantity of oil present on the scrap.
Vaporized fumes must be burned in an afterburner to prevent excessive
air pollution.
3.2.2 Blast Furnace
The blast furnace produces black copper from slag, skimmings,
and other residues. Emissions include oxides of various metals,
silicon, coke dust, smoke, and carbon monoxide. Discharge points
include the stack, charging doors, and metal tapping spout. Without
control equipment, emissions will create a plume of 60 to 100 percent
opacity (8). The mass emission rate on one tested cupola was
0.68 gr/scf, 216 Ib/hr, and 73.2 Ib/ton (14). The slag tap is not
a major emission point. The slag is rich in zinc oxide but it is in
solution and does not volatilize to any extent and it is quickly
quenched with water. Blast furnace (cupola) emissions are limited
to 10 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 scrap
charged.
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3.2.3 Reverberatory, Rotary and Crucible Furnaces
The ingot producing furnaces include the reverberatory, rotary,
and crucible. The NSPS apply to the reverberatory and by definition
includes the rotary. Crucibles heated by electricity also are regu-
lated by the NSPS. As pointed out earlier the industry produces 95
percent of its ingots by reverberatory furnaces. Also the chemical
makeup of emissions and the factors which influence emission rates
are similar so these factors will be discussed as they apply to all
ingot producing furnaces but with emphasis on the reverberatories.
Probably the most important factor affecting metal fume emission
rates is the percentage of zinc in the alloy. The rate of discharge
of zinc oxide will be proportional to the amount of zinc in the alloy.
This is a factor because zinc has a relatively low boiling point com-
pared to copper and other alloy materials. Lead oxide is probably
the second most common fume especially in the high-lead alloys.
Type and condition of the scrap raw materials may affect emis-
sion rates. Oily and dirty scrap will create considerably more
smoke and particulate emissions.
Location of the charging doors is important. Top loading doors
allow excessive emissions when opened whereas end or side charging
doors may be under negative pressure when opened and only small
quantities of effluent will escape. Even with side or end charging,
however, the firing rate should be reduced to prevent excessive dis-
charges .
Air blowing rates will affect emission rates. Compressed air
is blown into the molten bath of metal to selectively oxidize metals
in accordance with their position in the electromotive series. Iron,
manganese, silicon and aluminum are high in the series and are there-
fore oxidized. For a typical 50-ton reverberatory furnace, a 160 cfm
of compressed air will volatilize and oxidize up to 750 pounds of
zinc per hour in the metal bath. Based on the total volume of gases,
of course, this could result in a ZnO concentration of 20 gr/cf at
the furnace exit.
Flux covers, which are eventually skimmed off, prevent excessive
volatilization losses. On the other hand, a thick layer is not de-
sirable from the operator's viewpoint since it will reduce heat
transfer to the melt. A slag cover of about 1/2 inch is desirable
although thicknesses up to 12 inches are not uncommon.
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The quantity of zinc or other volatile metal alloy that must be
added to the melt at the end of the refining step will affect emission
rates. Emissions are less if the initial charging period can include
the right combination of alloy constituents. When zinc bars are
added towards the end of the refining step, the flux cover is broken,
the molten metal is very hot and zinc oxide emissions are greater.
The oxidation of zinc is an exothermic reaction, thereby, generating
large quantities of heat.
Pouring temperature also is important to the quantity of fumes
generated. For a given percentage of zinc, an increase of 100°F
increases the rate of loss of zinc about three times. The boiling,
pouring, and melting points of metals and alloys are shown in the BBII
publication. Highlights of the pouring temperatures are indicated
below:
High nickel alloy — 2400°F
High lead alloy -- 2200°F
High zinc alloy — 2100°F
Magnesium alloy — 1400°F
Aluminum alloy — 1350°F
Notwithstanding all of the variables that can affect emission
rates, test data on two reverberatory furnaces (100 ton and 60 ton)
showed emissions on the order of 50 to 150 Ib/ton. The test data
are summarized (14). Apparently about three percent of the total
material charged to the furnaces is eventually collected in the bag-
houses. Two rotary furnaces were tested (17.5 and 4 ton) and showed
a similar emission range of about 30 to 150 Ib/ton. Limited data
indicate that concentrations of dust from brass furnaces may range
from 0.05 to 4.1 grains per standard cubic foot (scf) . Concentra-
tions as large as 20 grains per cubic foot may be expected during the
use of compressed air beneath the molten metal.
Electric furnaces discharge much smaller quantities of particu-
late fume. No tests were conducted by EPA prior to establishing the
NSPS standard. Certain electric furnaces were felt to be able to
easily meet the standards since an electric furnace in a brass and
bronze foundry showed only 2.8 Ib/ton of emission.
3.3 EMISSION CONTROL METHODS
The principal control device used to reduce particulate emis-
sions from secondary brass and bronze furnaces is the fabric filter
baghouse. In the case of controlling blast furnace emissions, the
3-6
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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 performed within the furnace. Prior to entering the baghouse
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 may be unnecessary.
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 fiberglass
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 com-
mon 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 5QOF 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 ulti-
mately rupture the bag fabric. In addition to the water, acids will
also be formed from the sulfur oxides, 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 acfm/1 sf is commonly employed
for efficient operation of the collection system. Most likely, the
only monitoring instrument used with a baghouse will be a manometer
which measures the pressure drop across the entire system. This will
commonly range up to 4 in I^O gage. 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 in visible emissions emitted by the baghouse is
the more common method of establishing a malfuntion in the baghouse.
Venturi scrubbers are not utilized as commonly as baghouses
in the secondary brass-bronze industry. Depending on the appli-
cation they can vary between 30 and 100 in 1^0 pressure drop.
3-7
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In some0cases, the furnace gas temperature has to be reduced by
water sprays to prevent adverse operation of the scrubber. A 60
in. t^O 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.
However, wet scrubbers and electrostatic precipitators have not been
particularly successful in the collection of zinc oxide fume. Three
scrubbers serving brass-melting furnaces reported efficiencies between
53 and 65 percent. Pressure drop was not indicated but was probably
not too high. To achieve the control efficiencies required to meet
the NSPS, pressure drops would have to be on the order of 50 to 60
inches of water. Apparently an electrostatic precipitator has re-
cently been adopted as a control device but no details are available
on its application or performance. Their potential application to
the brass and bronze industry is small however since industrial pre-
cipitators are not common on gas flows below about 20,000 scfm.
Future use of electrostatic precipitators may be facilitated as more
experience and information are gained.
The BBII members account for 40 percent of the industry's total
ingot production. The members completed questionnaires on the air
pollution control equipment in use in the industry. Results are
shown in Table 3.1.
The Environmental Protection Agency selected four plants for
source testing and three were successfully tested. The fourth test
was aborted because plant malfunctions during testing rendered the
test results invalid. All furnaces were controlled with fabric filters
and all showed average emission rates below the standard of 0.022 gr.
dscf. The three emission rates were 0.001, 0.006, and 0.008 gr/
dscf. Results of other tests conducted by Federal, state, and local
agencies showed emission rates to range from 0.002 to 0.017 gr/dscf
from reverberatory furnaces with a size range from 7.5 to 100 tons
and all controlled by fabric filters.
Results of one blast furnace test revealed emissions of 0.013
gr/dscf and there were no visible emissions. No electric furnaces
were source tested.
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
3-8
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Table 3.1 AIR POLLUTION CONTROL EQUIPMENT IN USE IN THE INDUSTRY
Furnace type
Reverberatory
Rotary
Electric
Crucible
Sweat
Cupola
Wire burning
Rotary dryer
Incinerator
Raw material concen-
trator
Slag furnace
Number
2
6
4
7
2
2
3
1
3
5
2
1
1
2
3
1
3
1
2
4
1
1
3
2
4
2
2
2
2
2
1
1
4
1
4
1
1
1
1
1
1
2
1
Approximate capacity, tons
80
75
70
60
30
30
25
12
12
35
15
10
10
5
4
4
2.7"
2-1/2
2
2 (?)
4
3
1/2
1/2
1
3/4
1/2
0.4
3/8
1/4
600 Ib
100 Ib
-
Control Equipment
Baghouse
Baghouse
None
Baghouse
None
Baghouse
None
Baghouse
None
Baghouse
None
Baghouse
None
Baghouse
Baghouse
None
Baghouse
None
Baghouse
None
Baghouse
Baghouse
Baghouse
Scrubber
None
None
None
None
None
None
None
None
None
Afterburner & baghouse
-
-
-
Baghouse
None
Wet collector
Afterburner chamber
-
-
-
-
25
None
Afterburner
Cyclone
•
None
Baghouse
3-9
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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 air dilu-
tion cooling directly ahead of the fabric filter. If this air dilu-
tion damper opens, the bags are protected but the collection effi-
ciency 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 atmos-
phere through the plant's roof monitors.
In the BBII industry survey three of the eight furnaces tested
were reported to be capturing only 80-85, 80-85, and 90-95 percent
of the generated emissions. In the EPA new source performance stan-
dard testing, it is noteworthy that the pouring phases of the heats
were not tested because none of the facilities adequately collected
emissions during this phase of the heat.
One other experience of the BBII testing may be important from
the standpoint of NSPS compliance. Tests on a cupola effluent were
taken prior to and after a baghouse. R-...suits showed that stack
gas volume at the baghouse outlet was two to three times the baghouse
inlet gas volume. The discrepancies were attributed to leaks in the
baghouse structure. The stack gases would have come close to meeting
the NSPS of 0.022 gr/dscf while the efficiency of the baghouse was
between 74 and 85 percent.
In addition to BBII experience, visits to brass and bronze plants
were conducted by the authors. At one plant with three rotary fur-
naces (capacities of 100,000, 50,000, and 6,000 pounds) and two re-
verberatory furnaces (capacities of 3,000 pounds), the 50,000 and
6,000 pound rotary and both reverberatory furnaces were operating.
Blowing air was introduced for 5-10 minutes on the rotary furnaces
to remove concentrations of zine oxide. Emission controls on the
five furnaces consisted of 25,000 scfm fans in the ductwork from the
hoods, connected to a water spray cooling and settling chamber and two
baghouses. Hoods were located over the charging doors and pouring
areas with air being moved by a 25,000 scfm fan and ducted to the
settling chamber. Oxide escaping to the roof was collected through
four dust collectors of 15,000 scfm each serving the roof monitors.
Baghouses were one six-compartment Wheelabrator of 25,000 scfm
and one six-compartment Taylor of 75,000 scfm. Cleaning of baghouses
was accomplished by compartment. A normal cleaning cycle was to
shake compartment bags for 90 seconds, allow 15 seconds for particu-
late to settle with a time delay of 30 seconds before moving to the
3-10
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next compartment of the baghouse. Thus, two minutes and 15 seconds
were required for cleaning one compartment of the baghouse. To clean
one baghouse, 13 minutes and 30 seconds were required (2 min. 15 sec.
x 6 compartments = 13 minutes 30 seconds). At the time of the visit,
one baghouse was off the line for repairs and one of four 15,000 scfm
dust collectors was being used for roof monitor gas cleaning.
Air blowing of the molten metal at one plant was done at 60 psi
while at another plant 30 psi for blowing air was found. Normally
4,000 fpm (approximately 67 fps) was the minimum velocity utilized
to eliminate settling of dust in the ductwork. Fan speeds were not
checked by the plant operators at the facilities vistied; however,
determination of rpm would pose no problem. A more difficult problem
would be that of checking full-load amperage on electrical motors.
At one plant with a 75,000 scfm baghouse, static pressure was -16"
H£0 by the fan, -1" 1^0 in the duct ahead of the baghouse, with only
10" AP on the compartments. In this inspection, a door was found
open on one of the compartments.
Further detail on air pollution control equipment applications
on secondary brass and bronze smelters can be obtained from:
(1) Air Pollution Engineering Manual (8)
(2) Background Information for Proposed New Source Performance
Standards (4)
(3) Proceedings: The User and Fabric Filtration Equipment
Specialty Conference (15)
(4) Sources of Air Pollution and Their Control (19)
(5) Study of Technical and Cost Information for Gas Cleaning
Equipment in the Lime and Secondary Non-Ferrous Metal-
lurgical Industries (13)
(6) Control of Metallurgical and Mineral Dusts and Fumes in
Los Angeles County (1)
(7) Control Techniques for Particulate Air Pollutants (7)
A schematic of the air pollution control system commonly found
in the brass and bronze industry is shown in Figure 3.1.
3-11
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I
M
Ni
COOLING &
SETTLING
CHAMBER
[£) = EMISSION POINTS
REVERBERATORY
FURNACE
-ELECTRIC
CRUCIBLE FURNACE
Figure 3.1 Air pollution control system in the brass and bronze industry
-------
4.0 MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS
4.1 MONITORING THE PROCESS, CONTROL DEVICE, AND EMISSIONS
One purpose of monitoring the operations and maintenance of the
furnaces at secondary smelters is to ensure that the compliance de-
termined 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 brass and bronze smelting are efficient
capture of particulate matter generated by the furnaces and subse-
quent removal of the particulate by abatement equipment. It has
been positively shown that with current air pollution control
technology, particulate emissions from the 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, the new source performance standards for
new or modified secondary brass and bronze ingot production plants
do not require any monitoring equipment on the process, control
equipment, or emissions. However, either specific or general moni-
toring requirements may be in effect under certain State Implementa-
tion Plans, although again, EPA has not promulgated any minimum
requirements for secondary brass and bronze ingot production plants.
4.2 RECORDKEEPING
Since automatic monitoring is not presently required for brass
and bronze plants, recordkeeping on a routine basis becomes ex- T
tremely important to provide a method for the air pollution control
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 al-
though 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, pro-
vides that the Administrator may require the owner or operator of
4-1
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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
later enforcement by EPA.
The facility operator should maintain a description (tabula-
tions and schematic diagrams) of the plant identifying major
equipment items, types of furnaces and controls used for smelting
operations. Within the brass and bronze smelter there are several
different types of furnaces. However, the types of records that
should be maintained are similar. On each furnace, the following
information should be recorded for each heat or batch:
0 Process or charge weight rate and quantity of ingots produced,
to nearest ton;
0 Specification of the ingots, using BBII standards;
0 Date and time heat began and ended, to nearest hour;
0 Fuel consumption, to nearest 100 cubic feet or 10 gallons;
0 Oxygen consumption, to nearest 100 cubic feet;
° Slag handling process and H S emission control;
° Compressed air consumption, to nearest 100 cubic feet;
o Flux identification by constituents and consumption, to nearest
100 pounds;
0 Gas flow system data, power requirements, exhaust flow rate;
° Malfunctions; and
° 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 continuous the above
information should be recorded at the end of each shift or three times
daily.
4-2
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The exhaust gas collection, venting and emission control system
should be described (diagrammed) in detail. The sequence of con-
trols, types of controls (afterburners, cooling system, particulate
material collectors, baghouses, filter types) should be outlined
and described using quantitative parameters.
For each control component or system checkpoint, information
recorded, at the intervals indicated, should include:
0 Quantity of collected dust and fume, by month to nearest ton;
o Volumetric flow on inlet to collector, on first of each month;
o Volumetric flow on outlet from collector, on first of each month;
o Pressure drop across each section of the collector after
cleaning, on first of each month;
o Static pressure from fan .through collector, gas cooling system
and ductwork to collecting hood, on first of each month;
0 Fan speed, on first of each month;
o Capture velocity on hood faces, on first of each month;
o Excess air data for gas exhaust system and results of any
Monoxer (CO detector) and Fyrite (0? detector) analyzer surveys;
o Inspections, maintenance and repairs, by month; and
0 Malfunctions.
The purpose of having the above information kept on the air pollu-
tion 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 owner 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 plajit operators
should record and report complaints and should indicate the probable
cause of the problem.
4-3
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4.3 REPORTING REQUIREMENTS
The proposed 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
more frequent basis. As will be described later, the Federal require-
ment 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 main-
tain a file of all recorded information required by the regulations
for at least two years after the dates of such information.
Suggestions for formats and contents of inspectors worksheets are
indicated in Tables 6.1, 6.2, 6.3 and 6.4 at the end of Section 6.0.
For further detail on monitoring, recordkeeping, and reporting
requirements, please refer to:
0 Federal Register, October 6, 1975, page 46240 (10);
0 Federal Register, October 6, 1975, page 46250 (10);
0 Guideline for the Selection and Operation of a Continuous
Monitoring System for Continuous Emissions (12).
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 extent
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."
At another part, Section 60.7 states, "A written report of excess
emissions as defined in applicable subparts shall be submitted 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 completion of each period of
excess emissions. Periods of excess emissions due to startup, shut-
down, 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 following the end of the calendar
quarter. Reports are not required for any quarter unless there have
been periods of excessive emissions."
The above provisions presently apply only to three furnace types
at new brass and bronze ingot production plants. 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 mal-
function which excluded several common causes of excessive emissions.
The wording is as follows: "Malfunction means any sudden and unavoid-
able 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 considered malfunctions."
Suggestions for format and content of recordkeeping on start-
up and shutdown operations and malfunctions, are indicated in
Table 6.3 at the end of Section 6.0-
5-1
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5.1 STARTUP
Startup operations are common practice, occurring daily, in the
brass and bronze industry. Since almost all of the furnaces are batch
operations, startup of the furnaces poses no particular problem from
the emission point of view. When a furnace is being heated up, only
fuel is being burned. Even a blast furnace which is a continuous
operation starts by heating up the furnace and it typically takes
about four hours to reach normal operating conditions. The reverber-
atory furnace is a continuous operation also but it may be somewhat
cyclic depending on the rate of scrap addition and the rate of copper
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. Thus, for a furnace
with a 24-hour cycle time, it is conceivable that several hours could
pass with excessive emissions before correction.
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 conceivably
be manifested by pouring ingots at higher temperature than necessary
but would generally be due to insufficient draft on the collection
hoods which could be due to:
0 slippage on fan belts
° high pressure drop in the baghouse which in turn may be due to:
. improper compressed air supply
. improper timer operation
. improper solenoid valve operation
. leaky airlock or dust discharge valve
. moisture blinded bags
. dust in clean air plenum
. static electricity
5-2
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. incorrectly installed blow tubes'
. collector overloaded from too much air
0 fan rotating in the wrong direction;
o leaking ductwork, access doors, explosion doors or discharge
valve on air lock;
0 clogged ductwork or faulty damper;
° duct size improper; and
0 higher 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:
. addition to the furnace charge of scrap with high amounts of
aluminum, magnesium or other low boiling point alloys;
. addition to the blast or reverberatory furnace charge of scrap
with large amounts of oil or other combustibles;
. blowing the molten b'ath at too high a rate with compressed air;
. firing at excessive rates especially with use of oxygen;
. adding large quantities of zinc late in the refining process;
. hardened or insufficient slag cover in the reverberatory furnace;
and
. slips in the blast furnace following bridging.
The second category of malfunctions would result from control
equipment failures. The more important examples would include:
o short bag life with frequent failures (ruptures) which in turn
could be due to :
. high operating temperatures
. low dew point gas conditions with condensation of SC>2 and S0_
. acidic or basic dust that attacks fabric
. a high filtering velocity, air to cloth ratio; or high AP
. excessive bag cleaning or shaking
. dust in clean air plenum from previous bag failures or from
bridging of dust in the hopper cleanout
° poor water distribution due to buildup of mud;
° pump failure;
o motor failure;
5-3
-------
0 fan unbalanced due to particulate buildup; and
° clogged or worn nozzles
For further information on baghouse design, operation, and
maintenance please refer to the following reference materials:
0 Appendices to Handbook of Fabric Filter Technology (3)
0 Proceedings: The User and Fabric Filtration Equipment Specialty
Conference (15)
0 Air Pollution Engineering Manual (8)
° Air Pollution Aspects of Brass and Bronze Smelting and Refining
Industry (14)
° Systems Study of Scrubbers (20)
5-4
-------
6.0 INSPECTION PROCEDURES
6.1 CONDUCT OF INSPECTION
Before an air pollution control official inspects 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 in-
spection:
o Determine the scope of the facility's operation.
o Determine the applicability of standards.
° Inspect records and/or monitoring equipment.
o Evaluate visible emissions (Appendix B).
o Determine if a stack test is required.
o Conduct or observe stack tests or other field tests.
o Evaluate maintenance and operation of equipment.
° Establish compliance or non-compliance with compliance schedules.
o Investigate feasibility of various control methods.
o Investigate compliance with emergency episode plans.
Section 114(a)(2) of the Clean Air Act 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.
Such authority may be delegated to a state and be exercised by a
state official.
In preparing for the inspection, the control official should:
0 Review the literature on the subject industry's process descrip-
tions, inspection points, and control equipment.
6-1
-------
0 Review the NEDS file or osher plant file for details of processes
and control equipment in use including plot plan.
0 Review applicable standards (Federal, state and local).
0 Review enforcement history on the plant.
. administrative and court actions
. compliance schedules
. monitoring and recordkeeping requirements
. previous inspections
. section 115 abatement actions
. waiver, notifications, quarterly reports, registration (NSPS
and NESHAPS)
0 Finalize objectives.
0 (If appropriate) provide advance notice.
0 Obtain credentials and business cards (EPA has a procedure for
generating the issuance and control of credentials)*
0 (If desired) obtain for handout a supply of applicable statutes
and regulatory authority as well as EPA or state literature
explaining the enforcement program.
0 Obtain or develop a supply of inspection checklists.
0 Obtain personal safety equipment. (A source owner or operator
has no responsibility to supply EPA inspectors with safety
equipment.)
. hard hat
. safety glasses or goggles
. steel-toed shoes
. respirator
. gloves
. coveralls
0 Obtain necessary inspection equipment.
. tape measure
. flashlight
. thermometer and gauze
. manometer (flex-tube)
. inclined manometer
. RPM indicator
6-2
-------
. velometer
. camera
. Fyrite combustion analyzer - CL, CO, CO
. smoke spot analyzer
6.2 INSPECTION CHECKLIST
After preparing for the inspection by reading appropriate
information 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 observation prior to
the appointment.
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 inspector
should not sign the waiver forms or "visitor releases" prior to
entry. The inspector has specific legal authority (Federal or
state) for right of entry and signing such forms may adversely
affect his Federal or state insurance or survivor 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:
0 The purpose of the inspection (NSPS, SIP, NESHAPS).
0 The authority for the inspection (113, 114, State law, etc.).
0 The agency's organization and responsibilities.
0 Recent history of legislative and enforcement activity
affecting the subject industry and specific plant.
0 The scope, timing, and organization of the inspection.
0 Information and records to be examined (self incrimination -
see Appendix)-
0 The treatment of confidential data (trade secrets - see Appendix).
0 Possible measurements to be made.
6-3
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Possible followup activity including:
. future inspections
. section 114 letter
. stack tests
. notice of violation
After the preliminaries are completed, the control official
should request the name, title and address of the appropriate
company officer for official contact on future inspections and
correspondence.
Next, he should request a brief summary of the plant's produc-
tion facilities and air pollution control equipment. This informa-
tion 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 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 shut-
down or malfunctioning equipment. The schedule for returning shut-
down equipment to operation should be indicated. The malfunctioning
equipment should be shutdown if such malfunctioning adversely affects
emission rates to the atmosphere 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 plat-
forms, 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 control official
should note whether the process, furnace, etc. is running 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 in-
formation from his records that will allow the inspector to complete
the process, control equipment and malfunction worksheets which
are appended. Records for several heats on each furnace prior to
the visit will generally suffice to give a baseline of the plant's
6-4
-------
operations. With such information, comparisons can be made with
future operations, with past performance test and design operating
conditions, and with operations at the time of the current inspec-
tion. In the event the company identified certain data confidential,
a company official must make a request for such confidentiality in
writing to EPA.
Next, the inspector 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, and pressure
drops, hood capture velocities, 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,
valves and dampers, fan and drive belts, collection hoppers, etc.
The inspector should take note of those conditions cited in Section
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 per-
mance 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 main-
tenance and housekeeping is a violation of NSPS regulation 60.lid.
In the first case of new brass and bronze ingot production
facilities subject to the NSPS, the only possible violations which
could be cited are opacity violations or failure to record or report
malfunctions. The mass loading limitation on reverberatory furnaces
could not be determined without isokinetic particulate tests. On
existing facilities state opacity limitations or reporting require-
ments for upset conditions would seem to be the only possible
6-5
-------
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 emis-
sions 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 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 compliance.
Section 113 of the Act should be cited. At the conclusion of the
designated time period for compliance, a followup inspection should
be made to verify conformance with the recommendations and applicable
standards.
For further information on inspection procedures refer to:
o Field Surveillance and Enforcement Guide for Primary Metallurgical
Industries (11)
o Workshop on Stationary Source Inspections (21)
° Air Pollution Control Field Operations Manual (17)
o S 12. - General Policy on the Use of Section 114 Authority for
Enforcement Purposes (Appendix C).
6-6
-------
Table 6.1
Company
Street Address
BRASS AMD BRONZE INDUSTRY
INSPECTORS WORKSHEET
Part I - Process Data
From:
To:
Dates covered
Furnace-Company Designation
City
State
Furnace Identification No. or NEDS No.
Official Completing Form
Furnace Type
Title of Official
Furnace Rated Capacity (Charge Rate)
Heat
lumber
HEAT
Charge
hours
' PERIOD
Refine
hours
Pour
hours
Total
hours
Copper
Containing
Material/tons
RAW MATE
1 Zinc
Content %
of Charge
RIALS
Fuel
106 btu
Dxygen
ft3
Air
ft3
Tons
PRODUCTION
Specification-%
Cu Sn Pb Zn Fe Al Ni Si Mn
ON
I
-J
Date
Inspector
-------
Table 6.2
Company
Street Address
BRASS AND BRONZE INDUSTRY
INSPECTORS WORKSHEET
Fart II - Control Equipment Data
From:
Dates covered
State Identification No. or NEDS No.
City
State
Control Equipment Co. Designation
Official Completing Form
Control Equipment Type
Title of Official
I
CO
Quantity of dust collected
Gas flow rate @ baghouse inlet
Cas flow rate @ baghouse outlet
Temperature @ baghouse inlet
tons
acfm
acfm
Pressure drop across each section of clean baghouse 1_
Static pressure in collection system
stack
before fan
baghouse outlet
baghouse inlet
"H20
"H20
"H20
before radiant coolers
before water sprays
duct after hood
Fan speed
Face velocity of hoods
over furnace _
charging doors _
pouring spout _
rpm
f pm
f pra
fpm
"H20
"H20
"H20
Remarks concerning inspections, maintenance and repairs; i.e., baghouse bag replacement, shaking circumstances, etc.
Date
Inspector
-------
Company
Street Address
Table 6.3
BRASS AND BRONZE INDUSTRY
INSPECTORS WORKSHEET
Part III - Startup, Shutdown, and
Malfunction
From:
To.
Dates Covered
Furnace Identification
City
State
Official Completing Form
Title of Official
Excess emissions occurred
Began
Ended
date
date
time
time
Were excess emissions due to startup, shutdown, or
malfunction
Describe the magnitude of the excess emissions
I
VO
Detailed explanation of reasons for excess emlsslons_
Corrective action taken to halt excess emissions
Preventatlve measures adopted to prevent recurrence
Further comments
Date
Inspector
-------
Table 6.4
BRASS AND BRONZE INDUSTRY
INSPECTORS WORKSHEET
Part IV - General Observations
From: To:
Company Dates Covered
Street Address
City State
Official Providing Information
Title of Official
(-^ Process
I
I—' Charging procedure - weights, frequency
O
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
-------
7.0 PERFORMANCE TEST
The Code of Federal Regulations, Title 40, Part 60 provide in
Section 60.8 for performance tests of new brass and bronze facilities.
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 furnaces have a mass emission
rate which requires performance testing; electric and blast 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 performance
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
normally encountered conditions that create the maximum emission
rate. The operating conditions that should be specified for the
tests are as follows:
0 The production rate should be the maximum rated capacity of
the furnace;
0 The period of the heat should be the minimum possible to
achieve the specification of the melt;
0 The specification of the ingots to be produced should contain
either a very high or very low percentage of zinc;
0 If oxygen is used at all, the consumption rate should be the
maximum rate anticipated;
0 If compressed air is used at all, the consumption rate should
be the maximum rate anticipated;
7-1
-------
The fuel consumption rate should be the maximum rate anti-
cipated;
0 The flux addition rate should provide a slag and flux cover
depth typical of the operation to be tested; and
0 The pouring temperature should be the maximum anticipated
for the metal alloy being produced.
7.2 PROCESS OBSERVATIONS
Since a large reverberatory furnace will require several hours
(on the order of 12-48) to produce one heat of brass or bronze,
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 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 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 total charge, and thus the total production rate will affect
emissions. Since most of the emissions are due to zinc oxidation, a
furnace half full will have only one-half the mass rate of emission of
zinc oxide. Yet the fuel consumption rate and certainly the air deli-
vered to the baghouse will be nearly the same in both cases; thus, the
grain loading will be reduced if the production is reduced. Overall,
however, the total mass of charge is probably less a determinate of
emissions than percent volatiles in charge, temperature, and production
rate.
The duration of the heat is important in that the quantity of
impurities to be removed 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. In the case of high
zinc charges, a longer heat allows more zinc to boil off. Thus, there
is a trade off involved in the total effect of longer duration heats.
The approximate zinc content of the scrap which is charged
should be noted and the zinc content of the ingots should be noted.
If the charge is high in zinc and the final product is low in zinc,
then more blowing with compressed air will be necessary to remove
7-2
-------
the zinc and most of this material will go to the baghouse. In
the case where zinc is high in the finished ingots, emissions will
be much greater during pouring of the ingots.
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 is important since the slag
cover hinders the loss of low boiling point metals and impurities
to the atmosphere. Slag covers are usually at least 1/4" to 1/2"
thick. A thicker layer will reduce emissions but will tend to
insulate the charge from the burners. Thus, 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 operation, 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 equip-
ment 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.reverberatory furnace. Whatever final
procedure is determined for operating the control equipment, the
inspector should note all conditions and should complete the
Inspection Checklist Forms relating to the control equipment.
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 meet CFR, and that the smelter is
run at representative performance during all. sampling runs. A
7-3
-------
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 to 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.
(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. The 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 identification labels
7-4
-------
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 particu-
lates have been removed.
(10) Observe gas analysis procedure for determining CO--
Technicians 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 accuracy 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 determining
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
-------
Table 7.1
NSPS INSPECTION CHECKLIST FOR SECONDARY BRASS AND BRONZE SMELTERS
DURING PERFORMANCE TEST
Facility Name .
Facility Address
Name of Plant Contact
Source Code Number
Unit Identification (To be tested)
Design Input Capacity
Initial Start-up Date
Test Date
tons/day
A. FACILITY DATA
Type
Charging Method
Control Devices
Furnace
Other
Batch
Fabric Collector
Scrubber
Other
No. of Furnaces
Specify
Continuous
Specify Type
Specify Type
Operating Schedule
hrs/day
days/wk
wks/yr
B. OPERATING PARAMETERS
Data to Obtain During Performance Test'
Parameter
Clock Time
Charge Capacity
Charge Rate
Charge Copper Content
Product Copper Content
Period of Heat
Oxygen Rate
Compressed Air Rate
Fuel Rate
Pouring Temperature
Data should be recorded every 20 minutes
7-6
-------
Table 7.1 (.continued). NSPS INSPECTION CHECKLIST FOR SECONDARY
BRASS AND BRONZE SMELTERS DURING PERFORMANCE TEST
C. PRETEST DATA (OBTAIN FROM TEST TEAM FIELD LEADER)
Test Company
Field Leader
2
Duct Dimensions in. x in. ; Area ft
Nearest Upstream Obstruction ft
Nearest Downstream Obstruction ft
No. of Sampling Ports
No. of Sampling Points
No. of Sampling Points Required From 40 CFR 60
D. PARTICULATE PERFORMANCE TEST
Test No. Start Time Finish Time
Preliminary Traverse Run (Method 1)
Chosen Nozzle Diameter in.
Train Leak Check Yes
Opacity Readings Taken Yes
Moisture Determination (Method 4)
Percent Moisture „
ml Collected/Gas Volume ml ft
(or wet/dry bulb readings)
Combustion Gas Analyzer 00 %
C00 %
L '"
Dry Gas Meter Reading Before Test ft at
3
Dry Gas Meter Reading After Test ft at
3
Volume Sampled ft
7-7
No
No
(time
(time
-------
Table 7,1 (continued). NSPS INSPECTION CHECKLIST FOR SECONDARY
BRASS AND BRONZE SMELTERS DURING PERFORMANCE TEST
D. PARTICULATE PERFORMANCE TEST (continued)
Test Duration minutes
Average Meter Orifice Pressure Drop
Average Duct Temperature °F
Velocity Head at Sampling Point
Meter H@
Repetition Start Time
Repetition Finish Time
E. CLEAN-UP PROCEDURE
Filter Condition
Probe Status
Glass Connectors
Clean-up Sample Spillage
Dry
Unbroken
Unbroken
None
Sample Bottle Identification Yes
inches
inches H~0
Acetone Blank Taken
Yes
Wet
Broken
Broken
Slight Major
No
No
7-8
-------
8.0 REFERENCES
(1) Allen, Glenn L. "Control of Metallurgical and Mineral Dusts
and Fumes in Los Angeles County, California." U.S. Depart-
ment of the Interior, Washington, D.C. April 1952.
(2) "American Smelting and Refining Company, San Francisco, Cali-
fornia," Engineering-Science, Inc., Washington, D.C. Decem-
ber 1971.
(3) Appendices to Handbook of Fabric Filter Technology, Vol II.
GCA Corporation for NAPCA Division of Process Control Engi-
neering. Research Triangle Park, N.C., December 1970.
(4) Background Information for Proposed New Source Performance
Standards, Vol. 1, Main Text. Environmental Protection
Agency, Research Triangle Park, N.C., June 1.973.
(5) "Bladensburg Metals, Bladensburg, Md." Engineering-Science,
Inc., Washington, D.C. 1971.
(6) Code of Federal Regulations. Title 40, Part 51 Revised as of
July 1, 1976, General Services Administration, Washington,
D.C. 1976.
(7) "Control Techniques for Particulate Air Pollutants," U.S. De-
partment of Health, Education, and Welfare, Washington, D.C.
January 1969.
(8) "Air Pollution Engineering Manual," U.S. Department of Health,
Education, and Welfare, Cincinnati, Ohio. 1967.
(9) Emission Testing Compliance Manual EPA 68-02-0237. Environ-
.mental Protection Agency, Washington, D.C. 1974.
(10) • Federal Register, Vol. 40. No. 194. General Services Adminis-
tration, Washington, D.C. October 6, 1975.
(11) Field Surveillance and Enforcement Guide for Primary Metallur-
gical Industries. Engineering-Science, Inc., Washington,
D.C., December 1973.
8-1
-------
(12) Guideline for the Selection and Operation of a Continuous Mon-
itoring System for Continuous Emissions. Division of Sta-
tionary Source Enforcement, Environmental Protection Agency,
Washington, D.C. 1974.
(13) Hardison, L.C. "Study of Technical and Cost Information for Gas
Cleaning Equipment in the Lime and Secondary Non-Ferrous
Metallurgical Industries," Industrial Gas Cleaning Institute,
New York. December 1970.
(14) Herrick, Robert A. "Air Pollution Aspects of Brass and Bronze
Smelting and Refining Industry," U.S. Department of Health,
Education, and Welfare, Raleigh, North Carolina. November
1969.
(15) Proceedings: The User and Fabric Filtration Equipment Specialty
Conference. Edited by the Air Pollution Control Association.
Pittsburgh, Pa. October 1973.
(16) "R.L. Lavin & Sons, Inc., Chicago, Illinois," Engineering-
Science, Inc., Washington, D.C. March 1972.
(17) Weisburd, Melvin I. "Air Pollution Control Field Operations
Manual," U.S. Department of Health, Education, and Welfare,
Washington, D.C. December 1962.
(18) "West Coast Smelting and Refining, Chino, California," Engi-
neering-Science, Inc., Washington, D.C. December 1971.
(19) Stern, A. C. "Air Pollution, Volume III, Sources of Air Pollu-
tion and Their Control." Academic Press, N.Y. 1968.
(20) Calvert, S. "Systems Study of Scrubbers," Environmental Protec-
tion Agency, Research Triangle Park, N.C. 1972.
(21) Workshop on Stationary Source Enforcement, Engineering-Science,
Inc., Washington, D.C. December 1974.
3-2
-------
APPENDICES
-------
APPENDIX A
STANDARDS OF PERFORMANCE FOR
SECONDARY BRASS AND BRONZE INGOT
PRODUCTION PLANTS
A-l
-------
Chapter 1 - Environmental Protection Agency
SUBCHAPTER C - AIR PROGRAMS
PART 60 - STANDARDS OF PERFORMANCE
FOR NEW STATIONARY SOURCES
Subpart M - Standards of Performance
for Secondary Brass and Bronze Ingot Production Plants
§60.130 Applicability and designation of affected facility.
The provisions of this subpart are applicable to the following
affected facilities in secondary brass or bronze ingot production
plants: Reverberatory and electric furnaces of 1,000 kg (2,205 Ib)
or greater production capacity and blast (cupola) furnaces of 250
kg/hr (550 Ib/hr) or greater production capacity.
§60.131 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) "Brass or bronze" means any metal alloy containing copper
as its predominant constituent, and "lesser amounts of zinc, tin,
lead, or other metals.
(b) "Reverberatory furnace" includes the following types of
reverberatory furnaces: Stationary, rotating, rocking, and tilting.
(c) "Electric furnace" means any furnace which uses electricity
to produce over 50 percent of the heat required in the production of
refined brass or bronze.
(d) "Blast furnace" means any furnace used to recover metal from
slag.
A-2
-------
§ 60.132 Standard for Particulate Matter
(a) On and after the date on which the performance test re-
quired 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 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 re-
quired 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 any blast (cupola) or electric
furnace any gases which exhibit 10 percent opacity or greater.
§ 60.133 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 § 60.132 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 120 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. Particulate matter sampling shall be con-
ducted during representative periods of charging and refining, but
not during pouring of the heat.
A-3
-------
APPENDIX B
METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FOR STATIONARY SOURCES
B-l
-------
METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FROM STATIONARY SOURCES
METHOD 9 VISUAL DETERMINATION O? THE
OPACITY OP EMISSIONS JTIOM STATIONARY
SOTJBCE3 -
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 ot
plums opacity by qualified observers. The
method Includes procedures for the training
and certification of observers, and procedures
to be used in the field for determination, of
pluma 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 no
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 steam
plume; and angle of the observer with re-
spect to a plume emitted from a rectangular
stack with a large length to width ratio. The
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 la viewed.
Thesa 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 is 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-
ing 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 qualified observers while read-
Ing plumes under contrasting conditions and
using the procedures set forth In this
method. The results of these studies (field
trials) which Involve a total of 769 sets of
25 readings each are as follows:
(1) For black plumes (133 sets at a smoke
generator), 100 percent of the sets were
read with a positive error1 of less than 7.5
percent opacity; 99 percent were read with
a positive error of less than 5 percent opacity.
(2) For white plumes (170 sets at a smoke
generator, 168 sets at a coal-fired power plant,
298 sets at a sulfurlc 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.
The positive observational error associated
with an average of twenty-five readings la
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 qualified observer.
1.2 Applicability. This method- la appli-
cable for the determination of the opacity
of emissions from stationary sources pur-
suant to 3 60.11 (b) and for qualifying ob-
servers for visually determining opacity of
emissions.
2, Procedures. The 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 qualified 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, nonclrcular 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 are 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 set of multi-
ple stacks (e.g. stub stacks on baghouses).
22 Field records. The observer shall re-
cord the name of the plant, emission loca-
tion, type facility, observer's name 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 plums background'are recorded
1 For a set, positive error=average opacity
determined by observers' 25 observations-
average opacity determined from transmis-
someter's 25 recordings.
B-2
-------
on a field data sheet at the time opacity read-
ings are initiated and completed.
2.3 Observations. Opacity observations
shall be made at the point of greatest opacity
in that portion of the plume where con*
densed water vapor Is not present. The ob-
server shall not look continuously at the
plume, but Instead shall observe the plume
momentarily at 15-second Intervals.
2.3.1 Attached steam plumes. When con-
densed water vapor Is present within the
plume as It emerges from the emission out-
let, opacity observations shall be made be-
yond the point In the plume at which con-
densed water vapor Is no longer visible. The
observer shall record the approximate dis-
tance from the emission outlet to the point
in the plume at which the observations are
made.
233 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 3
percent at 15-second Intervals on an ob-
servational record sheet. (See Figure 9-3 for
an example.) A minimum of 24 observations
shall be recorded. Each momentary observa-
tion recorded shall be deemed to represent
the average opacity of emissions for a 18-
second period.
2.5 Data Reduction. Opacity shall 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 of 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. If 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
•certification as a qualified observer, a can-
didate must be tested and demonstrate the
•ability to assign opacity readings in 3 percent
increments to 25 different black plumes and
38 different white plumes, with an error
not to exceed IS 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 3.2
shall be equipped with a smoke meter which
meets the requirements of paragraph 3.3.
The certification shall be valid for a period
of 6 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 SO plumes—23 black plumes
and 25 white plumes—generated by a smoke
generator. Plumes within each set of 25 black
and 28 white runs shall be presented In ran-
dom order. The candidate assigns an opacity
value to each plums and records his obser-
vation on a suitable form. At the completion
of each run of SO readings, the score of the
candidate Is determined. If a candidate falls
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
smoke 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 In Table 9-1.
The smoke meter shall be calibrated as pre-
scribed in paragraph 3 J.I prior to the con-
duct 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
be 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 8 months, whichever occurs
first.
TABLS 9-1 SMOKE METEE DESIGN AND
I SPECIHCAT10N3
Specification
Incandescent lamp
operated at nominal
rated voltage.
Photoplc (daylight
spectral response of
the human eye—
reference 4.3).
15* maximum total
angle.
15* ma.T
-------
simulated opacity of 0 percent and 100 per-
cent. When stable response at o percent or
100 percent is noted, the 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 may 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
metar design and performance are to be
evaluated as follows:
3.3.2.1 Light source. Verify from manu-
facturer's data and from voltage measure-
ments made at the lamp, as installed, that
the lamp Is operated within :±5 percent of
the nominal rated voltage.
3.3.2.2 Spectral response of photocell.
Verify from manufacturer's data that the
photocell has a photonic response; I.e., the
spectral sensitivity of the cell 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 esceed 15'. The total
angle of view may be calculated from: #=2
tan-1 d/2L, where 0=total angle of view;
d=the sum of the photocell diameter-)-the
diameter of the limiting aperture; and
L = the distance from the photocell to the
limiting aperture. The limiting aperture Is
the point In the path between the photocell
and the smoke plume where the angle of
view is most restricted. In smoke generator
smoke meters this la normally an oriflco
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:
0=2 tan-1 d/2L, where fc 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.
3.3.2.5 Calibration error. Using neutral-
density filters of known opacity, checK the
error between the actual response and the
theoretical linear response of the smoke
meter. This check is accomplished by first
calibrating the smoke meter according to
3.3.1 and then Inserting a series of three
neutral-density filters of nominal opacity of
20, 50, and 75 percent In the smoke met«r
pathlength. Filters callbarted within ±2 per-
cent shall be used. Care should be taken
when Inserting the filters to prevent stray
light from affecting the meter. Make a total
of five nonconsecuttvd readings for each
filter. The maximum 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 la 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, Melvln I., Field Operations
and Enforcement Manual for Air, U.S. Envi-
ronmental Protection Agency, Research Tri-
angle Park, N.C., AFTD-1100, August 1972.
pp. 4.1-4.38.
4.3 Condon, B. tr., and Odlshaw, H., Hand-
book of Physics, McGraw-Hill Co., IT.T.. N.Y.,
1958, Table 3-1, p. 8-52.
B-4
-------
Ttjure 9-t
Menu) or VISUAL DETERMINATION or OPACITY
COMMIT
10CATIOM
AST
BATE
TWS FACILITY
GOtmOL DEVICE
HODM OF OBSERVATION.
OBSERVES
OBSERVER CEXTinCATIOK DATE
OBSERVER AFFILIATION ~
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
Xecord the following Information prior to and upon completion of observations it each source.
If observation! art mads over an extended period of tine, additional recordings should be siada
•a applicable.
CWCK TIME IMTIAt _'_».m. ' TIJIAI, _!_ a.n.
CSSER.VEX LOCATION
filatance to Dischara*
Direction froo Discharge
fielght of Observation Point
SACXCROUHD DESCRIPTION
BATHER CONDITIONS
Vlnd Direction
Mnd Speed
Aabiene Temperature
SKY CONDITIONS (clear,
overcast, ^clouds, etc.)
nVMi DESCRIPTION
Color
Distance Visible
MINUTES OF NONCOKFLIANCg
/
^~
-
r
-
COMPANY
LOCATION
TEST HUHBHT
DATE
FIGURE 9-2 OBSERVATION RECORD
OBSERVER
PAGE
OF
TYPE FACILITY
POINT OF EMISSTT5RT
Hr.
Min.
0
i
2
3
u
5
6
7
8
9
' 10
11
12
13
11*
IS
16
17
l£l
19
20
' 21
22
' 23
2<*
25
2G
•27
28
29
Seconds
0
15
30
^ • •
45
STEAM PLUME
(check if aoDlicable)
Attached
Detached
•
COMMENTS
.
•
.
B-5
-------
FIGURE 9-2 OBSERVATION RECORD PAGE OF
(Cont.)
COMPANY
LOCATION
TEST NUMBEF
DATE i
OBSERVER
TYPE FACILITY ~
POINT OF EMISSlURT
Hr.
Min,
30
31 •
32
33
3t*
35
36
37
38
39
1*0
1*1
1*2
1*3
It If
US
46
1*7
1*8
1*9
50
51"
52
' '53' '
5"t
55
56
57
58
59
Seconds
0
lb
30
45
STEAM PLUME
(check if applicable)
Attached
/
•
Detached
. . . . ; .
COMMENTS
• '.N
v
B-6
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APPENDIX C
S 12. - GENERAL POLICY ON THE USE
OF SECTION 114 AUTHORITY FOR ENFORCEMENT PURPOSES
C-l
-------
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) (1) 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
-------
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 s-tandard 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
EPA. 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)(1) 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 Release'".
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
-------
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.
(b) 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 and 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
-------
(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
-------
APPENDIX E
BRASS AND BRONZE INGOT INSTITUTE
LIST OF STANDARD COPPER BASE ALLOYS
E-l
-------
Ingot
No.
101
115
120
123
125
Casting
Method
Centrifugal
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Investment
Precision
Sand
Centrifugal
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Sand
Sand
CDA
842
842
842
842
836
836
836
836
836
836
838
838
838
838
844
844
844
844
845
ASTM
-
B505
B30
-
B271
B505
B30
-
-
B62
B584
(formerly
B145)
B271
B505
B30
B584
(formerly
B145)
B271
B505
B30
B584
(formerly
B145)
-
ASME
-
-
-
-
SB271
-
-
-
-
3B62
-
-
-
-
-
-
-
SAE
-
-
-
-
CAS 3 6
CAS 36
-
CA836
-
CA836
-
-
-
"
-
-
-
-
AMS
-
-
-
-
4855
4855
-
-
-
4855
-
-
-
"
-
-
-
"
-
Federal
QQ-C-390
QQ-C-390
-
QQ-C-390
QQ-C-390
QQ-C-390
-
-
-
QQ-C-390
QQ-C-390
QQ-C-390
-
QQ-C-390
-
QQ-C-390
-
QQ-C-390
-
Military
-
-
-
-
MIL-C-15345,
Alloy 1
-
-
MIL-C-22087,
Comp . 2
MIL-C-11866 ,
Comp. 25
MIL-C-22229,
Comp . 2
-
-
-
"
-
-
-
"
-
E-2
-------
Ingot
No.
130
131
194
197
199
200N
205
Casting
Method
Centrifugal
Continuous
Ingot
Sand
Sand
Centrifugal
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Sand
-
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Sand
CDA
8/1 8
848
848
848
833
913
913
913
913
910
910
910
910
909
925
925
925
907
907
907
907
ASTM
B271
B505
B30
B584
(formerly
B-145)
-
-
B505
B30
B22
-
B505
B30
-
-
B505
B30
—
-
B505
B30
—
ASME
-
-
-
™
-
-
-
-
-
-
-
-
-
-
-
-
—
-
-
-
—
SAE
-
-
-
™
-
-
-
-
-
-
-
-
-
-
-
-
CA925
-
-
-
CA907
AMS
-
-
-
™
-
7322
7322
-
7322
-
-
-
-
-
-
-
—
-
-
-
*
Federal
-
-
-
™
-
QQ-C-390
QQ-C-390
-
QQ-C-390
QQ-C-390
QQ-C-390
-
Q-C-390
-
-
-
—
-
QQ-C-390
-
"~
Military
-
-
-
™
-
-
-
-
-
-
-
-
-
-
-
-
—
-
-
-
—
E-3
-------
Ingot
No,
205N
206
210
215
225
Casting
Method
Centrifugal
Continuous
Sand
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Sand
Sand
Centrifugal
Continuous
Ingot
Investment
Precision
Sand
CDA
916
916
916
927
927
927
905
905
905
905
926
903
903
903
903
903
903
ASTM
B427
-
B472
B505
B30
-
B271
B22
B505
B30
B22
B584
(formerly
B143)
-
B271
B505
B30
-
-
B5&
(formerly
B143)
ASME
-
-
-
-
-
_
-
_
-
_
-
-
-
-
_
SAE
-
-
CA92.7
CA927
CA905
CA905
-
CA905
-
CA903
CA903 •
CA903
CA903
CA903
CA903
\MS
-
-
-
-
4845
4845
-
4845
-
_
-
-
-
-
_
Federal
QQ-C-390
-
-
-
-
QQ390
QQ-C-390
-
QQ-C-390
-
QQ-C-390
QQ 390
-
-
-
_
Military
MIL-C-15345,
Alloy 23
-
-
-
—
-
-
-
-
-
MIL-C-15345,
Alloy 8
-
-
MIL-C-22087,
Comp . 3
MIL-C-11866,
Comp. 26
MIL-C-22229,
Comp. 1
E-4
-------
Ingot
No.
230
242
245
255
295
305
Cast lag
Method
Centrifugal
Continuous
Ingot
Sand
-
Centrifugal
Continuous
Ingot
Permanent
Mold
Sand
Sand
Continuous
Ingot
Sand
Centrifugal
Continuous
Ingot
Sand
CDA
923
923
923
923
902
922
922
922
922
922
-
928
928
928
937
937
937
937
ASTM
B271
B505
B30
B584
(formerly
B143)
-
B271
B505
B30
-
B61
B584
(formerly
B143)
-
B505
B30
—
B271
B505
B30
B584
(formerly
B144)
ASME
-
-
-
"
-
SB271
-
-
-
SB61
-
-
-
—
SB271
-
-
SAE
CA923
CA923
-
CA923
-
CA922
CA922
-
CA922
CA922
-
. -
-
—
CA937
CA937
-
CA937
AMS
-
-
-
"
-
-
-
-
-
-
-
-
—
4842
-
-
4842
Federal
QQ-C-390
QQ390
-
QQ-C-390
-
QQ-C-390
QQ-C-390
-
-
QQ-C-390
-
-
-
—
-
QQ-C-390
-
QQ-C-390
Military
MIL-B-15345,
Alloy 10
-
-
"
-
MIL-C-15345,
Alloy 9
MIL-B-16541
MIL-B-16541
-
-
MIL-B-16541
-
~" \
-
-
-
-
-
E-5
-------
Ingot
No.
311
312
315
319
321
Casting
No.
Centrifugal
Continuous
Ingot
Investment
Sand
Sand
Centrifugal
Continuous
Ingot
Permanent
Mold
Sand
Centrifugal
Continuous
Ingot
Sand
Sand
CDA
934
934
934
934
934
944
932
932
932
932
932
938
938
938
938
945
ASTM
-
B505
-
-
—
B66
B271
B505
' B30
_
B584
(formerly
B144)
B271
B505
B30
B66
B584
(formerly
B144)
B66
ASME
-
-
-
-
••
-
-
-
-
_
—
-
-
-
-
-
SAE
-
- -
-
-
—
-
CA932
CA932
-
CA932
CA932
-
-
-
-
-
AMS
-
-
-
-
-
-
-
-
-
_
—
-
-
-
-
-
Federal
QQ-C-390
QQ-C-390
-
-
QQ-C-390
-
QQ-C-390
QQ-C-390
-
_
QQ-C-390
QQ-C-390
QQ-C-390
-
QQ-C-390
-
Military
MIL-C-15345,
Alloy 11
-
-
MIL-C-22087,
Comp . 1
MIL-C-22229,
Comp . 3
-
MIL-C-15345,
Alloy 12
-
-
_
—
-
-
-
-
-
E-6
-------
Input
Mo.
322
325
326
400
403
405.1
406
405.2
406
407
Casting
Method
Centrifugal
Continuous
Ingot
Sand
Ingot
Sand
Centrifugal
Continuous
Sand
Ingot
Sand
Ingot
Sand
Die
Centrifugal
Ingot
Various
CDA
943
943
943
943
941
941
935
935
935
852
852
854
854
858
857
857-
858
ASTM
B271
B505
B30
B66
B584
(formerly
B144)
B30
B67
B271
B505
B584
(formerly
B144)
B30
B584
(formerly
B146)
B30
B584
(formerly
B146)
B176
B271
B30
-
ASME
-
-
-
-
-
-
-
-
_
-
_
-
_
_
—
-
-
SAE
-
-
-
_
-
-
CA935
CA935
CA935
-
_
-
_
_
—
-
-
AMS
-
-
-
_
-
-
-
-
_
-
_
-
_
_
—
-
-
Federal
QQ-C-390
QQ-C-390
-
QQ-C-390
-
-
QQ-C-390
QQ-C-390
QQ-C-390
-
QQ-C-390
-
QQ-C-390
—
QQ-C-390
-
-
Military
-
-
-
_
-
-
-
-
_
-
_
i
-
_
MIL-B-15894,
Class 1
MIL-C-15345,
Alloy 3
-
-
E-7
-------
(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.
E-8
-------
Ingot
No.
407.5
410
411
412
413B
415
415D
415D
415D
415D
415D
Casting
Method
Centrifugal
Centrifugal
Sand
-
Centrifugal
Sand
Centrifugal
Sand
Centrifugal
Continuous
Ingot
Investment
Precision
Sand
CDA
834
973
973
974
976
976
978
978
952
953
954
955
958
952
953
954
955
952
953
954
955
955
953
952
ASTM
"
B271
B584
(formerly
B149)
-
B271
B584
(formerly
B149)
B271
B584
(formerly
B149)
B271
B271
B271
B271
B271
B505
B505
B505
B505
B505
B30
B30
B30
_
_
B148
ASME
"
-
_
-
SB271
SB584
_
3B271
-
3B271
-
—
_
-
-
-
-
-
-
-
_
-
-
SAE
™
-
_
-
-
_
-
—
CA952
CA953
-
-
—
-
-
-
-
-
-
-
-
_
CA953
CA952
AME
**
-
_
-
-
_
-
_
_
-
-
-
-
_
-
-
-
-
-
-
-
_
-
-
Federal
*™
-
_
-
-
_
-
_
QQ-C-390
QQ-C-390
QQ-C-390
QQ-C-390
QQ-C-390
_
-
-
-
-
-
-
-
_
.
QQ-C-390
•
Military
MIL-B-20295
-
_
-
-
_
-
_
—
-
MIL-C-15345,
Alloy 13
MIL-C-15345,
Alloy 14
-
_
-
-
-
-
-
• -
-
MIL-C-22087 ,
Com(> . 8
MIL-C-11866,
Comp. 22
MIL-C-22229,
Comp . 5
E-9
-------
Ingoc
No.
415
(cont'd)
415D
420
421
422
423
Casting
Method
Sand
(cont'd)
Centrifugal
Continuous
Ingot
Sand
Centrifugal
Ingot
Investment
Sand
Centrifugal
Ingot
Sand
Centrifugal
Continuous
Ingot
Investment
CDA
953
954
955
958
864
864
864
864
865
865
865
865
867
867
867
861
862
862
862
861
862
ASTM
B148
B148
B148
8148
B271
B505
B30
B584
(formerly
B132 d
B147)
B271
B30
-
B584
(formerly
B147)
B271
B30
B584
(formerly
B132)
B505
B505
B30
-
ASME
-
-
-
-
-
-
-
-
"
-
-
-
-
-
-
SAE
CA953
-
-
-
-
CA865
-
CA865
CA865
-
•
-
-
-
CA862
AMS
-
-
-
-
-
"
4860
-
-
4860
-
-
-
-
-
-
Federal
QQ-C-390
QQ-C-390
QQ-C-390
QQ-C-390
-
-
-
QQ-C-390
QQ-C-390
-
-
QQ-C-390
-
-
QQ-C-390
-
-
-
Military
-
MIL-C-22229,
Comp . 6
MIL-B-24480
-
-
-
MIL-C-15345,
Alloy 4
-
-
MIL-C-22229,
Comp . 7
-
-
MIL-C-15345,
Alloy 5
-
-
MIL-C- 22087,
Comp . 7
MIL-C-22087,
Comp . 9
E-10
-------
Ingot
No!
423
(Cont'd)
424
500
500-13B
500-13B
500-13B
500-13B
500-13B
500-13B
500-13B
Casting
Method
Precision
Sand
Centrifugal
Continuous
Ingot
Investment
Precision
Sand
Centrifugal
Die
Ingot
Investment
Precision
Sand
CDA
862
862
863
863
863
863
863
863
872
874
875
878
872
874
875
876
875
872
872
874
ASTM
-
B584
(formerly
B147)
B271
B505
B30
; -
-
B22
B584
(formerly
B147)
B271
B271
B271
B176
B30
B30
B30
B30
-
-
B584
(formerly
B198)
B584
(formerly
B-198)
ASME
-
-
-
-
-
-
-
-
-
-
-
-
SAE
-
CA862
CA863
- ;
CA863
-
CA863
-
-
- '•
-
-
-
AMS
-
4862
-
-
-
-
4862
-
-
-
-
-
-
Federal
-
QQ-C-390
QQ-C-390
-
-
-
-
QQ-C-390
QQ-C-390
QQ-C-390
-
-
-
-
QQ-C-390
QQ-C-390
Military
MIL-C- 11866,
Comps . 20
and 21
MIL-C-22229,
Comps . 9
and 10
MIL-C-15345,
Alloy 6
-
-
MIL-C-22087,
Comp. 9
MIL--11866,
Comp. 21
MIL-C-22229,
Comp. 8
-
MIL-B-15894,
Class 3
-
MIL-C-22087,
Comp. 4
MIL-C-11866,
Comp. 19
MIL-C-22229,
Comp . 4
E-ll
-------
Ingot
No.
500
(Cont'd)
Casting
Method
Sand
(Cont'd)
CDA
875
876
ASTM
B584
(formerly
B198)
B584
(formerly
B198)
ASME
-
SAE
-
AMS
-
Federal
QQ-C-390
-
Military
_
-
E-12
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
«SPORT NO.
EPA 340/1-77-003
3. RECIPIENT'S ACCESSIOIVNO.
•1. TITLE ANO SUBTITLE
Inspection Manual for Secondary Brass and Bronze
Smelters
5. REPORT DATE
February 1977
8. PEHFORMfNG ORGANIZATION CODE
7. AUTHOH(S)
M. b. High—
T. A. Li Puma
M. E. Lukey
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
Engineering-Science, Inc.
7903 Westpark Drive
McLean, Virginia 22101
10. PROGRAM ELEMENT NO.
1.1. CONTRACT/GRANT NO.
68-02-1086
12. SPONSORING AGENCY NAME ANO ADDRESS
Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C.
13. TYPE OF REPORT ANO PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. 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 brass and bronze 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 brass and bronze
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 AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATl Field/Group
Smelters
Air Pollution
Copper Smelters
13B
14D
11F
13. DISTRIBUTION STATEMENT
Release unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
91
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |