United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/3-79-015
March 1979
           Air
v>EPA
A Review of Standards
of Performance for New
Stationary Sources -
Secondary Lead Smelters

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                            EPA-450/3-79-015
 A Review of  Standards
 of Performance for New
    Stationary Sources -
Secondary Lead Smelters
                  by

         John W. Watson and Kathyrn J. Brooks

         Metrek Division of The MITRE Corporation
            1820 Dolley Madison Blvd.
             McLean, Virginia 22102
             Contract No. 68-02-2526
           EPA Project Officer: Thomas Bibb
                Prepared for

        U.S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Air, Noise, and Radiation
        Office of Air Quality Planning and Standards
        Research Triangle Park, North Carolina 27711

                March 1979

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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air, Noise
and Radiation, Environmental Protection Agency, and approved for publica-
tion . Mention of company or product names does not constitute endorsement
by EPA. Copies are available free of charge to Federal employees,  current
contractors and grantees, and non-profit organizations - as supplies permit
from the Library Services Office, MD-35, Environmental Protection Agency,
Research Triangle Park, NC 27711;  or may be obtained, for a fee,  from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
VA 22161.
                     Publication No. EPA-450/3-79-015
                                    11

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                          TABLE OF CONTENTS
LIST OF ILLUSTRATIONS                                           vi
LIST OF TABLES                                                  vii

1.0  EXECUTIVE SUMMARY                                          1-1

1.1  Scope of Standards                                         1-1
1.2  Overview of Secondary Lead Industry                        1-1
1.3  Control Technology                                         1-3

     1.3.1  Source of Emissions                                 1-3
     1.3.2  Types of Control                                    1-3
     1.3.3  Results of Controls                                 1-4
     1.3.4  Costs of Controls                                   1-5

1.4  Test Results                                               1-6
1.5  Industry Trends                                            1-6
1.6  Possible Changes:  Analysis, Conclusions and
     Recommendations                                            1-7

     1.6.1  Current NSPS                                        1-7
     1.6.2  Standards for Lead Emissions                        1-7
     1.6.3  Investigation of Standards for S02                  1-8

2.0  INTRODUCTION                                               2-1

3.0  CURRENT STANDARDS FOR SECONDARY LEAD SMELTERS              3-1

3.1  Affected Facilities                                        3-1
3.2  Pollutants Controlled and Emission Levels                  3-1
3.3  Performance Test                                           3-2
3.4  Definitions Applicable to Secondary Lead Smelters          3-2
3.5  Regulatory Basis for Any Waivers, Exemptions, or
     Other Tolerances                                           3-4

4.0  STATUS OF CONTROL TECHNOLOGY                               4-1

4.1  Scope of Industrial Operations                             4-1

     4.1.1  Production of Secondary Lead                        4-1
     4.1.2  Geographic Distribution                             4-7
     4.1.3  Plants Subject to NSPS                              4-7

4.2  Production of Secondary Lead                               4-9

     4.2.1  Reverberatory Furnace Operation                     4-9

                                 iii

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                          TABLE OF CONTENTS
                             (Continued)
     4.2.2  Blast Furnace Operation                              4-12
     4.2.3  Pot Furnace Operation                                4-14

4.3  Pollutant Emissions                                         4-15
4.4  Applicable Controls                                         4-20

     4.4.1  Methods and Effectiveness                            4-20
     4.4.2  Cost to Industry    ,                                 4-37

4.5  Energy and Other Resource Requirements                      4-39
4.6  Environmental Effects of NSPS                               4-43

     4.6.1  Estimated Particulate Reduction                      4-43
     4.6.2  Estimated Reduction in Lead Emissions                4-44

5.0  INDICATIONS FROM TEST RESULTS                               5-1

5.1  Test Coverage in Regions                                    5-1
5.2  Test Data                                                   5-3

6.0  ANALYSIS OF POSSIBLE REVISIONS TO NSPS                      6-1

6.1  Industry Trends                                             6-1
6.2  Review of Current NSPS                                      6-3
6.3  Lead                                                        6-4

     6.3.1  Emission Rates                                       6-4
     6.3.2  Control Effectiveness                                6-5
     6.3.3  Fugitive Emissions                                   6-8

6.4  Sulfur Dioxide                                              6-13

     6.4.1  Emission Rates                                       6-13
     6.4.2  Resulting S02 Concentrations                         6-17
     6.4.3  Control Technology                                   6-19
     6.4.4  Potential Impacts for S02 NSPS                       6-31

7.0  CONCLUSIONS                                                 7-1

7.1  Retention of Current NSPS                                   7-1
7.2  No Specific NSPS for Lead Emissions                         7-3
7.3  Study of Fugitive Emissions                                 7-4
7.4  Investigation of NSPS for S02 Emissions                     7-5

                                 iv

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                          TABLE OF CONTENTS
                             (concluded)
8.0  RECOMMENDATIONS
8.1  Current NSPS for Particulates and Opacity                   8-1
8.2  Comprehensive Data on Lead Content of Emissions             8-1
8.3  Fugitive Emissions                                          8-1
8.4  NSPS for S02 Emissions                                      8-2

9.0  REFERENCES                                                  9-1

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                        LIST OF  ILLUSTRATIONS

Figure Number                                                    Page

     4-1        U.S.  Secondary Lead Production                    4-4

     4-2        Secondary Lead Smelters                           4-8

     4-3        Lead  Reverberatory Furnace                       4-10

     4-4        Process Flow Sketch of Lead Blast Furnace
                or Cupola with Cooling System                     4-13

     4-5        Controlled Lead  Pot and  Ventilation System
                with  Baghouse                                    4-16

     4-6        Comparison of Allowable  Emissions for
                Particulates (50 to 50,000 Ib/hr) vs.
                Process Weight  for NSPS  and State
                Implementation Plans                             4-23

     4-7        Efficiencies Required to Meet  NSPS for
                Particulates as  Function of Uncontrolled
                Emission Rates                                    4-25

     4-8        Capital Costs of a Fabric Filter Control
                System for Blast and Reverberatory Furnaces
                as Functions of  Flow Rates                       4-29

     4-9        Horsepower Requirements  for Venturi Scrubber
                as a  Function of Fan Efficiency and
                Pressure Drop                                    4-41

     4-10       Fuel  Requirement for Venturi Scrubbers           4-42

     6-1        Maximum Ground-Level Concentration of Lead
                Particles in Air and Distance  from Stack         6-9

     6-2        Uncontrolled S02 Emissions                       6-16

     6-3        Maximum S02 Concentrations as  a Function
                of Emissions                                     6-18

     6-4        S02 Emissions at Selected Control Levels         6-28
                                  VI

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                           LIST OF TABLES

Table Number                                                     Page

    4-1         Consumption of Scrap Lead in the U.S.            4-2

    4-2         Estimated Production of Secondary Lead           4-6

    4-3         Secondary Lead Smelters Estimated
                Uncontrolled Emission Rates (Ib/ton charge)      4-18

    4-4         Estimated Particulate Control Efficiency
                for Equipment Used with Secondary Lead
                Furnaces                                         4-26

    4-5         Comparison of Cost Estimates for Control
                of Secondary Lead Smelters - Fabric Filter
                System (dollars)                                 4-31

    4-6         Comparison of Cost Estimates for Control of
                Secondary Lead Smelters with Venturi
                Scrubbers ($ thousands)                          4-33

    4-7         Estimated Costs of Control (Annualized
                Basis)(1978 dollars/ton of lead)                 4-36

    4-8         Estimated Annual Reduction of Particulates
                From NSPS                                        4-43

    4-9         Estimated Total Reductions in Lead Emissions
                From NSPS                                        4-46

    5-1         MITRE/Metrek Survey of NSPS Test Data From
                Regions  II and IV                                5-2

    6-1         Estimated Total SCL Emission in 1985 From
                Selected  Source Categories                       6-14

    6-2         Estimated Costs of SC^ Control per Ton
                Captured                                         6-29

    6-3         Estimated Reductions in Total Annual SC>2
                Emissions from Future NSPS                       6-32
                                 vn

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1.0  EXECUTIVE SUMMARY

     This report reviews current New Source Performance Standards

(NSPS) for secondary lead smelters and analyzes possible revisions.

It provides background information to be used by the U.S. Environ-

mental Protection Agency in assessing the need for possible revision

of the NSPS.

1.1  Scope of Standards

     Currently the NSPS for secondary lead smelters applies to par-

ticulate emissions and opacity.  Particulate levels are set at 50

mg/dscm* (0.022 gr/dscf**) for blast and reverberatory furnaces.

Opacity of emissions from these furnaces may be no greater than 20

percent.  Pot furnaces with capacity exceeding 550 tons are subject

to standards for opacity only, which is set at a maximum of 10

percent.

1.2  Overview of Secondary Lead Industry

     Secondary lead produced by smelting of scrap accounts for rough-

ly half of all lead produced in the U.S.  After a record output of

over 626,000 tons in 1976, secondary lead output declined in 1977 to

between 588,000 and 600,000 tons (Bureau of Mines, 1978).  Used vehi-

cular batteries typically account for some 60 percent of all lead

scrap recycled annually at secondary smelters.  Storage batteries for

vehicles and other uses accounted for more than half of the total

U.S. demand for lead (primary and secondary combined) in 1976.  The
 *Milligrams per dry standard cubic meter.
**Grains per dry standard cubic foot.
                                  1-1

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transportation sector is expected to consume a larger share of total




output by the year 2000.  Major consumption of lead for construction




and electrical purposes, paints and pigments is also expected to




continue.  Attrition of the tetraethyl lead market for gasoline




additives and a continuing shift to other materials for such purposes




as pipes, caulking, cable sheathing and interior paints are expected




to reduce the rate of, but not prevent, increase in lead demand over




the next 20 to 25 years.  On the average, output of secondary lead




has increased by about 1.4 percent annually since 1955.




     The secondary lead industry is characterized by a high degree of




concentration in that a few companies dominate the market.  The trend




is towards fewer and larger plants.  Total number of smelters de-




creased from 160 in 1967 to about 115 in 1975.  Overall, the average




annual output per smelter is in the range of 5700 to 6000 tons.  Geo-




graphically, the industry is somewhat dispersed; secondary lead




smelters are located in all of the 10 EPA regions.




     Best estimates are that on the average two new plants and from




one to two modified smelters will become subject to NSPS each year




(EPA, 1973; Bureau of Mines, 1978).  EPA projection of a typical




secondary smelter with a 50 ton/day capacity and a flow rate of




15,000 scfm has been used as the basis for many of the calculations




in this report.
                                 1-2

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1.3  Control Technology




     1.3.1  Source of Emissions




     Operating blast and reverberatory furnaces emit particulate




matter from the stacks.   EPA has estimated average rates of




uncontrolled particulates emitted to be about 147 Ib/ton of metal




charged to a reverberatory furnace and about 193 Ib/ton for a blast




furnace.  On the basis of about 70 percent recovery of metal, these




rates exceed 200 Ib of particulates/ton of lead product.  Average




emission rates of S02 per ton of lead product are estimated to be




about 76 Ib and 114 Ib for blast and reverberatory furnaces, respec-




tively (EPA, 1975).  Pot furnaces, which are used in secondary




smelters only to remelt and purify or alloy the product of a blast or




reverberatory furnace, emit particulates and S0£ at a rate which




was indicated as negligible by EPA (1975).  The particulate emissions




from secondary lead furnaces have a lead content estimated at 23




percent (EPA, 1977).  Their capture is, therefore, important for




environmental protection and is also advantageous to plant operation




because the fines recovered can be recycled in further lead




processing.




     1.3.2  Types of Control




     For collection of particulates, fabric filters and high-energy




wet collectors of the variable-throat (venturi) type are effective in




enabling secondary lead smelters to meet the NSPS.  A baghouse or




venturi scrubber may be employed alone or in combination with




auxiliary devices in secondary lead furnaces.




                                 1-3

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     Efficiencies well above 99 percent are typically required of




control systems to meet particulate standards imposed on secondary




lead smelters.  Inlet particulate loadings from about 3 up to 12




gr/dscf of gas may be presented to collectors from a representative




furnace requiring efficiencies of over 99.5 percent.




     1.3.3  Results of Controls




     The reduction in particulate emissions from establishment of the




NSPS is estimated to be about 1000 tons each year from those plants




newly subject to the standards (i.e., plants built, modified or




reconstructed during that year).  While this is a small reduction in




comparison with the total estimated particulate emissions for the




U.S. of 16 million tons (in the year 1976), the lead content of the




particles makes their capture environmentally important.  Since




future plants may be twice the size of the present average, a




reduction in particulate emissions of twice the above value may occur




in the next few years.  Possible  adverse environmental effects and




resource consumption have been relatively small.  EPA (1973)




estimated negligible solid waste disposal requirements because of




recycling of captured particulate matter.  Incremental energy




requirements for fabric filter controls are insignificant because of




very nominal pressure drop (4 inches of water gauge) through the




baghouse.  The very high pressure drops (30 to 100 inches water




gauge) required with high-energy scrubbers increase horsepower




requirements and result in additional fuel consumption estimated as




the equivalent of about 1000 barrels of oil per plant annually.  The



                                 1-4

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total additional energy consumption each year would depend on the




number and production rate of new and modified plants coming in line




which used high-energy venturi scrubbers.  Since no more than four




new and modified plants are estimated in any one year, the increment




would represent much less than 1 percent of the average daily import




to the U.S. of more than 7 million barrels for the year 1976 (Bureau




of Mines, 1976).




     1.3.4  Costs of Controls




     Costs of control have been high to operators of secondary lead




smelters that come under NSPS.  EPA has estimated costs for 50 ton/




day model blast and reverberatory furnaces equipped with baghouses




(fabric filters) and with venturi scrubbers.  Capital costs for




control of such a blast furnance using fabric filters are estimated




(EPA, 1977) to be on the order of $1.24 million and about $470,000




for a reverberatory furnace (in 1976 dollars).  These costs have also




been estimated on an annualized basis, representing amortization of




capital outlays and expenditures for operation and maintenance.  In




terras of the value of the lead product, yearly control costs are




estimated to be on an overall average about $78/ton for a blast fur-




nace and $9/ton for a reverberatory furnance.  These amounts repre-




sent, respectively, about 14.6 and slightly less than 2 percent of




the average value of the lead product (based on an average price per




ton of lead of about $535).  Venturi scrubbers are estimated to




involve capital costs of about $895,000 for blast furnaces and




$669,000 for reverberatory furnaces (EPA, 1978).  The resulting




                                1-5

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annualized costs represent, respectively, about $33 and $22 per ton




of lead product, or about 6 and 4 percent of product value.




1.4  Test Results




     Information on only four tests of secondary lead smelters was




available to the study.  In these results for blast, reverberatory




and pot furnaces, particulate emissions were 0.0135, 0.015 and 0.0013




gr/dscf, respectively, compared with the current NSPS level of 0.022




gr/dscf.  Opacity readings were less than the maximum allowable per-




centage.  This sample is too small to be considered as adding any-




thing to the results reported by EPA (1973) at the time of preparing




the NSPS.




1.5  Industry Trends




     The concentration of  the secondary lead production in the hands




of a few large companies which dominate the market is expected to




continue.  Despite shifts  in demand patterns and attrition of the




major tetraethyl lead market, consumption of all lead (primary and




secondary) is expected to  grow at an average rate of nearly 2 per-




cent/year from 1976 to 2000.




     A trend in the lead industry, both secondary and primary, which




has been under way since at least the mid-fifties has been a decrease




in the real price of the metal product.  In other words, although the




sales price of lead per ton has increased, in terms of constant dol-




lars (i.e., relative to overall inflation), the value has declined.




Despite occasional oscillations, the price has decreased about 27
                                 1-6

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percent since 1954 (Bureau of Mines, 1977).  Thus, the industry is

faced simultaneously with decreasing net income margins and with the

need for expensive capital outlays for control equipment.

1.6  Possible Changes:   Analysis, Conclusions and Recommendations

     1.6.1  Current NSPS

     Available data indicate that no change is warranted in current

NSPS for particulates and opacity from secondary lead smelters.

Additional data are needed to investigate the:

     •  Extent of fugitive, emissions from secondary lead plants
        subject to NSPS control.

     •  Present state of control technology applicable to both
        fugitive and stack emissions.  In regard to the latter, the
        type of control equipment seen as reflecting best current
        technology does not seem to have changed since the NSPS were
        promulgated.  However, more information on capabilities under
        a range of representative operating parameters of both the
        devices themselves and the furnaces is needed as a basis for
        considering whether the level of control technology has
        significantly advanced.

     1.6.2  Standards for Lead Emissions

     No NSPS which would set levels specifically for lead emissions

from secondary smelters are warranted at this time because best

technological control systems for particulates also represent BACT for

lead which is required by current standards for particulates.  Avail-

able evidence indicates that control systems trap at least as high a

percentage of lead-bearing particles as were emitted by the furnace

(23 percent) and, hence, that no useful purpose would be served by

developing new standards for lead emissions which would be redundant

to those already promulgated for particulate control.  Furthermore,


                                  1-7

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two standards applicable to the same particulate control system would




cause potential administrative and enforcement difficulties.




     However, the information on lead emissions from secondary lead




smelters is not totally comprehensive so that it is not now possible




to eliminate all doubt on the issue*  One recent study suggested a




higher percentage of lead in stack emissions.  To confirm the




conclusions which are implied by currently available data, a compre-




hensive analysis of the matter is warranted.  It is recommended that




additional data should be collected under field and laboratory condi-




tions and analyzed to determine the disposition of the lead-bearing




particles of various sizes emitted from the  furnace.  A materials




balance should resolve the issue, based on comparison of the size




distribution of lead particles from baghouse  catches with those emit-




ted  from the furnace (inlet loading to the control system) and those




trapped in the output from the control system.




     1.6.3  Investigation of Standards for S(>2




     Total S02 emissions from all secondary  lead smelters are not




excessive on the present uncontrolled basis when compared with the




overall output of other industries.  Nor are  the ground-level concen-




trations of S(>2 at the point of maximum concentration predicted to




occur from secondary smelters of typical size under average meteoro-




logical conditions high, relative to ambient  standards.  However, the




rates of uncontrolled emissions of S02 per ton of lead product from




secondary smelters seem somewhat high per ton of product when com-




pared with those for other industries and with rates for sources





                                 1-8

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controlled under NSPS.  Emission rates of SC>2 per ton of secondary




lead product are on the average about twice those from regenerative




furnaces used in filter glass manufacture and they compare with




uncontrolled rates for sulfuric acid plants on a per ton of product




basis.




     It appears that the BACh? could potentially reduce SO  emissions




from secondary lead smelters by about 80 to 90 percent of uncon-




trolled rates.  Such a reduction would represent technology transfer




from control methods used elsewhere, particularly in control of large




fossil fuel fired boilers in utilities and other industrial plants.




Limited information available from manufacturers of control equipment




indicates that the most efficient and economic means consist of a wet




collector system that uses an alkaline reagent to neutralize sulfur




oxides in the stack gas while simultaneously scrubbing out particu-




lates.




     Although the potential for technology transfer looks promising,




the economic aspects require a much more detailed analysis than is




possible from information currently available.  Based on available




data, best estimates currently possible of the capital costs for a




combined system are from 10 to 20 percent higher than costs for a




venturi scrubber designed to control particulate emissions only




(although an increase in costs by as much as one-third cannot be




ruled out).  On an annualized basis the additional increment would




appear to represent less than 5 percent of the average value of a ton




of lead product and is probably in the range of 2 to 3 percent.




                                 1-9

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Annualized cost estimates per ton of SC>2 removed are about $115 for




a reverberatory furnace and $235 for a blast furnace.




     The ability of the secondary lead industry to afford these




increased costs is also an issue that warrants close investigation.




At present, the potential impact on the industry is very difficult to




assess because of the proprietary nature of information regarding




industry costs and earnings and because of the limited manufacturers'




data on costs of control systems.  The demand for lead appears rela-




tively inelastic so that cost increases in the range of 5 percent or




less would probably be passed along to the consumer without signifi-




cant effect on the average net income for the industry as a whole.




It is problematic whether small companies requiring new plants or




modification might be so adversely affected by even slight cost




increases as to accelerate the existing trend towards concentration




of production within the industry in a few large companies.  There is




also the question of competition between new plants faced with




increased expenditures for SC>2 control and older plants able to




operate without such costs.




     In view of all of the uncertainties, it is concluded that the




question of NSPS  for S02 emissions  from secondary lead smelters




should be  investigated.  Consideration of a possible  standard  is




based on two principal factors:  (1)  the state of SC>2 control




technology that appears applicable  to secondary lead  furnaces, and




(2) the relatively high rate of uncontrolled emissions of S02  that
                                  1-10

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is  estimated  to  occur from these plants.   It is recommended that the

following  investigations  be undertaken:

     •   Comprehensive data on emission rates of SC>2 from plants
        now controlled under current NSPS should be assembled and
        analyzed to assess the need for  a regulatory standard.
        Information now available reflects the general estimates of
        AP-42 and a few pre-1974 test results which are inconclusive
        and show a wide range.

     •   More  comprehensive and detailed  surveys should be made of
        manufacturer capabilities and costs involved in supplying
        combined systems  for SC>2 and particulate removal, with
        particular reference to plant smelters of different size
        and operating conditions and to  the needs of smaller plants
        (under 50 ton/day capacity).

     •   Achieved efficiencies for such combined systems should be
        determined in terms of S02 reduction and particulate
        removal, and the relationship of efficiency to cost should
        be assessed.

     •   The probable economic impacts of a regulatory standard on
        the secondary lead industry should be thoroughly assessed in
        terms of its ability to afford SC>2 controls.  Issues to
        address would include the ability to pass on costs and the
        effects on the competitive position of smaller plants and of
        new plants vs. existing ones.
                                 1-11

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2.0  INTRODUCTION




     The Clean Air Act of 1977 requires that the NSPS be reviewed




every 4 years.  The levels of performance achievable under best




available control technology are compared with existing NSPS.




Estimated energy needs, environmental effects produced by emission




controls and potential effects on industrial operations are also




considered.




     Results of testing emissions from secondary lead smelters under




NSPS are examined.  Only four results were available from tests




conducted for EPA regions and state agencies.




     Possible revisions to the standards are analyzed with particu-




lar attention given to changes in acceptable emission levels, addi-




tions to the pollutants controlled, and process facilities regulated.




The probable effects of changes in standards and/or associated regula-




tions are considered with respect to the environment and industry.




Specific recommendations are made regarding standards and unresolved




issues are addressed.
                                  2-1

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3.0  CURRENT STANDARDS FOR SECONDARY LEAD SMELTERS




     New Source Performance Standards were adopted on March 8, 1974,




which specified allowable levels of emissions from several industrial




sources, including secondary lead smelters (40 CFR 60).  Any secondary




lead smelter under construction, modification, or reconstruction on or




after June 11, 1973, became subject to NSPS.  The NSPS for secondary




lead smelters were revised April 17, 1974 and October 6, 1975.




3.1  Affected Facilities




     Facilities in a secondary lead smelter that are subject to NSPS




are reverberatory furnaces (stationary, rotating, rocking, or tilt-




ing), blast (cupola) furnaces, and pot furnaces of more than 550-lb




charging capacity (EPA, 1977).  Furnaces for smelting lead alloy for




newspaper linotype are subject to the standards if they meet the same




size requirement as applied to pot furnaces.  Also affected by NSPS




are modified secondary lead smelters (a physical or operational change




that increases the emission rate of any pollutant) and reconstructed




secondary lead smelters in which the replacement cost of components




exceeds 50 percent of the cost of building a comparable new facility.




3.2  Pollutants Controlled and Emission Levels




     Particulate emissions from secondary lead smelters are subject to




regulatory control.  Approximately 7 percent of a charge from such a




smelter is lost or released in the forms of fumes and particulate




matter:  smoke, dirt, limestone, coke dust, fuel bits, and metal
                                  3-1

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oxides—specifically oxides (or sulfides) of lead (EPA, 1977).   As

stated in 40 CFR 60, no owner or operator of a secondary lead smelter

under construction on or after June 11, 1973 shall discharge or cause

the discharge into the atmosphere from any affected facility any gases

which:

     •  Contain particulate matter in excess of 50 mg/dscm (0.022 gr/
        dscf).

     •  Exhibit 20 percent opacity or greater; or 10 percent opacity
        or greater in the case of gases discharged from a pot furnace
        larger than 550-lb charging capacity (EPA, 1977).

3.3  Performance Test

     A performance test of a secondary lead smelter must be conducted

within 60 days after the facility has achieved its maximum production

rate and not later than 180 days after its initial startup, and at

such other times specified by the Administrator.  Such a test consists

of three separate runs of which the arithmetic mean is the result for

determining compliance with NSPS.

     No continuous monitoring requirement is set  for secondary lead

smelters (40 CFR 60).

3.4  Definitions Applicable to Secondary Lead Smelters

     Terms applicable to secondary lead smelters  as defined in 40 CFR

60 include:

     •  Affected facility - with reference to a stationary
        source, any apparatus to which a standard is applicable.

     •  Lead - elemental lead or alloys in which  the predominant
        component is lead.
                                  3-2

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•  Modification - any physical change in, or change in the
   method of operation of, an existing facility which increases
   the amount of any air pollutant (to which a standard applies)
   emitted into the atmosphere by that facility or which results
   in the emission of any air pollutant (to which a standard
   applies) into the atmosphere not previously emitted.

•  Opacity - the degree to which emissions reduce the
   transmission of light and obscure the view of an object in the
   background.

•  Particulate matter - any finely divided solid or liquid
   material, other than combined water, as measured by Method 5
   of Appendix A to this part [Subpart A] or an equivalent or
   alternative method.

•  Reconstruction - the replacement of components in an
   existing facility to such an extent that:  (1) the fixed
   capital cost of the new components exceeds 50 percent of the
   fixed capital cost that would be required to construct a
   comparable entirely new facility, and (2) it is
   technologically and economically feasible to meet the
   applicable standards set forth in this part.

•  Reverberatory furnace - includes the following types:
   stationary, rotating, rocking, and tilting.

•  Run - the net period of time during which an emission
   sample is collected.  Unless otherwise specified, a run may be
   either intermittent or continuous within the limits of good
   engineering practices.

•  Sampling time [for Method 5] - for each run shall be at least
   60 minutes and the sampling rate shall be at least 0.7
   dscm/hr (0.53 dscf/min) except that shorter sampling times,
   may when necessitated by process variables or other factors,
   be approved by the Administrator.

•  Secondary lead smelter - any facility producing lead
   from a lead bearing scrap material by smelting to the metallic
   form.

•  Shutdown - the cessation of operation of an affected
   facility for any purpose.

•  Startup - the setting in operation of an affected facility for
   any purpose.
                             3-3

-------
     •  Test methods  (explained in Appendix A of 40 CFR 60)  -

          -  Method 1  to determine sample and velocity transversea
          -  Method 2  to determine velocity and volumetric flow rate
          -  Method 3  for gas analysis
          -  Method 5  to determine the concentration of particulate
             matter and the associated moisture content

        Sampling shall be conducted during representative period* of
        furnace operation, including charging and tapping*

3.5  Regulatory Basis  for Any Waivers, Exemptions, or Other
     Tolerances

     Occasionally, opacity standards do not apply, such as during

periods of startup, shutdown, and malfunction, or during periods of

excess emissions caused by post-blowing, unstable process condition!,

or emissions of uncombined water vapor (EPA, 1977).  In addition, when

acceptable systems of emission reduction cannot meet the opacity

limits, a means is provided for exempting the source from the standard

at that time (39 PR 9309, March 8, 1974).
                                  3-4

-------
 4.0  STATUS OF CONTROL TECHNOLOGY

 4.1  Scope of Industrial Operations

     4.1.1  Production of Secondary Lead

     Lead occupies a unique position among nonferrous metals in  that

 secondary lead production relies heavily on one source of scrap—used

 batteries.  More than 60 percent of all secondary  lead is derived  from

 resmelting battery-lead plates.  Other sources include pipe, cable

 covering, type metal, solder, drosses and other by-products.  Return

 slag from smelting is also reused (Bureau of Mines,  1973, 1976;

 Engineering-Science, Inc., 1977).

     Secondary lead is smelted down from so-called old and new scrap

 leads.  Old scrap lead consists of discarded, dismantled, or worn-out

 metallic items.    New scrap or "prompt industrial scrap" is lead

 generated at various points of the production process.  It has never

 been made into or used as an end product and is supplied directly to
                                                                     •
 smelters in larger, more uniform lots than old scrap (Fine et al.,

 1973).  Consumption of these various kinds of scrap  lead is shown in

Table 4-1.

     Secondary lead competes widely with primary lead, since most of

the same product needs can be met from both sources.  In 1975, the

output of secondary lead (658,500 tons) represented approximately 51

percent of the total U.S. lead consumption.  The 1975 production of

secondary lead was about 6 percent below the output of approximately

700,530 tons in  1974.  Although the decrease in recycled lead from
                                 4-1

-------
1974 is not fully explained,  it was part of an overall drop in total

production and consumption of lead both in the U.S.  and inter-

nationally.  The Bureau of Mines (1975) noted a worldwide recession

and a decrease in demand for  lead in automobile batteries.  Secondary

lead production rose to a record 726,569 tons in 1976, then dropped

again in 1977 to a total estimated amount of 588,000 to 600,000 tons.

Overall, the increase in production of secondary lead by smelting of


                              TABLE 4-1

                CONSUMPTION OF SCRAP LEAD IN THE U.S.
Amount Used By Remelters.
Smelters, Refiners (tons)
New3
Scrap Lead Type 1972C 1975d
Soft Lead
Hard Lead - -
Cable Lead - -
Battery Plates
Mixed Babbitt
Solder and Tinny Lead
Type Metals
Dross and Residues 114,988 136,066
Total 114,988 136,066
Old0
1972°
57,674
15,402
31,909
520,913
4,270
11,853
32,462
-
674,483

1975a
32,642
26,912
50,569
623,448
3,515
11,250
19,820
-
768,156
3Scrap  lead never made  into or used as an end product.   It  is
  available in  larger, more uniform lots  than old  scrap.
"Scrap  lead that is a discarded, dismantled, or worn-out metallic
  element.

cAmerican Metal Market,  1972.
dBureau of Mines,  1975.


                                  4-2

-------
discarded melal from about 500,000 tons in 1955 to over 658,500 tons





in 1975 (Figure 4-1) represents an average annual growth rate of about




1.4 percent.  However, decreases in the annual production of secondary




lead have also occurred in recent years.  Early in the 1970s the Lead




Industry Association (1972) predicted a possible excess of lead supply




over demand before 1980.  The Bureau of Mines (1973) predicted that




secondary lead production would increase at a faster rate than primary




production.  This projection is supported by the fact that primary




production from domestic ores actually declined from about 573,000




tons in 1971 to slightly over 530,000 in 1975, while the output of




secondary lead increased by over 50,000 tons over that period (Bureau




of Mines, 1975).




     In 1975, the secondary lead industry comprised about 85 predomi-




nantly small companies.  Bureau of Mines figures showed 160 plants in




1967, 140 in 1973, and in 1975, "approximately 115 secondary plants




engaged in recovering lead and lead alloys from recycled scrap materi-




als."  By 1977, the total number of such secondary smelters had




decreased further to 104.  The Bureau of Mines figures apply to plants




which conduct smelting and auxiliary operations that change the nature




of the product metal from the state in which it is charged to the




furnace (Bureau of Mines, 1973, 1978).  The average output per plant




in any given year is in the range of 5700 to 6000 tons.  However, a




very wide variation occurs in annual production for individual




smelters.  Viewed over a period of months, production of secondary
                                  4-3

-------
   1,600




   1,400





   1,200
o
4-1
t!  1,000
o

CO
CO
=}
o
CO
(U
     800
     600
     400
     200
       0
               Secondary production
       1950
1955
1960
1965
1970
1975
        Source:  Bureau of Mines,  1975.
                          FIGURE 4-1

              U.S. SECONDARY LEAD PRODUCTION
                             4-4

-------
lead is an intermittent operation.  It is unusual for a smelter to




operate continuously up to capacity.  Plants may be shut down for a




period of time and started up again when market conditions are more




favorable (Bureau of Mines, 1978).  Therefore, annual production of a




plant is not be directly determined by daily capacity or vice versa.




     The high degree of domination by a few companies in the secondary




lead industry is shown by the fact that the two largest producers,




operating 18 smelters, provided over half the total U.S. output in




1975.  Informal estimates are that by 1977, their share of the market




may have been nearly 60 percent.  More than 50 percent of the




remaining output (or some 20 percent of the total) is produced in 24




smelters operated by 13 other companies (Bureau of Mines, 1977; 1978).




Since more than 3/4 of the output comes from these 42 plants, the




total production of the remaining 70 small firms cannot exceed 24




percent of total output and may be nearer 12 percent.  Earlier




estimates ascribed about 75 percent of production to four firms (EPA,




1973).  Production data are regarded as proprietary, particularly




among the smaller firms and further details on distribution of output




are not available.  However, a range of estimates can be made (Table




4-2).  Estimates of production among the three categories of secondary




lead firms, annual averages per smelter, and average number of




operating days per year based on assumed plant capacity.  Estimates in




this table as to share of production captured by the largest producers




are conservative.
                                  4-5

-------
                                                              TABLE 4-2
                                               ESTIMATED PRODUCTION OF SECONDARY  LEAD
t
Total Annual
Number of Production, Production^
Category
Large Producers
Other Major
Producers
Small Producers
Total
Companies %
2 51
13 25
70a 24
85 100
Category
336,000
165,000
158,000
659,000
Per Co.
118,000
12,690
2,260
7,750
Number of
Smelters
18
24
73
115
Annual
Production
Per Smelter
18,660b
6,875
2,164
5,730
Operating Days/Year
Based on Selected Averages
for Smelter Capacity (TPD)
20 35 50 60
N/A N/A N/A 311
N/A 196 138 115
108 62 43 N/A
_ _ _ -
80
233
N/A
N/A
-
    fEstimated  from available approximations (1976)
     Rounded-off.
    Source:   Bureau  of Mines,  1975;  1977.

-------
     Use of lead is expected to increase during the rest of the cen-




tury marked by changing patterns in consumption.  Demand for secondary




lead from the printing industry and from manufacturers of paint




pigment is expected to decrease by the year 2000 (Brobst and Pratt,




1973).  There will also be decreased usage of secondary lead in




gasoline, lead covered cable, plumbers'  (caulking) lead foil, and




collapsible tubes (Fine et al., 1973).  However, the demand for




secondary lead in storage batteries is expected to increase greatly




and, according to an extreme estimate, could triple or quadruple by




the year 2000 (Brobst and Pratt, 1973).




     4.1.2  Geographic Distribution




     Despite its concentration in the hands of a few predominant




companies which produce most of the total output, the secondary lead




industry is fairly well dispersed geographically.  Secondary lead




smelters are present in all 10 EPA regions.  Figure 4-2 shows the




general distribution of secondary lead smelters in operation.  The




areas of highest concentration of secondary lead smelters are Chicago,




the Baltimore-Washington industrial corridor, and Perth Amboy, New




Jersey.  These areas provide most of the old and new scrap utilized by




secondary lead smelters in the form of discarded batteries and zinc




and copper alloys.




     4.1.3  Plants Subject to NSPS .




     EPA (1973) originally estimated that an average of two new plants




would come on line each year and that one or two would be modified or




reconstructed.  This estimate correlates reasonably well with



                                 4-7

-------
I
CO
           LEGEND:


           •  Secondary lead smelter as of 1973

              (Chapman, 1973; Bureau of Mines, 1976)!


           O  Secondary lead smelter under construction
              in 1978 (MITRE  Corporation,  1978).

-------
projections based on the average annual growth rate of the secondary




lead industry (1.4 percent).   The estimate of about three new plants




every 2 years does not take into account new plants added to replace




old ones.  Of course,  no estimate of reconstructed or modified plants




is provided by projections based on the industry growth rate.




     The estimates of  two new plants per year agrees with latest




figures of the Bureau  of Mines (1978) which show six plants completed




or scheduled for completion in the 1977-1979 period (including major




expansions of existing plants).




     At least six plants were tested after the promulgation of NSPS




for secondary lead smelters.   Evidence of six tests was obtained




chiefly through the Compliance Data System, a computerized means of




recording information  necessary for the enforcement of NSPS, during a




recent survey of the 10 EPA regions (MITRE Corporation, 1978).




However - results of only  four  tests were available.




4.2  Production of Secondary Lead




     4.2.1  Reverberatory Furnace Operation




     Reverberatory furnaces produce what is termed semisoft lead,




containing typically from 3 to 4 percent antimony and less than 0.05




percent copper (Danielson, 1973; Engineering-Science, Inc., 1977).




The process flow in a reverberatory furnace is shown in Figure 4-3.




The details of the cooling and collecting system may differ greatly,




depending upon the type of controls installed, as discussed in Section




4.3.
                                  4-9

-------
                                                                                                                   Emissions
               Fuel  (Oas or Oil)
       Conbustlon Air
      Lead Scrap
        Charge—
r
s
                                             Ventilation Gas
mJ
_t
V
IT
Process Gas

->


1

Cooling
1
                                                                        System
T
                                        Lead
                                      Product
                                                Reverberatory
                                                   Furnace
                                            Dross
                                                                      Fan
                                          Dust Recycle
      Sources:  Danlelson, 1973.
                EPA, 1973
                Mantell, 1975.
                Engineering-Science, Inc., 1977.

-------
     When a smelter is operating, reverberatory furnaces may operate




on a continuous basis, and are used in sweating operations and in




reclaiming lead from oxides and drosses.  Sweating utilizes differ-




ences in melting point temperatures to separate lead from other




metals.  Material for sweating and for reclamation from lead oxides




and drosses may be charged in the reverberatory furnace at one time.




Such a furnace radiates heat from burners and the refractory lining




into the metal charge within it.  The furnace operates at a tempera-




ture of about 2300°F and at near atmospheric pressure so that air will




not leak in.  Air blown through the molten metal eliminates impuri-




ties.  Attempts are made to keep as much heat as possible in the




furnace.  Only enough draft is provided to remove smoke and fumes.




Dross formed in the furnace floats on top of the molten metal and is




removed periodically in an operation known as slagging.  The slag may




be later rerun in a blast furnace.  The lead product is periodically




tapped into molds.




      External hoods are used with the objective of passing all smoke




and fumes to a collector.  To keep cool air out of the furnace,




ventilating air for all the hoods is similarly vented.  The spout




through which the molten lead product pours is the only exception to




the hooding.  The collected dust is valuable for recycling as fines,




either in a reverberatory or a blast furnace.  In a continuous




operation, a typical weight balance of material shows:




     •  47 percent metal recovery as lead product
                                 4-11

-------
     •  46 percent recovery of slag, which may be at least partially
        recharged

     •  7 percent loss as smoke and fumes (Danielson, 1973;
        Engineering-Science, Inc.,  1977).

     4.2.2  Blast Furnace Operation

     A blast (cupola) furnace is cylindrical and vertically oriented

and is batch-fed from a car or hopper near the top at a fairly con-

stant rate (Figure 4-4).  Although material content varies somewhat, a

typical charge may consist of:

     •  82.5 percent drosses, oxides and slags, including material
        rerun from reverberatory furnaces and pot-furnace refining

     •  4.5 percent highly silicated slag rerun from previous blast
        furnace operation

     •  4.5 percent cast-iron scrap

     •  3 percent limestone

     •  5.5 percent coke.

     Smaller percentages of iron may be used, while the percentages of

rerun slags, limestone and coke may run as high as 8, 10 and 8,

respectively.  The combustion of coke furnishes heat for the process

and also facilitates chemical reduction of lead oxide in the feed.

Forced air, which may be oxygen enriched, is introduced near the

bottom through openings known as tuyeres at a gage prespure of about 8

to 12 oz/in2.  Slag floating on top retards oxidation and is tapped

periodically.  About 5 percent of the recovered slag may be rerun

later.  The lead product is drawn off more or less continuously from

the bottom and may be retained in lead holding pots for further

melting and refining.  Blast furnaces produce what is termed hard or


                                 4-12

-------
I
I-*
U>
    NATURAL GAS
    AFTERBURNER
    TORCH
COOLING «
WATER  ~*-
OUT
 BLAST

COOLING  .
WATER IN
                                 COOLING
                                 WATER
                                 SPRAY
                 • '
                      • * •
     Source:  EPA, 1973.
CHARGE
MATERIALS
                                 LEAD
                                 PRODUCT
                                                           I
                                                     \n  n   n/
                                          FIGURE 4-4
                         PROCESS FLOW SKETCH OF LEAD BLAST FURNACE
                               OF CUPOLA WITH COOLING SYSTEM
                                                                              FLUE GAS

-------
antimonial lead containing 'as much as 10 percent antimony as well as


small amounts of arsenic, copper, nickel and tin (EPA, 1973;


Danielson, 1967; Engineering-Science, Inc., 1977; Mantell, 1975).


     A typical blast furnace may be rated at 50 tons per day of prod-


uct (over 2 tons/hr process weight) with a flow rate of about 15,000


dry standard cubic feet (dscf)/min.  EPA (1973) projected the new fur-


naces to range in size from 20 to 80 tons/day ingot production with a


gas flow rate of 10,000 to 40,000 dscf.  Often blast and reverbera-


tory furnaces in a single installation combine the effluents that are


run into a brick-lined chamber with an afterburner.  The afterburner


is necessary to incinerate oily and sticky material and to convert CO


to C0o»  No afterburner is required with the reverberatory furnace,


previously mentioned, since the excess air necessary for combustion


and the operating temperature used ensure that CO and hydrocarbon


materials are fully incinerated.  In one Pennsylvania plant consisting


of two blast furnaces and one reverberatory furnace at a combined


production capacity of 100 tons/day of alloyed lead, the process gas


flows into the control system at a rate of 65,000 ft^/min from the


three furnaces and from a set of lead holding pots; the ventilation

                          Q
gas flow rate is 60,000 ftj/min.  To contain emissions a furnace


must be sealed and all gases vented to a control system (Danielson,


1967; EPA, 1973; Mantell, 1975).


     4.2.3  Pot Furnace Operation


     Pot furnaces use a batch process to remelt lead for alloying or


refining.  At a temperature range of 600° and 900°F, the process may



                                 4-14

-------
require from a few hours to more than 2 days.  The metal is fed into




open top kettles that are ceramic lined and usually fired by natural




gas burners placed underneath.  The open top of the pot is hooded so




that lead oxide fumes will not escape into the working area.  A soft




lead of high purity (which may exceed 99.9 percent lead) can be




produced by the removal of copper and antimony.  A hard lead product




results from removing arsenic, copper and nickel.  For alloying,




ingots of a specified metal are added in the desired percentages.




Copper, tin, arsenic, antimony, and nickel are commonly employed in




alloys.  Emissions from the furnace and from the holding, melting and




refining pots are vented to a control system.  The lead-containing




dust is recycled to a reverberatory furnace.  Figure 4-5 shows the gas




flow for a pot furnace controlled by a baghouse (Danielson, 1967; EPA,




1973; Engineering-Science, Inc., 1977).




4.3  Pollutant Emissions




     Emissions may occur from a blast furnace via the charging doors




and metal tapping spout, as well as from the furnace stack.  These




outlets are hooded to provide for venting dust and fumes through the




control system.  In the reverberatory furnace the charging point, the




furnace itself, and the repositories of recovered slag and metallic




lead are hooded.  Hooding is also provided for emissions from holding,




melting and refining pots.  Depending on the efficiency of the hoods




in trapping dust and smoke, some may escape as fugitive emissions.   In




a pot furnace only the open top of the pot provides a source of




emissions (Engineering-Science, Inc., 1977; EPA, 1973).





                                 4-15

-------
                                     EMISSIONS
           FROM FURNACES
 -4FT3 ET^3FrpCT73C!
 \J\J\J\J\J
   HOLDING, LEAD MELTING,
   AND REFINING POTS
     DUST RECYCLED TO REVERBERATORY FURNACE
                             «
Source:  EPA, 1973.
                      FIGURE 4-5
        CONTROLLED LEAD POT AND VENTILATION SYSTEM
                    WITH BAGHOUSE

-------
     Particulate emissions from blast and reverberatory furnaces




contain oxides and sulfides of lead, small amounts of other elements,




coke fuel, and oil vapor.  The high temperature used in a reverber-




atory furnace (approximately 2300°F) accounts for a relatively high




mean loading (in pounds per ton of charge) of oxides of sulfur,




chiefly 802*  The sulfuric acid in lead batteries smelted accounts




for much of the sulfur emissions from a typical furnace, along with




casings and other impurities charged.  On the basis of 7 percent loss




of charge, uncontrolled particulate emissions would be on the order of




140 Ib/ton of material charged to the furnace.  Tests have shown that




the actual particulate emission rate varies widely.  Estimates by EPA




are shown in Table 4-3.  Particulate emissions from pot furnaces are




more than two orders of magnitude lower than from blast or reverbera-




tory furnaces, less than 1 Ib/ton charged to the furnace.  A rela-




tively low temperature is used with pot furnaces, and there is less




turbulence than with the other types.




     The particulates emitted by secondary lead smelters are high in




lead content, chiefly in the form of lead oxide.  It has been esti-




mated that on an uncontrolled basis lead emissions from blast and




reverberatory furnaces amount to about 56 and 53 Ib/ton of product,




respectively, which is approximately 23 percent of the  total particu-




late emission rate (EPA, 1977).




     The concentration of particulate matter in emissions  from blast




furnaces (prior to application of control) may be high, as much  as




12.3 gr/dscf in one test reported.  Typical ranges for  concentration





                                  4-17

-------
                                                      TABLE 4-3

                                               SECONDARY LEAD SMELTERS
                                        ESTIMATED UNCONTROLLED EMISSION RATES
                                                   (Ib/ton charge)
JS
h-«
oo
Test Data
• RANGE
AP-42
Tests Reported by EPAa
• MEAN OR SINGLE VALUE
Danielson (1 Test)b
Tests Reported by EPA (Average)3
AP-42
Danielson (Weight Balance)b>c
Reverberatory
Particulates

56-313
N/A

104
N/A
147
140
Furnace
S02

71-88
109-185

N/A
146
80
N/A
Blast Furnace
Particulates

21-381
N/A

172
N/A
193
140
S02

18-110
0.1-64

N/A
41
53
N/A
Pot Furnace
Particulates

N/A
N/A

N/A
N/A
0.8
N/A
S02

Negligible
N/A

N/A
N/A
Negligible
N/A
    Background  Information,  Vol.  I,  June,  1973.

   bAir  Pollution Engineering Manual,  2d Ed.  (EPA,  1973).
   Q
    7% of  charge  estimated carried out as  dust  in smoke and fumes.

-------
of particulates in stack gases from reverberatory furnaces are




reported to be from 1.4 to 4.5 gr/dscf, but higher values occur, such




as 4.98 gr/dscf (Danielson, 1973; Engineering-Science,  Inc., 1977;




EPA, 1975).




     Particles emitted from blast furnaces are much larger than those




from reverberatory furnaces and range in size from 1 to 100 microns.




By contrast, particulate sizes from reverberatory furnaces range




between 0*07 and 0.4 microns (as determined from analysis of baghouse




content) with a reported mean size of 0*3 microns.  These particles




are nearly spherical and have a tendency to agglomerate (Danielson,




1973; Engineering-Science, 1977).




     On the average, S02 emissions from reverberatory furnaces are




higher (Table 4-3) than those from blast furnaces 80 and 53 Ib/ton of




charge, respectively.  However, the upper limit of the range of




emissions from blast furnaces exceeds that for furnaces of the




reverberatory type.  Pot furnaces emit only negligible amounts of




S02.




     Emission factors from furnaces used in secondary lead smelters




have not been determined as explicit functions of the variables that




affect them.  However, a number of factors that influence the emission




rate have been briefly presented in the Inspection Manual for




Enforcement of New Source Performance Standards, Secondary Lead




Smelters (Engineering-Science, Inc., 1977).  These  include:




     •  production rate
                                4-19

-------
     •   quality of charge  (i.e.,  increase  in dirt or oil on  the scrap
         increases emissions)

     •   method of charge (i.e., adding essentially all of the charge
         at  the beginning of the heating process results in lower
         emissions than by  intermittently charging a hot operating
         furnace)

     •   fuel rate

     •   oxygen rate

     •   slag cover (i.e.,  a thick layer tends  to harden, increasing
         lead oxide emissions; prior to the time of hardening mass
         emissions are decreased by a  thick layer)

     •   length of time over which a charge is  smelted

     •   slag fines charged to the furnace  (i.e., an increase in
         these results in a higher rate of particulate emissions)

     •   for blast furnace, rate of air blowing through the tuyeres.

4.4  Applicable Controls

     4.4.1  Methods and Effectiveness

     In  the past, various  control methods have been used in  secondary

lead smelters to meet state and local requirements for particulate

removal  and to recover the lead dust valuable  for recycling.  These

have included centrifugal  dust collectors, settling chambers and

low-energy scrubbers.  In  the Background Information Document for  the

proposed NSPS, EPA noted that "At well controlled secondary  lead

smelters, either baghouses or high-energy scrubbers are used to

collect dust and fumes from the furnace."  The Agency predicted

further "The predominant control  devices for the secondary lead

industry are expected to be fabric filters, along with a small number

of high-energy scrubbers."  (EPA,  1973).  Some authorities consider

                                4-20

-------
the baghouse to be the most effective control system (Danielson, 1975;




EPA, 1977), and the use of fabric filters predominates over use of




venturi scrubbers in the secondary lead industry (Engineering-Science,




1977).



     Baghouses used to control emissions from secondary lead smelters




commonly employ a pull-through, tubular bag made of either dacron or




fiberglass.  To facilitate maintenance, the baghouses are usually




compartmentalized.  Because the temperature of the gas is very high




when it leaves the furnace stack (up to 1350°F), it is necessary to




employ cooling measures that reduce the temperature to about 500°F for




fiberglass fabric filters and about 300°F for dacron filters.  Tempera-




ture is reduced by passing the gas through radiant or water-jacketed




cooling ducts.  The cooling duct system may use a water spray and/or




U-tube coolers.  Although dilution air may also be introduced to




effect cooling, the volume of gas that may be pulled is limited by the




capacity of the system fan, so that the success of the system depends




on radiation and/or water-cooling.  It is also necessary to ensure




that sparks and other burning material do not come in contact with the




fabric" of the filter bag.  As previously noted, with blast furnaces  an




afterburner is employed to ensure complete combustion of such material




before it enters the baghouse.  To prevent condensation within  the




baghouse, the entering gas temperature must be maintained at 50°F




above the dewpoint; otherwise condensation results in caking on the




bags and a pressure buildup that will ultimately rupture the fabric.




Also, sulfur in the cake forms damaging acids.  A ratio of air  to






                                 4-21

-------
cloth of about 2:1 is commonly employed.  The pressure drop is usually




up to 4 inches water gauge (WG) (Danielson, 1973; Engineering-Science,




Inc., 1977).




     Venturi scrubbers are also used for emission control, although




less widely than baghouses.  These scrubbers commonly employ a pres-




sure drop between 30 and 100 inches WG.  Efficiency of the scrubber is




affected principally by the pressure drop and secondarily by the rate




of water flow.  A water quench is typically used which lowers gas




temperature.  With a pressure drop of 60 inches, a throat velocity of




about 200 ft/s and a water flow of 3 gal/min is typically used.




     Figure 4-6 compares the more rigorous requirements of the current




NSPS for particulate emissions from secondary lead smelters with those




provided by earlier EPA guidelines for State Implementation Plans




(SIP).  The SIP formula specified maximum allowable emission rates in




pounds per hour as a function of hourly processing weight.  To facili-




tate comparison, the graph of the permissible level under NSPS has




been converted to the same units of measure as SIPs, on the basis of a




representative furnace with a daily capacity of 50 tons of product




(EPA, 1973) and a flow rate of 15,000 scf/min.  Such a plant producing




4160 Ib/hr (2.08 tons/hr) would be allowed to emit up to 2.72 Ib of




particulates per hour.  An uncontrolled emission rate from such a




plant of 150 Ib/ton of product (Table 4-3) would produce an hourly




inlet loading to the control system of 312 Ib, requiring an efficiency
                                 4-22

-------
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           *
           ft
60

40



20



10




 4



 2
-6

.4
                .2  -
                           0
                           m
o
o
                      o  o
                         0
                         in
O
en
o
o
o
O  O O
O  O O
o  »n o
CM  ro in
o
o
o
o
o
o
 n
o
CM
o
o
o
                                           Process Weight Rate

                                                (Ib/hr)


       Source:  U.S.  Environmental Protection Agency,  1973


                                           FIGURE 4-6

                     COMPARISON OF ALLOWABLE EMISSIONS FOR PARTICULATES

                           (50 TO 50,000 LB/HR) VS. PROCESS WEIGHT FOR

                             NSPS AND STATE IMPLEMENTATION PLANS

-------
of 99.1 percent; whereas an uncontrolled rate of 193 Ib/ton (average




for blast furnaces as listed in Table 4-3) would require an efficiency




of over 99.3 percent (Danielson, 1973; EPA, 1973; 1975).




     However, even higher loadings may be encountered.  The achieve-




ment of 12.3 gr/dscf reported in one test (Danielson, 1973) would




require an efficiency of over 99.8 percent in order to meet the NSPS




level of 0.022 gr/dscf or less.  Figure 4-7 shows efficiencies




required of control systems as a function of inlet loading, again




using the basis of the representative furnace with a ratio of exit




flow-rate (in dry standard cubic feet per minute) to pounds of lead




produced of 220.




     To achieve the control efficiencies required, more than one




control system may be combined in a secondary lead smelter.  Table 4-4




shows systems associated with secondary lead furnaces together with




estimated efficiencies.  These efficiencies do not necessarily reflect




BTS.  A baghouse may be combined with a wet or dry cyclone.  Some




plants with heavy use of lead batteries as a source of scrap




reportedly combine the baghouse with a venturi scrubber.  After the




exhaust gas has passed through a fabric filter, the scrubber is used




to remove SC^ that may be present from sulfuric acid in the




batteries.  (EPA, 1975; Engineering-Science, Inc., 1977).  Control of




S02 is discussed in Section 6.




     Current control technology provides for the high collection effi-




ciencies demanded to meet particulate standards, as shown in the test
                                 4-24

-------
                1.0
N>
U1
            X
           •O

            &
            «  0.07
                                   0.3  0.4 0.50.6  0.8  1.0
               2.0    3.0  4.05.06.0  8.0  10
           Inlet Loading (gr/dscf)
20
      30   40  50 60 708090100
           Sources:  EPA, 1973;  1975.'
    60   80  100    150  200    300  400
Uncontrolled Emission Rate in Pounds/Ton Charged
  (Based on 50 Tons/Day, 15,000 dscf/Minute)

                  FIGURE 4-7
   EFFICIENCIES REQUIRED TO MEET NSPS FOR
        PARTICULATES AS FUNCTION OF
        UNCONTROLLED EMISSION RATES

-------
                              TABLE 4-4

            ESTIMATED PARTICULATE CONTROL EFFICIENCY FOR
             EQUIPMENT USED WITH SECONDARY LEAD FURNACES
                                 Furnace Type    Particulate Control
    Control Device	Applicable	Efficiency, %a

Fabric Filter (Baghouse)         Blast                  98.4
                                 Reverberatory          99.2

Dry Cyclone Plus Fabric Filter   Blast                  99.0

Wet Cyclone Plus Fabric Filter   Reverberatory          99.7

Settling Chamber Plus Dry
  Cyclone Plus Fabric Filter     Reverberatory          99.8

Venturi Scrubber Plus Demister   Blast                  99.3

aNot necessarily efficiencies achieved by BTS.

Source:  EPA, 1975.


results and in analysis of rated capabilities of control equipment.

However, very high pressure drops are demanded of a venturi scrubber

for high efficiencies in removing small particles.  For example, a

pressure drop of greater than 40 inches WG would be required to

achieve 99 percent efficiency with particles less than 0.4 microns

such as those emitted by reverberatory furnaces (Soderberg, 1974).

Therefore, a pressure drop of up to 100 inches WG should not be sur-

prising (Engineering-Science, 1977).

     Studies of the air around secondary lead smelters in Canada

showed the suspended lead particles to be relatively large and

nonrespirable.  The influence of fugitive emissions was suspected.

However, comprehensive data are lacking, and it would be unwise to
                                  4-26

-------
draw general conclusions from these limited observations (Roberts  et




al., 1974).  Based on physical considerations, it might therefore be




expected that the lead content of participates emitted from a control




system would be lower than that on an uncontrolled basis.  Generally,




the larger particles are easier to trap both in a fabric filter and in




a scrubber control device, whereas efficiency of the collector systems




tends to decrease with particle size.




     Test results on secondary lead furnaces equipped with scrubbers




and/or baghouses may support this conjecture (EPA, 1973; Davis, 1973).




In six tests conducted on emissions from seven furnaces, the lead




emissions represented about 19 percent of the particulate emission




rate.  This compares with EPA estimates (1977) of 23 percent lead




content of uncontrolled emissions.  Lead emissions under controlled




conditions are discussed further in Section 6.3.




     4.4.2  Cost to Industry




     The cost of controls for particulate emissions depends not only




on the type of system selected but also on operating variables at a




given secondary lead smelter.




     4.4.2.1  Baghouses.  Capital and annual costs for a fabric-




filter control system fitted to blast and reverberatory furnaces have




been calculated by EPA (1977) on the basis of typical or model fur-




naces, with some operating parameters specified and others implicitly




averaged out.  It was found in the analysis forming the basis of these




calculations that capital costs for both furnace types were primarily




a function of flow rate in actual cubic feet per minute (ACFM) of gas




                                4-27

-------
exiting the furnace.  For furnaces with flow rates of between 10,000

and  100,000 ACFM, the capitalization costs were expressed as:
     C =  906 Q°*6 (reverberatory furnaces)
     C = 2460 Q0'6 (blast furnaces)
where C is expressed in dollars and Q represents flow rate in actual
cubic feet per minute.  These results are plotted in Figure 4-8.
     Capitalization costs comprised equipment, installation, interest
during construction, taxes, engineering, and other miscellaneous items
including a 20 percent allowance  for contingencies (EPA,  1977).
     Annualized costs included capital recovery, utilities, operating
labor, maintenance, and overhead.  These costs were expressed as a
function of flow rate and of annual hours of labor.  Specifically,
annualized costs in dollars were  expressed as:

     A = 0.364Q + 19.6H + 236Q0'6 for reverberatory furnaces
     A = 7.25Q + 642Q0-6 + 19.6H  for blast furnaces

where Q represents flow rate as before and H denotes annual labor
hours.
     Costs were calculated for reverberatory and blast furnaces with
a capacity of 50 tons/day.  For the reverberatory furnace an exhaust

rate of 33,500 ACFM at 1350°F was assumed and  for the blast furnace a
rate of 32,000 ACFM at 500°F.  These flow rates correspond approxi-

mately to about 17,000 and 10,000 dry standard cubic feet per minute
(dscfm) depending on the percent  of moisture in the gas.  For annual-

ized cost it was assumed that 3000 hours of labor were required per
year.
                                4-28

-------
     10,000
      9,000
      8,000
      7,000
      6,000

      5,000

      4,000


      3,000

      2,500

      2,000

      1,500
    CO
    !H 1,000
    £   900
    M-.   800

    I   70°
    ?   600
    9
    O
    •s
    4J
    CO
    O
    o
     cfl
     4-1
     CO
    O
500

400

300

250

200

150
            BLAST FURNACE
                    REVERBERATORY FURNACE
           10    15  20  25 30  40  50  60708090100
                    Flow Ratze  of Exit Gas
            (thousands of actual cubic feet/minute)
           Source:  EPA, 1977.

                      FIGURE 4-8
CAPITAL COSTS OF A FABRIC FILTER CONTROL SYSTEM FOR
BLAST AND REVERBERATORY FURNACES AS FUNCTIONS OF
                     FLOW RATES
                          4-29

-------
     For the 50 ton/day reverberatory furnace, capital costs were




calculated by EPA to be $470,000 and annualized costs were $194,000




(mid-1976 dollar values).  For the corresponding blast furnace, the




capital and annualized costs were much higher—$1.24 million and




$615,000, respectively.  Credit for recycling the dust estimated to be




collected at a value of 5 cents/lb would result in decreasing annual-




ized costs by $141,000 for a reverberatory furnace and $150,000 for a




blast furnace (EPA, 1977).




     Earlier analyses indicated that the equipment and installation




cost of baghouse systems used to control reverberatory furnaces would




be higher than that for a blast furnace of the same capacity.  A study




by the Industrial Gas Cleaning Institute (Hardison et al., 1970) was




based on a survey of companies supplying control systems to secondary




lead smelters.  The figures of this study agree with those of EPA




(1973) that rate the reverberatory furnace the more expensive of the




two.  The Industrial Gas Cleaning Institute  (IGCI) study derived costs




as a logarithmic function of flow rate in actual cubic feet per




minute, which was then equated to a furnace  of specified capacity.




The relation of flow rate to furnace capacity does not agree with that




used in the model plant figures cited earlier from EPA (1977); thus




two cost figures, one based on flow rate and the other on furnace




capacity, give a range of values for comparison.  The IGCI figures are




much lower than the 1973 EPA estimates for furnaces of equivalent




size.  The various estimates are summarized  in Table 4-5.
                                  4-30

-------
                              TABLE 4-5

             COMPARISON OF COST ESTIMATES FOR CONTROL OF
           SECONDARY LEAD SMELTERS - FABRIC FILTER SYSTEM
                              (dollars)
        Cost
EPA (1977)
IGCI (1970)
EPA (1973)
Reverberatory Furnace

Capitalization Cost        474,000

Annual Operating
  & Maintenance Costs3

Annualized Costsb           53,000

Blast Furnace

Capitalization Costs     1,240,000

Annual Operating
  & Maintenance Costs

Total Annualized Costs     465,000
             168,000-260,000

               9,100-14,250
              61,000-82,000

               3,800-6,000
                  188,000
                                   51,000
                  157,000
                                   21,000
aEPA operating and maintenance costs are included in total annual-
 ized costs.
 Includes credit from recycled dust (deducted from total annual-
 ized costs).
    4.4.2.2  Venturi Scrubbers.  The most precise recent cost esti-

mates of venturi scrubber control systems were developed by EPA

(1978).  Computer modeling techniques were used to calculate costs for

both blast and reverberatory furnaces as functions of flow rates and

efficiency in particulate removal.  Parametric input was obtained for

cost factors for the various system components (including installa-

tion) developed in a study under contract to EPA (Kinkley and Neveril,
                                 4-31

-------
1976).  On the basis of 99.5 percent efficiency in particulate




removal, capitalization costs for blast and reverberatory furnaces of




50-ton/day capacity can be estimated at about $775,000 and $580,000,




respectively (in 1976 dollars).  These costs are based on exit rates




of furnace gas of about 32,000 and 33,500 ACFM, respectively, so as to




derive estimates comparable to those of the model furnaces for which




baghouse costs were developed by EPA (1977).




     These cost estimates for venturi scrubbers may be compared with




those from other sources, as shown in Table 4-6.  This table expres-




ses costs for 50 ton/day furnaces in thousands of 1978 dollars.  Flow




rates were used to scale costs not estimated for secondary lead smel-




ters.  It can be seen that the above EPA estimates for blast and




reverberatory furnaces bracket the estimate of about $640,000 from a




control equipment manufacturer.  Differentiation between furnace types




was not feasible for this estimate.  Estimates developed earlier are




much lower, even after applying inflation factors for increases in




costs of machinery and equipment (U.S. Department of Commerce, Bureau




of the Census, 1976).




     The IGCI estimated costs for a high-efficiency venturi  scrubber




are about $137,000 for a 50 ton/day blast furnace, assuming  only




14,700 ACFM.  With an assumed flow of 32,000 ACFM, the corresponding




IGCI costs increase to about $175,000.  For a reverberatory  furnace,




the cost estimates on a 50 ton/day and 33,500 ACFM basis are, respec-




tively, about $103,000 and $115,000.  These figures agree with EPA




(1978) estimates in being higher for a blast furnace and lower for a






                                4-32

-------
                                             TABLE 4-6

                            COMPARISON OF COST ESTIMATES FOR CONTROL OF
                           SECONDARY LEAD SMELTERS WITH VENTURI SCRUBBERS
                                           ($ thousands)
                                                                                   Manufacturer's
                                                                                  Estimate(l978)a
                                                                                     Combustion
                                                                 IGCI (1970)      Equipment Associ-
                     EPA (1978)            EPA (1973)      Hardison et al. (1970)    ates (1978)
Source	Reverberatory Blast  Reverberatory Blast    Reverbatory Blast   (Not distinguished)


 Capitalization
  Costb               580  775            125  123              115  175             640
 1978 dollars         669  895            202  199              184  280             640


 Annual Operating
  & Maintenance
  Costs                  N/A                 N/A                  1     1            N/A
 1978 dollars            N/A                 N/A                  1.6   1.6          N/A


 Total Annualized
  Costs                  N/A               36   80                  N/A              N/A
 1978 dollars         234  313             58  128                  N/A              N/A


 Assuming Credit
  for Recycled Fines
 1978 dollars         152  226               N/A                    N/A              N/A


aBased on conversion from estimate in dollars/megawatt, assuming a basis of flow rate
 for smelters that corresponds to a 9-MW power plant; type of furnace not distinguished.
^As provided by source (i.e., before conversion to 1978 dollars).

-------
reverberatory furnace than the EPA (1973) estimates for venturi scrub-




ber capitalization costs.  Direct comparison of estimates from various




sources is difficult because of different assumptions regarding costs.




It is not known what items were included or what efficiency in




particulate control was assumed.




     In estimating fixed annual costs for control systems using




venturi scrubbers to control lead emissions from various sources, EPA




recently used as a general rate 20.28 percent (including taxes) of




total capital investment (EPA, 1977).  Operating and maintenance costs




are estimated to range generally between 8 and 18 percent of total




capital investment, with 13 percent an average figure although very




high percentages of up to 40 percent are noted (Kinkley and Neveril,




1976).  On this basis, a rate of 35 percent may be assumed for total




annualized costs.  These would accordingly run about $234,000 each




year for a reverberatory furnace and about $313,000 for a blast




furnace.  Total annualized costs for the earlier EPA estimates and




annual operating and maintenance costs as estimated by IGCI are also




shown in Table 4-6.




     EPA (1975) originally estimated the value of recycled lead-bear-




ing dust from venturi scrubbers to be half that from fabric filters.




Applying this factor to the credit for recycled dust from baghouses of




$150,000 for blast and $141,000 for reverberatory furnaces (EPA, 1977)




and escalating the value to 1978 dollars, total annualized costs would




be reduced to about $226,000 for a blast furnace and $152,000 for a




reverberatory furnace as shown in Table 4-6.





                                4-34

-------
     A significant feature that emerges from the range of cost esti-




mates is the effect of annualized costs of controls per ton of pro-




duct.  Originally, EPA (1973) estimated the annual cost per ton of




lead produced to be $1.65 for reverberatory furnaces and $4.05 for




blast furnaces.  Both figures were based on fabric filter control;




with venturi scrubbers, the cost per ton estimates increased to $2.86




and $6.40, respectively.  A representative 50 ton/day furnace was




assumed for the estimates.  These early estimates appear to have been




too optimistic.  From the Bureau of Mines statistics previously




considered in Section 4.1.1, the average annual production of a




secondary lead plant of about 6000 tons is close to the average output




of 6875 tons/year of the 24 smelters of the second-largest set of




producers, which produce approximately 50 tons/day (Table 4-2).  The




two largest producers operate smelters that are larger than 50




tons/day; whereas small plants operate smelters of much lower




capacity.  The average output in any year varies, but taking the 1975




figure of 6875 tons as a basis for a representative 50 ton/day




smelter, annualized costs can be seen in Table 4-7.  The costs as




percentage of the price per ton of lead product are based on




escalating the average 1976 price to 1978 dollars by an assumed




inflation rate of 7.5 percent per year, which is about the increase in




1976 price per ton of lead over that for 1975.




     It may be reasonably assumed that new furnaces will be larger




than the previous average sizes.  Information available to the Bureau
                                 4-35

-------
                              TABLE 4-7

            ESTIMATED COSTS OF CONTROL (ANNUALIZED BASIS)
                      (1978 dollars/ton of lead)
                        Reverberatory Furnace       Blast Furnace
                                     Venturi                 Venturi
	Cost	Baghouse	Scrubber	Baghouse	Scrubber

Total Annualized
  Costs ($000)              61          152         536         226

Average Cost
  (Dollars/Ton)               9           22          78           33

Value of Lead
  Product  (%)
  ($534/ton)                  2           4          14           6
 of Mines  (1978)  indicates  furnaces which  have  or will  come  on  line  in

 the  1977-1979 period  to range  from 27,000 up to 70,000 ton/year

 capacity  and a daily  capacity  of more  than  100 tons.

     However, it is difficult  to convert  EPA estimates to larger

 furnaces  or to estimate the  costs involved  on  a basis  of dollars  per

 ton  of product.  On the one  hand, estimates provided by IGCI (Hardison

 et al., 1970) were based on  flow rates  as a linear  function of size of

 furnace.  Therefore,  no economy of scale  is achieved and the cost of a

 specific  control system per  ton of product  for a given type of furnace

 does not  vary.   On the other hand, flow rates  as used  in more  recent

 calculations by  EPA (1978) represent a  second  degree function  of

 furnace capacity from which  significant economies of scale  result.

     The  annual  production of  these larger  furnaces is unknown.   It is

 reasonable to relate  control costs for  a  50-ton day furnace to average

                                 4-36

-------
production figures, because such a furnace can be taken as typical of




existing plants.  However, estimates for new furnaces twice as large




or larger would have to be based on predictions as to future annual




production and the relative share of the market that these newer and




bigger plants will capture.  The very limited data available will not




support precise calculations but approximations are possible; these




indicate the range of reduction in control costs per ton of product




that result from estimates based on much larger furnaces.




     Calculations by EPA (1978) for reverberatory furnaces equipped




with venturi scrubbers reflect an increase of under 15 percent in flow




rate for a furnace twice the capacity of that previously taken to




represent a 50-ton day furnace.  The increase in capitalization costs




is a relatively modest 7 percent.  For blast furnaces, an increase in




flow rate of approximately 50 percent is postulated when the furnace




capacity is doubled.  The increase in capitalization costs is about 32




percent.




     These increases in assumed flow rate may also be applied to




furnaces equipped with fabric filters.  The estimated flow rates can




then be used to derive new capitalization estimates from the formulas




used by EPA (1977) as previously cited.  (These estimates may also be




read from the graphs in Figure 4-8.)  On this basis, the blast furnace




with a capacity of 100 tons or more per day would use a flow rate of




about 50,000 ACFM, and the reverberatory furnace a rate of about




40,000.  Applying these approximations to the cost functions







                                  4-37

-------
previously cited results in estimates of about $1.62 million and

$520,000 for blast and reverbatory furnaces, respectively.  These

represent relatively modest increases of about 31 and 11 percent,

respectively, in the cost of controls for furnaces of more than double

the original size.

     When these percentages are applied to the estimated annualized

costs for furnaces of the respective types of furnaces and control

systems, the results are:


                                           Annualized Costs (Thousands
                 Furnace                   	of 1978 Dollars)	

     Reverberatory furnace, fabric filter              68

     Reverberatory furnace, venturi scrubber          163

     Blast furnace, fabric filter                     702

     Blast reverberatory furnace, venturi
     scrubber                                         298

     Relating these costs to furnace output requires similar assump-

tions to those already made.  In the absence of more specific data, it

is not unreasonable to assume that the production of these furnaces

will be approximately twice the annual output of the smaller typical

furnaces half their size.  On the basis of 13,000 tons of lead/year,

the cost of controls per ton would be about $54 and $23 for blast

furnaces with fabric filter and venturi scrubber, respectively.

Corresponding figures for reverberatory furnaces would be about $5 and

$13/ton.
                                  4-38

-------
     While these estimates necessarily remain conjectural,  they




indicate the possibility that the increase in price of a ton of




secondary lead necessary to recover the increase cost of controls per




ton of lead product for the furnaces subject to NSPS may be on the




order of 60 to 70 percent of the estimates shown in Table 4-7.




     Some of the cost increase due to controls might be absorbed in




lower prices paid for lead scrap, but a substantial part or all of the




cost will be passed to the consumer.  Figures for the entire non-




ferrous metal industry showed the net income after taxes to be in the




range of 4 percent for 1976-77 (Levine, 1978).  These averages include




large primary producers, as well as secondary smelters.  Information




on the secondary lead industry alone is not available.  It is certain




that many small smelters will earn a smaller net income and could face




severe difficulties in modifying or reconstructing a furnace.




4.5  Energy and Other Resource Requirements




     Requirements for additional consumption of energy and other




resources are very small for fabric filter control systems that




operate at a nominal pressure drop of between 3 to 7 inches water




gauge, with an average of 4 inches (Engineering-Science, Inc., 1977;




Soderberg, 1974).  Additional requirements imposed by the use of ven-




turi scrubbers may be calculated in terms of horsepower necessary to




provide high pressure drops and flow of water used in wetting and




separating the particles.
                                 4-39

-------
      Horsepower  requirements  as  a  function  of pressure drop and fan




 efficiency  are shown  in  Figure 4-9.  Results in terms of additional




 energy  and  fuel  consumption are  shown  in Figure 4-10, assuming that a




 plant operates on  the  average for  2800 hr/yr.  This  figure is based on




 the  average annual  plant output  of  5725 tons and  a typical capacity of




 50 tons/day.  Further  assumptions have been made  regarding the amount




 of Btu  as heat input  required per kilowatt-hour (1 kW-hr represents




 0.7457  hp-hr) as shown in the figure.  The  fuel requirements are pre-




 sented  in terms  of  barrels of oil  equivalent to provide the necessary




 heat  input,  on the  assumption of 6  million  Btu per barrel of oil.  The




 results represent  a wide range because of variations possible in both




 fan  efficiencies and  pressure drop.  However, the fuel requirements




 are  on  the  order of 1000 barrels of  oil equivalent per plant per year.




     Water  requirements  may be estimated on the basis of a typical




 plant with  a gas flow  rate of 15,000 cfm.   Various ratios of water in




 gallons  per minute  to  flow rate  in  thousands of cubic feet per  minute




 may be  employed  in  wet scrubber  systems from less than one to as high




 as 20 (American Air Filter Company,  Inc., 1978).  Typical rates of




 about 3  gal/min  for each 1000 cfm  of gas flow have been reported for




 venturi  scrubbers  (Danielson, 1973;  Soderberg, 1974).  On this basis




 the  typical  plant may  be assumed to  use about 2700 gallons of water




 per hour or  about 7.56 million gallons in a year's operation as




 calculated  above.   The recycling rate  for scrubber water is high.




Based on the assumption  that  90  percent or  more of the water would be




recycled, annual  consumption  is  about 750,000 gal/plant.



                                 4-40

-------
  CO
  4J


  S
600



500
  2  400
  •H
  3
  cr
  
-------
1500
            100               200

             Additional Horsepower Required
                FIGURE 4-10
 FUEL REQUIREMENT FOR VENTURI SCRUBBERS

                   4-42

-------
4.6  Environmental Effects of NSPS

     4.6.1  Estimated Particulate Reduction

     Prior to promulgation of current NSPS for smelters, EPA (1973)

estimated that the secondary lead industry was approximately 90 per-

cent controlled.  On this basis the particulate output of an average

plant may be estimated as 10 percent of the uncontrolled rate.  Uncon-

trolled emission rates in Table 4-3 are based on pounds per ton of

metal charged to the furnace.  Using an average figure of 70 percent

lead product recovered from the metallic input, these values have been

adjusted (as used in Table 4-8) to facilitate conversion to annual

output through use of average rates.  It was assumed that each new

plant would produce on the average 6000 tons of lead per year (a

slightly higher figure than the 1975 average obtained from Bureau of

                             TABLE 4-8

        ESTIMATED ANNUAL REDUCTION OF PARTICULATES FROM NSPS
                                        Blast      Reverberatory
                                       Furnace        Furnace
Average particulate emissions
  per plant (Ib/ton of product)3
276
210
Without NSPS (90% control)
With NSPS (99.3% control)
Net reduction per plant
(Ib/ton of product)
Annual average reduction
per plant (tons)
28
2
26
78
21
1
20
60
aSingle value rates as estimated by EPA (1975) multiplied by  1.43
 to convert Ib/ton of lead product.


                                  4-43

-------
Mines statistics).   A conservative estimate of 99.3 percent

efficiency was used to calculate particulate emissions under NSPS.  It

was further assumed that all lead would require smelting in either a

blast or reverberatory furnace with any refining or alloying in pot

furnaces additional.  (Pot furnaces have negligible emissions and are

not subject to particulate control under NSPS rates on an uncontrolled

basis.)

    As shown in Table 4-8, the average annual reduction per plant is

78 tons of particulates for blast furnaces and 60 tons for reverbera-

tory furnaces.  Assuming an approximately equal mix between the two

figures and rounding off the average value to 70 tons annually, the

average can be applied to the number of plants coming under NSPS in

any one year.  The EPA (1973) estimate of  2 plants coming on line

each year results in a value of 140 tons of emission reduction.  This

figure estimates  the reduction in any one year from new and modified

plants subject to NSPS.  If a constant growth rate is assumed for each

of the 4 years during which the NSPS have been in effect, the total

reduction would be 10 times this figure or nearly 1,400 tons of

particulates.

     4.6.2  Estimated Reduction in Lead Emissions

     The secondary lead industry is not one of the prime sources of

lead emissions; its annual output is estimated to be only about one-

third that of primary production of lead.  In total tons of lead
 Future plants are likely to be about twice as large, so that annual
 reductions for 1978 and later may be double those shown in Table 4-8.

                                 4-44

-------
emitted, the secondary smelting industry ranks behind copper,  various

iron and steel processes, gasoline additives, oil-fired utilities and

municipal incinerators.  A survey of plants that produced approxi-

mately 90 percent of all secondary lead in 1970 showed an average

factor of lead emissions to the atmosphere of 0.7 Ib/ton of product
   /
(Davis, 1973; MITRE Corporation, 1977).

      Quantitative data are limited on Che emission rate of lead from

control systems meeting NSPS for particulates from secondary lead

smelters.  Limited test data from seven furnaces cited in Section

4.4.1 indicate that baghouses and/or venturi scrubbers may reduce the

rate of output (from the overall industry average of 0.7 Ib/ton) by

one to two orders of magnitude.  Lead emissions reported from the

plants tested ranged from about 0.009 to 0.0846 Ib/ton; five of the

tests resulted in emissions below 0.04 Ib/ton (EPA, 1973).  Using the

figure of 0.05 Ib/ton as a conservative estimate,* the reductions in

lead emissions attributable to NSPS may be calculated for plants

subject to these standards in the same way as was done for

particulates in the preceding section.  The results are summarized in

Table 4-9.

     The figures in Table 4-9 do not coincide with results that would

be obtained by applying to the estimates of reduced particulate emis-

sions (as given in Table 4-8) factors for the average concentra-

tion of lead particles.  On the basis of 23 percent lead content  of
*This estimate correlates well with that obtained from EPA  (1977)
estimates of 99.92 efficiency for capture of lead emissions with
baghouses as considered in Section 6.3.

                                  4-45

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                               TABLE 4-9

       ESTIMATED TOTAL REDUCTIONS IN LEAD EMISSIONS FROM NSPS
     Average emissions per plant

       Uncontrolled                            53-56 Ib/ton
       Without NSPS                            0.70 Ib/ton
       With NSPS                               0.05 Ib/ton
       Net reduction                           0.65 Ib/ton

     Average annual reduction per plant       3900 lb/1.95 tons

     Annual reduction for plants
       newly subject in 1 yr                  27.30 tons

     Estimated cumulative reduction
       1974 - 1978                            273.0 tons
particulate emissions and using the estimates of Table 4-8, the re-

ductions in lead emissions would increase by a factor of about eight

over the results shown in Table 4-9.  Several explanations for the

discrepancy are possible:

     •  The degree of particulate control in the absence of NSPS as-
        sumed for the secondary lead industry is too low, so that the
        net reduction in particulate emissions is overestimated in
        Table 4-8.

     •  The estimate of 23 percent lead in uncontrolled particulate
        emissions does not apply to the outlet of a control system,
        which actually traps a disproportionately high amount of
        lead-bearing particles.

     •  The average of 0.7 Ib of lead emitted per ton of product
        is inaccurate for the secondary lead industry as a whole so
        that the lead emissions in the absence of NSPS are actually
        higher than reported.  Comparing the value of 0.7 Ib/ton with
        the estimate of uncontrolled lead emissions on the basis of 23
        percent of particulates or about 55 Ib of lead per ton of
        product implies an efficiency of about 98 percent in control
        of lead.


                                 4-46

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     In the absence of more definitive data, particularly on lead em-




ission rates both controlled and uncontrolled (discussed further in




Section 6), the inconsistency cannot be resolved.
                                 4-47

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5.0  INDICATIONS FROM TEST RESULTS

5.1  Test Coverage in Regions

     MITRE/Metrek surveyed secondary lead smelters in the 10 EPA

regions to obtain NSPS compliance data and emission control tech-

nology information (Table 5-1).  Results of one test from Region II

and three tests from Region IV were made available.  No compliance

data were available from the other regions.  A few other tests were

conducted, but reports were not supplied.

     All tests were found to be in compliance with the particu-

late standard.  Two of these tests (Region IV) were also found to be

in compliance with the opacity standard.  Test results for opacity

were not reported from the other plants.

     The process equipment affected by the standards varied among the

plants tested.  The plant tested in Region II reported a facility

subject to NSPS consisting of three pot furnaces exhausting through

one stack.  Region IV reported process equipment that consisted of a

reverberatory furnace at one plant and a blast furnace at another.

Furnace type for the third was not reported.  Whether the plants

tested were new or modified sources is unknown.

     Control technology for the pot furnaces in the plant in Region

II is unknown.  The technology for the reverberatory furnace in

Region IV was reported to be afterburners and a melting  chamber;*

the technology for the other furnaces was reported to be a baghouse.
 At this time (December 1978), clarification of  this  surprising
 report has not been provided.

                                 5-1

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                                      TABLE 5-1

           MITRE/METREK SURVEY OF NSPS TEST DATA FROM REGIONS II AND  IVa
Region and
 Test No.
                                          Pollutants
Process
Equipment
                                             Particulates
                                                (gr/dscf)
                                   Opacity
                                      (%)
   Control
  Technology
Ol
N>
  IV-13



  IV-2a

  IV-3b
3 pot furnaces         0.0013
exhausting through
one stack

Reverberatory          0.015
furnace

Blast furnaces         0.0135

Unknown                0.0106
                                 <10
                                  0
                                                                  Unknown
Afterburners,
melting chamber

Baghouse

Baghouse
aNo tests submitted from the other eight regions.  MITRE Corporation, 1978.

bEPA, 1979.

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5.2  Test Data



     Available test data are too limited to be considered as adding




anything new to results reported prior to promulgation of NSPS.  The




relevant tests (pot furnaces are not subject to control of particu-




lates under NSPS) should be considered as three more data points that




may be added to the nine tests conducted by EPA and the Los Angeles




County Pollution District.  In all of these tests reported for plants




controlled by baghouses and/or venturi scrubbers, particulate emis-




sions averaged less than 0.022 gr/dcsf (EPA, 1973; Engineering-




Science, Inc., 1977).
                                  5-3

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6.0  ANALYSIS OF POSSIBLE REVISIONS TO NSPS




6.1  Industry Trends




     General trends of the secondary lead industry discussed in Sec-




tion 4 included the gradual rise in annual output, increased secondary




lead production with a decrease in the number of plants, and changes




in the pattern of lead consumption.  An important technologic develop-




ment is the emergence of a new battery for vehicles which is relative-




ly maintenance free.  This battery requires lead alloyed with only




one-half to one-third the antimony content previously used.  A higher




heat rate is applied in resmelting the scrap batteries and in produc-




ing a lead that is virtually free of antimony.  As a result, the quan-




tity of vapors and particulates emitted from the furnace with a given




charge of material may be increased, although quantitative data on the




effects are lacking.  The development of secondary lead with very high




purity tends to increase interchangeability between the recycled metal




and that produced from virgin ore.  In some instances, secondary lead




is produced that is purer than the primary product.  The competitive




position of secondary lead is apparently becoming stronger, although




the relative share of the market remains near the 50 percent level




subject to minor fluctuations each year (Bureau of Mines, 1978).




     The real price of lead has been decreasing steadily since 1950.




In terms of constant 1976 dollars, Jzhe price has declined by about 27




percent since 1954 and about 10 percent between 1974 and 1976.  Thus,




the profit margin or net annual income of the industry  as a whole  is






                                 6-1

-------
continuing to decrease at a time when heavy costs are being required




to control pollutants.  In production of primary lead, capital expen-




ditures have been particularly high (Bureau of Mines, 1977; 1978).




Thus, it appears that pollution control has not degraded the competi-




tive position of secondary lead.




     Production of lead from both primary and secondary sources is




expected to grow by about 50 percent between 1976 and 2000.  Changes




in demand patterns including attrition of the tetraethyl lead market




and the substitution of other materials for such uses as paints, cable




covering, calking, and some types of containers are expected to slow




the rate of, but not prevent increases in, lead production.  Average




annual increase in demand for lead from 1967 to 1976 was about 3 per-




cent.  A 50 percent increase by 2000 implies an annual growth rate of




slightly under 2 percent.  Bureau of Mines figures project that the




demand for lead in the year 2000 will be from 1.08 to 2.46 times the




1976 consumption of about 1.5 million tons.  An estimated total demand




of 2.33 million tons is deemed by the Bureau of Mines to be the most




probable projection.  The demand for lead in gasoline additives is




projected to decrease to about one-third of its 1976 level, although a




decrease by a factor of as much as six is possible.  Attrition of this




market is expected to be compensated by varying increases in all other




end uses.  Demand for lead for other transportation purposes is




expected to more than double.  The fraction of the market represented




by use of lead in paints and for electrical purposes will increase
                                 6-2

-------
about 20 percent over that in 1976.  End uses for other construction

purposes, in ammunition, and for miscellaneous products are seen as

changing less than 1 percent from their respective 1976 market per-

centages (Fine et al., 1973; Bureau of Mines, 1977).

6.2  Review of Current NSPS

     Little substantive data on current NSPS for opacity and particu-

lates from secondary lead smelters can be added to that reported by

EPA (1973) at the time the standards were proposed.  Standards of

0.022 gr/dscf for particulate emissions and 20 percent or less in

opacity (10 percent for pot furnaces) are being met.  No failure in

meeting standards has been reported in information available to the

present study.  Hence, there is no basis for relaxing these standards.

     Test results after 1973 are too limited to provide any foundation
                                              •
for inference as to whether efficiency of control systems has improved

enough to support more stringent standards.  Fabric filters and high-

efficiency venturi scrubbers still represent best technologic system

of control.  Examination of estimated inlet loadings to collector sys-

tems indicates that control efficiencies well in excess of 99.5 per-

cent are required.  Efficiencies in this range are reported in the

literature, and EPA (1977) has estimated overall collection efficien-

cies of 99.91 and 99.09 percent from the front half and the total

train, respectively, for secondary .lead blast furnaces equipped with

baghouses.  Specific test data are, however,  lacking by which to fix

the performance of control systems over the range of operating
                                 6-3

-------
conditions that may be encountered and, hence, to support a basis for
a more stringent level of control for particulate emissions.
     In regard to opacity, less quantitative data are available than
for particulates.  It is known that optical transmittance can range
widely in relation to mass concentration of particulate matter.  On
physical grounds and from analogy with industries where more test data
exist, one might conjecture that an opacity reading of considerably
less than 20 percent be associated with the NSPS for particulates of
0.022 gr/dscf.
6.3  Lead
     6.3.1  Emission Rates
     EPA (1975) estimates the uncontrolled emission rate for lead
from blast and reverberatory furnaces as 56 and 53 Ib/ton of product,
respectively, or about 23 percent of the particulate emissions.  Some-
what higher rates were reported in a recent study (details are not yet
available) and the issue remains in doubt.  These are high per unit
when compared with storage battery manufacturing (17.7 kg/1000 batter-
ies), lead glass (15 Ib/ton of product), iron and steel production,
and various processes that account for high percentages of annual lead
emissions as tabulated by EPA (1977).  However, EPA estimates the
secondary lead industry to be about 95 percent controlled and the 1975
total output of lead emissions from secondary smelters to be about 830
tons.  This compares with over 18,000 tons expected at the uncon-
trolled rate from the production of 658,500 tons of secondary lead in
1975.
                                 6-4

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     6.3.2  Control Effectiveness




     Controls for lead from secondary furnaces are the same as those




for particulates.  The technique consists of capturing the lead-




bearing particles in a baghouse or removing them in a high efficiency




wet scrubber.  EPA deems the baghouse to be the most effective control




technique and estimates its efficiency in removing lead emissions to




be as high as 99.92 percent, based on total-train sampling.  This




estimate would give a controlled emission rate of about 0.0448 Ib/ton




of lead, or an emission rate of 2.24 Ib/day for a typical 50 ton/day




plant.  The average plant production rate of about 6000 tons annually




would result in about 270 Ib/yr, or about 0.13 tons/year.




     The important question in regard to control of lead emissions is




whether the lead is captured in the form of lead-bearing particles at




the same rate as particulates generally or whether higher fractions of




the lead escape as smaller particles or  possibly in vaporized form.




If the captured particles contain 23 percent lead (i.e., the same per-




centage as estimated for uncontrolled emissions) then a 50 ton/day




plant meeting the particulate standards at 0.022 gr/dscf would release




about 2.8 Ib/hr of particulates (based on a flow rate of 15,000 dscf)




of which the lead content would be (at 23 percent) about 0.65 Ib/hr or




slightly over 0.3 Ib/ton.




     Results in control of lead emissions were recently reported by




the Chicago Department of Environmental Control (Petkus et al., 1974).




A survey of 11 controlled smelters producing some 6600 tons of lead in
                                 6-5

-------
a year revealed lead emissions at the rate of approximately 1 Ib/mil-




lion Ib (500 tons) of product (controlled emission rate of 0.002 lb/




ton of product).




     Very little basic data from tests on controlled lead emission




rates are available.  However, six tests conducted before 1973 showed




lead emissions from plants controlled by baghouses and/or venturi




scrubbers to be slightly less than 23 percent of the particulate rate




or about 19 percent on the average.




     Sublimation of lead particles might be conjectured at the very




high temperatures at which the stack gas leaves the reverberatory




furnace (up to 1350°F) or in the afterburner of the blast furnace.




However, gas must be cooled to 500°F or less before entering a bag-




house to avoid damage to the filter fabric.  With venturi scrubbers,




the water quench necessarily succeeds also in reducing the tempera-




ture of the gas.  Thus, the likelihood of vaporized lead escaping a




control system is much less than the likelihood of sublimation within




a furnace or afterburner.  Such particles escaping the collector would




tend to be smaller than 1 micron.




     No test data exist for comparing baghouse content of lead with




the results of Method 5 tests of emissions from fabric filters.  No




materials balance is thus possible to account comprehensively for




where lead emissions from the smelting furnaces finally appear.




Available evidence is consistent, however, in indicating that the




ratio of lead to particulate emissions from controlled furnaces is no
                                 6-6

-------
higher than the ratio for uncontrolled rates (23 percent).  Further,




the estimate of 0.0448 Ib/ton of product based on 99.92 percent bag-




house efficiency appears as a reasonable, and even conservative, es-




timate for a well-controlled furnace.




     Ambient standards for lead have now been promulgated by EPA.




Based on modeling results, EPA has estimated (Scruggs, 1977) that for




each ton of lead product, the lead concentration nearby will be 8.69 x




10~5 |j.g/in3.  The maximum downwind concentration average over a




year was estimated to be about 0.0105 fig/or for each ton of lead em-




itted by a plant.  Although much higher values have been recorded near




secondary smelters, they are unlikely to be observed as a result of




stack emissions from well-controlled furnaces.  Tests near a smelter




in Texas at a range of about 60 to 300 meters distant showed air con-




centrations from 3.3 (Jig/m^ to as high as 11.6 p-g/m^ (Texas Air




Control Board, 1974).  Data are not available as to the degree of




control practiced at this site.  Roberts et al. (1974) report lead




concentrations in suspended particles at about 200 m from two Canadian




smelters in the range from 1 to 5.3 fjig/m^.  These two Canadian




furnaces were estimated to have emitted over 33,000 and 66,000 Ib of




lead per year.  Such lead emissions are more than two orders of mag-




nitude greater than estimates previously noted for stack emissions




from an average 6000 tons of lead per year furnace; they would not be




approached by well-controlled furnaces of much greater capacity.
                                 6-7

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     Figure 6-1 shows the estimated maximum downwind concentrations



from the typical 50 ton/day furnace and the distances at which these



would be experienced for different meteorological stability condi-



tions as established from calculations by the U.S. Public Health



Service (Turner, 1969).  Results are based on a 3-minute sampling



time.  These results will vary with topographic and architectural



conditions that prevail at specific furnace locations.  However,


                T
levels of 2 [ag/m  would be expected from the estimated emission rate



for a controlled 50 ton/day furnace only under exceptional windspeed



conditions.  With production and output rates up to four times



greater, maximum concentrations of 2  u.g/nr* would not be expected



even with moderate wind conditions of 4 m/s (about 8 knots) or



greater.  For a 24-hour average, the estimated level decreases to 36



percent of the 3-minute sampling value (shown in Figure 6-1).  Thus, a



3-minute level of 5.56 [ig/m^ corresponds to a 24-hour average of



2 ng/m3-



     6.3.3  Fugitive Emissions



     Besides the material discharged through the stack of a secondary



lead furnace, smoke and dust particles may be emitted into the atmos-



phere in and around a plant from other operations.  Some of these



emissions may be process-related, e.g., when fumes escape from the



hoods provided around potential outlet points of a furnace.  Others,



which may be termed site related, result from auxiliary operations



outside the plant.  The term fugitive emissions is often limited to






                                 6-8

-------
vo
    Wind Speed » 1 m/s QL--
                                       Maximum Ground-Level Concentration (jjtg/m )
                                    II   I  I  1 I  I II I      I   I   I I  I I IH      I   II
    Wind Speed = 2 m/s

    Wind Speed = 4 m/s
Source:   Turner, 1969.
                                      .2  .3.4.5
                                      I      I   I
                    1     2345     10    20  30 40
                    I  I HI I      I    I  I  I I  MM     I
.05   0.1   0.2 0.3 0.5    1
 II   II I  I III      I I  I  I  I
                                                                   345    10    20
                                                                     1  i I  I  I I 1 III
.03' .05   0.1   0.2 0.3 0.5
                                                                         3  4<5
                                                   10
                                           FIGURE 6-1
                   MAXIMUM GROUND-LEVEL CONCENTRATION OF LEAD PARTICLES
                                IN AIR AND DISTANCE FROM STACK

-------
process-related emissions, but usage in the literature is divided,




with some writers applying the term both to smoke and fumes escaping




from the smelting process and to windblown dust from storage and hand-




ling procedures.  The important point is that both potential sources




can contribute significantly to pollution.  Both will be discussed in




the present section on fugitive emissions with a distinction made




between process- and site-related emissions.




     No fugitive emission points, whether related to processing or to




auxiliary operations at the site, are currently subject to specific




control under NSPS for secondary lead smelters.  In some situations,




fugitive emissions may be high.  The high concentration of lead, par-




ticularly in the soil, close to two Toronto smelters was largely




ascribed by Canadian investigators to "low-level, dust-producing oper-




ations rather than. . .stack fumes" (Roberts et al., 1974).  In ex-




treme situations, fugitive particulate  emissions from processing may




amount to over 15 Ib/ton of charge from reverberatory furnaces and as




much as 12 Ib/ton from blast furnaces.  While these rates are much




lower than uncontrolled emission rates  from furnace stacks, they are




also substantially higher than rates achieved under NSPS controls.




Lead and iron scrap burning may produce from 1 to 2 Ib/ton of scrap.




Other potential sources include storage, loading and transfer of




material, as well as handling of dust collected by control systems




(EPA, 1977).  It is reportedly common for baghouse catches to be




stored in open piles at a plant yard until enough material has
                                 6-10

-------
accumulated for charging to a reverberatory furnace (EPA, 1978b).




Experimental data are lacking on the extent to which fugitive emis-




sions at secondary lead smelters subject to NSPS control actually




occur, either from process-related operations or from auxiliary opera-




tions at the site.  On the one hand, several factors would be expected




to minimize such emissions at well-regulated plants.




     Hooding of all points of potential emissions in the smelting




process and venting of the air to the control system along with gas




from the furnace is intended to prevent significant escape of lead




particles or other particulate matter from the collector device.  It




is in the economic interests of an owner/operator to prevent fugitive




emissions during smelting to avoid loss of fines valuable for their




lead content, as well as to protect worker health and efficiency.  The




sound engineering practices dictated by these considerations to pre-




vent such fugitive emissions are prescribed in regulations of the




Occupational Health and Safety Administration, which note specifically




the need for enclosing potential sources by hooding.  Accidental leaks




in hooding and ventlines can be minimized by adequate maintenance




practice.




     However, several variables can affect the discharge of fugitive




emissions during smelting and can negate preventive measures.  These




include process aberrations, differences in raw materials, and varia-




tions in operating parameters such as blast air rates.  Data on the




effects of these variables are not available.  Where particulates







                                 6-11

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escape into the plant area adjacent to the smelting operation, some




release to the outside is almost inevitable as a result of normal




ingress and egress.  Monitoring of the atmosphere adjacent to second-




ary lead smelters has on occasion uncovered unacceptable concentra-




tions of lead which may reflect fugitive emissions.  At least one




instance has been reported in which a smelter was required to be




sealed, with all air inside the plant vented to the control system




(EPA, 1978).




     The role of fugitive emissions in the high lead concentrations




observed near Texas smelters (previously cited in Section 6.3.2) is




unknown.  The relative contributions of process- and site-related




sources are also unknown for the lead levels in the atmosphere and




soil as reported in the Canadian investigations.  Assuming that con-




trol of fugitive emissions through hooding and venting to the control




system achieves a level of reduction over uncontrolled emissions




which is comparable to that provided for furnace gas, less than 0.01




Ib of particulates/ton of lead product would be expected from proces-




sing operations, or a maximum of about 60 Ib/yr for each plant.  How-




ever, data from tests and observations on which to confirm or modify




this assumption are not available.




     Significant improvements in the technology of controlling fugi-




tive emissions from both process- and site-related operations in sec-




ondary smelting of lead have recently been reported in Denmark.  The




methodology uses improved furnaces that minimize the escape of dusts
                                 6-12

-------
during smelting and also enable baghouse contents to be recharged as

collected, thereby eliminating the accumulation of these fines in

storage piles where they are subject to transport into the environ-

ment.  Specialized waste management and housekeeping procedures are

used in conjunction with the furnaces to reduce the opportunity for

emissions from storage of raw materials and other sources on site.

The technology has been investigated by the EPA Industrial Environ-

mental Research Laboratory in Cincinnati in connection with the

National Institute of Occupational Safety and Health (NIOSH).  Test-

ing of the furnaces has been conducted under the joint auspices of EPA

and NIOSH at a plant in Denmark.  Initial reports indicate the tech-

nology as having high potential for application in reducing fugitive

emissions from secondary lead smelters in the U.S. (EPA, 1978d).

6.4  Sulfur Dioxide

     6.4.1  Emission Rates

     The rate of uncontrolled emissions of S02 from secondary  lead

smelters has been estimated by EPA (1975) to be approximately  half

that of particulates.  While the estimated rates of 76 Ib/ton  of  lead

produced for blast furnaces and of 114 Ib/ton for reverberatory fur-

naces* are low in comparison with emission rates from primary  pro-

duction of metals, they are more than twice the rates of regenerative

furnaces used in manufacturing fibeg: glass and compare with  the
*These values represent adjustments of the EPA estimates  so as  to
 reflect pounds per ton of lead product (assuming 70 percent
 recovery) instead of per ton of metal charged.


                                 6-13

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uncontrolled emission rates of sulfuric acid plants.  Comparative




costs for controls in some selected industries are considered in a




later section.




     Currently, no NSPS for SC>2 from secondary lead smelters are in




effect.  A reverberatory furnace of 50 tons/day (2.08 tons/hr) would




emit about 2.85 tons of SC-2 each day and a blast furnace of the




same capacity about 1.9 tons.  Assuming an equal mix between blast




and reverberatory furnace production, the total secondary lead pro-




duction in 1975 of 658,500 tons would have resulted in about 31,000




tons of S02-  This is about one-tenth of 1 percent of the total




SC-2 emissions from stationary sources (which comprised 98 percent




of the national emissions) in 1972 and the same percentage of 1975




emissions as estimated from modeling techniques by the Argonne




National Laboratory (Habegger et al., 1976).  This study has further




estimated that by 1985 SC>2 emissions from secondary lead reverbera-




tory furnaces will amount to about 29,000 tons.  This estimate may be




compared with estimates similarly derived from other source categor-




ies as shown in Table 6-1.  Overall, this study has ranked lead




reverberatory furnaces as fifteenth out of approximately 30 source




categories on a priority basis for consideration of controls by EPA.




     A wide range of SC>2 concentrations from secondary lead smel-




ters depends not only on the amount of sulfur in the charge but also




on production rates and flow rates of exit gas.  These ranges are




shown in Figure 6-2.  A 50 ton/day blast furnace with a flow rate of
                                 6-14

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                              TABLE 6-1

                   ESTIMATED TOTAL S02 EMISSION
               IN 1985 FROM SELECTED SOURCE CATEGORIES
     Category3                            Thousands of tons/yr
                                                    1985
     Boilers (>250 x 106 Btu/lb)                     8352

     Smaller boilers                                4445

     Portland cement                                 335

     Petroleum refinery (fluid catalytic
       cracking unit)                                259

     Wood pulping                                    164

     Stationary gas turbines                         125

     Incinerators                                     63

     Iron and steel                                   54

     Glass (soda lime glass)                          36

     Secondary lead, (reverberatory
       furnace)                                       29

     Sulfuric acid                                    23
aPrimary metal production is not included; greatly reduced
 emissions are anticipated under existing NSPS.
Source:  Habegger et al., 1976.
                                 6-15

-------
T
H*
0\
                 1300
                  100
                          20   40  60
    100                  200

  S02 Emission Rate (Ib/hr)


         FIGURE 6-2

UNCONTROLLED SO2 EMISSIONS
300

-------
15,000 dscfm emitting 802 at a rate of 158 Ib/hr would provide an




uncontrolled concentration of about 987 ppm on a dry basis.  For a




reverberatory furnace of the same capacity, the uncontrolled concen-




tration would be more than 1400 ppm.  These concentrations would be




reduced for higher flow rates as seen in the figure.  Much variation




is also shown in the limited test results available.  In eight tests




conducted on secondary lead smelters equipped with baghouses and/or




venturi scrubbers the S(>2 concentrations ranged from less than 0.1




ppm to over 2000 ppm (EPA, 1973).




     6.4.2  Resulting SO? Concentrations




     An important consideration in regard to S02 emissions from




secondary lead smelters is the concentration that can be expected to




result, particularly at ground level.  Results of calculations made




on the basis of hourly 802 emissions are plotted in Figure 6-3.




This figure plots the maximum ground-level concentration of 802 on




the horizontal axis for selected wind speeds and emission rates as




plotted on the vertical axis.  Separate graphs are plotted for dif-




ferent meteorological conditions (A, B and D) which are convention-




ally distinguished.  Effective stack heights (in meters) of the




discharge are indicated on each graph.  The computations in Figure




6-3 were based on the "Workbook of Atmospheric Dispersion Estimates"




(Turner, 1969).  For convenience, the output of 802 Per nour is




shown in pounds, but the downwind maximum ground-level concentration




(3-hr average) is shown in micrograms per cubic meter.  The secondary
                                 6-17

-------

-------
level of 1200 [ig/m  for a 3-hr average has been set as a value not




to be exceeded more than once per year.




     It can be seen from Figure 6-3 that a downwind concentration re-




sulting from an emission rate of 100 Ib/hr would exceed 1000 [ig/m^




only for relatively unfavorable meteorologic conditions and a rela-




tively low effective stack height (e.g., Condition A and wind speed




of no more than 2 m/s or about 4 knots maximum at a stack height of




30 m).  Average height of stacks discharging from a secondary lead




smelter is about 150 ft or 40 m (EPA,  1973).  The effective height is




somewhat greater, depending on the furnaces.  For a relatively neu-




tral set of conditions as represented by Condition D with wind speed




of only 2 m/s, a furnace emitting 200 Ib of S02/hr would not pro-




duce a maximum downwind concentration (on a 3-hr basis) of as much as




1000




     6.4.3  Control Technology




     6.4.3.1  Methods.  Available techniques for removing S02 from




gas exiting a secondary lead furnace consist essentially of contac-




ting the gas with liquid containing an alkaline reagent in the form




of a slurry or in solution as a clear  liquor.  Through chemical reac




tion the sulfur compounds in the gas are precipitated as sulfites or




sulfates in sludge.  In most processes this sludge is a waste that




must be discarded.  However, in regenerative processes, the sorbent




is recycled to provide for recovery of marketable  sulfur products.




In control of 802 from the primary metals industry, the smelting  of
                                 6-19

-------
lead, copper or other ores is often combined with a plant in which




sulfur compounds from a regenerative control process are used to




produce sulfuric acid.




     The process of S(>2 removal is often referred to as flue gas




desulfurization.  A number of techniques are commercially available




or in pilot plant operation.  Much of the developmental work and many




of the applications are for desulfurization of gas from boilers fired




by fossil fuels.  Lime and limestone are among the most commonly used




reagents, but other chemical compounds such as magnesium oxide or




ammonia may be used.  The so-called double alkali or soda lime pro-




cess employs a combination of sodium carbonate and lime or limestone.




     Scrubbing equipment may involve towers or columns packed with




absorbent material over which the gas to be cleaned and the scrubbing




liquid pass, or in which the gas is dispersed through liquid in a




series of trays or plates.  Spray towers may also be used, with the




liquid absorbent sprayed through nozzles.  Venturi scrubbers are




employed to remove both particulate matter and SC>2 from the gas,




often in combination with some device such as a spray tower or after




absorber, or the gas may circulate in two or more stages within the




scrubber with additional reagent being added at each stage.  In a




broad sense, a system for scrubbing S02 from furnace gas may be




thought of as an extension of the venturi devices and similar wet




collectors employed by secondary lead smelters for particulate




control.  A single-stage venturi scrubber, such as commonly used in
                                 6-20

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lead furnaces to remove particulates,  in which lime or limestone is




employed as the slurry, can be counted on in application to utility




boilers to remove about 40 to 50 percent of the 802 (Bechtel,




1978).  Typically, two or more stages  are necessary to meet S02




emission standards for fossil-fuel fired boilers.   Tests of a  proto-




type double alkali system employing a  combined venturi/absorber con-




figuration reportedly produced removal efficiencies greater than 95




percent when the bled liquor pH exceeded 5.2 and achieved efficien-




cies above 98 percent when pH of the venturi liquor was raised above




6.0 (PEDCo, 1977b).




     A few remarkably low 802 emission rates have been reported




from tests of secondary lead furnaces  controlled by scrubbers  denoted




only as venturi (i.e., without stipulation of the number of stages or




the characteristics of the chemical reagent).  EPA (1977) has  noted




that a scrubber for particulates provides an advantage in that it may




be designed for 802 reduction.  It is  not considered, however, that




a scrubber designed for particulate removal could regularly meet any




NSPS for control of S02 emissions from lead smelters.  While some




improvement in efficiency of 802 removal has been suggested for




single-stage venturi scrubbers through adjustment in operating condi-




tions (e.g., addition of magnesium oxide to a lime/limestone slurry




to improve its desulfurization properties), further analysis of con-




trol requirements and their costs is based on assumption of a  scrub-




ber specifically designed for 802 control.  Such a device might be
                                 6-21

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added to a system for removing particulates or it might be a subsys-




tem controlling both S02 and particulates.




     6.4.3.2  Cost Estimates.  A scrubber for 862 removal can be




very costly as an add-on to a baghouse.  One reported test involved a




secondary smelter in which a scrubber, representing an investment of




about $700,000, reduced S02 output from about 1800 to 140 ppm (about




90 percent control) (Los Angeles County, 1978).  On this basis a sep-




arate scrubber and baghouse for discrete control of S02 and partic-




ulates would approximately double capital costs.  The general proce-




dure, however, would be to install a special system designed for




simultaneous removal of both pollutants.  Several firms supplying con-




trol equipment were contacted for cost estimates.  Secondary lead




smelters do not regularly use scrubbers for reduction of S02 emis-




sions, at least not to the same degree as controls for trapping par-




ticulates (EPA, 1978).  Industrial representatives were reluctant to




supply cost estimates applicable to lead furnaces.  When experience of




the firm was in S02 control of fossil-fueled boilers, difficulty was




expressed in using costs based on kilowatt capacity of a power plant




or heat-input rate of an industrial boiler to estimate costs for




secondary lead furnaces of the size modeled by EPA (1977) at 50 tons/




day with exit rates of furnace gas in the range of 32,000 to 33,500




ACFM.  However, a few spokesmen supplied data varying in amounts and




in level of detail which indicate industrial capability to provide a




combined unit for simultaneous removal of both particulates and 802*
                                 6-22

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     Direct comparison between costs of combined systems and those




used only for particulate removal is difficult because of varying




estimates which may not include all of the same items.  Estimates




must be general because they apply to hypothetical plants with unspe-




cified design parameters; thus, only an approximation or a range of




values can be indicated.  Within these limitations, evidence shows




that the capitalization costs of a combined system are about 10 to 20




percent higher than those of a scrubber installed to control only




particulates.




     Based on manufacturer estimates, capital costs of a combined




system for a 50 ton/day secondary lead furnace fall between $500,000




and $1 million.  These costs include installation, instrumentation,




all materials, equipment for sludge handling, engineering, training




in usage, and start-up.  They are from 25 to more than 50 percent




higher for blast furnaces than for reverberatory furnaces.  Taking




$750,000 as the midpoint of the range for a reverberatory furnace and




$1 million for a blast furnace, comparison with EPA (1978) estimates




for particulate controls with a venturi scrubber of $669,000 and




$895,000, respectively, indicates increases of about 11 percent.




This relationship correlates with the estimate of one firm (based on




applications to plants generating electric power) for scrubber costs




designed to remove particulates only and those for combined removal




of particulates and S(>2»  These cost estimates are for  installation




made at the time of plant construction.
                                6-23

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     These estimates may be compared with those in a recent study of




costs of controlling S02 and particulates in coal-fired boilers




used by power plants (PEDCo, 1978).  Computerized modeling techniques




were used to calculate costs of several S02 control systems (with




particulate removal) for power plants of different capacity under




scenarios reflecting the type of coal burned and pecentage of S02




removal from flue gas.  Although the data were developed specifically




for coal-fired utility boilers, from the parametric assumptions re-




garding flow rates and S02 output, it is possible to draw analogies




with control of secondary lead smelters.




     In particular, it may be of interest to compare the inferences




of this study as to the increase in capitalization costs resulting




specifically from components designed to reduce S02«  It was found




that the study of costs for power plants produced somewhat higher




estimates than the above-cited figures, both for capitalization re-




quirements and increases due to SC>2 control.  Assuming that costing




of heat exchangers, fans and motors, and valves and ducting reflected




requirements for particulate removal as well as S02 reduction,




equipment specific to S02 control was calculated to increase direct




costs (all installed equipment, plus sludge pond) by over 55 percent.




Total cost increases ascribed to S02 removal were from about one-




fourth to one-third, depending upon what items of indirect cost




necessary to a power plant are also judged applicable for secondary




lead furnaces.
                                 6-24

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     Direct costs were estimated to be about $1,1 million.  Total




costs ranged from about $1.4 to under $2 million, again depending on




what indirect costs used by the model were included.  These estimates




were obtained by equating a 50 ton/day secondary lead furnace burning




0.8 percent sulfur coal to a 9-MW power plant, on the basis of flow




rate of exit gas and rate of S(>2 output.  Costs in dollars per




kilowatt as calculated in the model methodology for the scenario of 90




percent 862 reduction by use of lime scrubbing were then applied to




arrive at rough approximations applicable to the secondary lead




smelter.




     Annual operating and maintenance costs for scrubbers have been




estimated to range from 8 to 18 percent of total capital investment




with 13 percent as an average figure, although very high costs of up




to 40 percent are noted (Kinkley and Neveril, 1976).  In modeling of




costs for scrubbing and absorption systems to remove particulates as




well as S02 from flue gas emitted by coal-fired boilers used in




generating power, operating and maintenance (O&M) costs were esti-




mated to run 16 to 18 percent of capitalization costs (PEDCo, 1978).




The range of 13 to 16 percent is consistent with results reported in




operation of one manufacturer's equipment with particulate and 802




control of flue gas (Ferb and Stevens, 1978; Research-Cottrell, Inc.,




1978).  Fixed annualized costs representing about 20 percent of the




total capitalization requirements have been used by EPA (1977).
                                  6-25

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     Thus, 35 percent of the total capital investment representing the




sum of the O&M and fixed costs, may be used as a factor to estimate




total annualized costs of a combined system for venturi scrubbers




controlling particulates only.  On this basis, costs for a blast




furnace would be about $350,000/yr and $262,500 for a reverberatory




furnace.  It is not clear whether the same credit would apply for




recycled lead from the sludge of a venturi scrubber designed to remove




particulates only as would apply to that produced by the combined




system.  If the value of recycled lead is taken at $75,000/yr, annual




costs would be reduced to $275,000 for a blast furnace and $187,500




for a reverberatory furnace.  Based on the assumption made in regard




to recycling, at an average output of 6875 tons, price per ton of lead




product would be increased by an amount between $27.27 and $38.18 for




a reverberatory furnace and between $40 and $50.90 for a blast fur-




nace.  These estimates compare with increases in cost of $22 and $33




per ton resulting from use of a venturi scrubber to control particu-




lates alone.




     6.4.3.3  Estimated Costs per Ton Captured.  An important con-




sideration in regard to the possibility of NSPS for control of S(>2




emissions from secondary lead furnaces is the cost per ton of S(>2




captured.  Such costs may differ by more than an order of magnitude




when compared with other industries; for example, about $40 to $60/ton




of S02 captured in I^SO^ plants and from around $500 to nearly




$1500 for electric generating utilities, depending on the type of
                                 6-26

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coal burned.  It is estimated that in H2SO^ plants reduction of




the uncontrolled rate of 26 to 56 Ib of S(>2 per ton of product to




the maximum permissible level of 4 Ib/ton is achieved at a cost (based




on a 1970 estimate) of $1.05 per ton of I^SO^ produced (Chemical




Construction Corporation, 1970).  While this cost may have advanced




substantially since then, even if the increase significantly exceeded




the overall rate of inflation, the per ton cost would still be only a




small fraction of the estimates for removing S(>2 from flue gas of




coal-fixed utilities (EPA, 1978d).




     In the secondary lead industry the incremental annualized costs




for combined SC>2 and particulate control over those for particulate




removal alone as primarily calculated are about $35,500 and $49,000,




respectively, for a 50-ton-day reverberating and blast furnace (Table




6-2).  On the basis of average uncontrolled emission rates and annual




production, each plant may be estimated to release at present 393 and




260 tons of 802 Per year> respectively.  With 80 percent reduction,




the costs per ton of 802 captured would be $113 and $236, respec-




tively.




     6.4.3.4  Level of Control.  Reduction of S02 in the gas stream




by well over 80 percent is commonly reported in the operation of




lime-based scrubber systems used by coal-fired power plants.  How-




ever, in the present context  these results must be considered with




some caution until more comprehensive data are available  from  long-




term operation.  The magnesium oxide and double alkali systems  are




designed for removal of 90 percent or more 802 ^rom utility plants





                                 6-27

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•n
OS

C
o
•^
CO
en
•H

5
co
cj
120


100



 80


 60


 40


 20
                100
                   200     300
400    500
                                               600
                             S02 Pounds/Hr
           2550  100 150  175
                           1 T/H
       CO
O  3  |	L
M 84
     5 I
     O -H
     e a
            1 - 1 - 1 - 1 - 1
                                    2 T/H
             25   50 75 100 125 150
                                ii  i
25
1 L
20
50
i
25
75
i
50
100
i
75
110 125
i
100
150
i
114
j x/ a
i i
125 15
                                                           4 T/H
                           FIGURE 6-4

                       SO2 EMISSIONS AT

                   SELECTED CONTROL LEVELS
                             6-28

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                             TABLE 6-2

                  ESTIMATED COSTS OF S02 CONTROL
                          PER TON CAPTURED
              Parameter
Reverberatory
   Furnace
  (dollars)
  Blast
 Furnace
(dollars)
   Annualized costs,  combined
     particulate and  S02 control

   Annualized costs,  particulate3
     removal alone, with venturi
     scrubbers (Table 4-6)

   Incremental costs, S02 removal

   Average S02 output, Ib/ton
     lead product^3

   Average annual production,
     tons/plant (1975)c

   Average uncontrolled S02
    187,000
        114.29
      6,875
 275,000
152,000
35,500
226,000
49,000
      75.71
   6,875
emissions, tons/year
Tons captured at 80% reduction
Average cost/ton captured
393
314
113
260
208
236
aAs discussed in Section 6.4.3.2.
bAdjustment of AP-42 estimates on basis that 70% metal charged is
 recovered as lead product.
cBureau of Mines (1976).
                                 6-29

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and have tested at this level in pilot or prototype operation.




Results in this range have been reported among others from the  GM




Parma system, the Mystic Station Unit No. 6 at Everett,  Massachu-




setts, the Firestone-Potts system, and the Gulf-Scholz prototype




system (PEDCo, 1977; EPA, 1978c).  In support of the Background




Information Document for proposed revision of NSPS applicable to




steam-generation of electric power, cost calculations for combined




removal of S02 and particulates were made for scenarios with 80 and




90 percent reduction of S02 (PEDCo, 1978).  One manufacturer pro-




ducing combined units for removal of both S02 and particulates  sup-




plied a brochure with sample cost calculations (for a coal-burning




utility boiler) on the basis of average S02 removal efficiency of




95 percent (Research-Cottrell, Inc., 1978).




     However, these results are based on very limited operation and




represent systems designed to remove 802 from combustion of coal or




high-sulfur fuel oil.  Technology transfer would be involved in




applying them to the secondary lead industry and any predictions as




to the success of such transfer could at this time be offered only




with reservations.




     The question may be raised regarding efficiency of particulate




removal by such combined systems.  Use of venturi scrubbers may be




considered marginal with reverberatory furnaces which emit very fine




particles of less than 0.4 microns and a mean size of 0.3 microns.
                                 6-30

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In the absence of specific data from tests and/or operating exper-




ience with such combined systems for secondary lead furnaces,  there is




some risk.  An owner who purchased such a system (at a cost from 10 to




25 percent above the price of venturi controls for particulates) and




then found his plant out of compliance with NSPS might face a severe




penalty.  If forced to obtain a fabric filter system in addition, the




owner would incur costs essentially double what they would have been




for control of particulates alone.  It may be noted, however,  that




some combined equipment is designed for such eventualities, by en-




abling improved collection efficiencies to be achieved through higher




fan horsepower to increase the pressure drop (Research-Cottrell, Inc.,




1978).




     6.4.4  Potential Impacts of SO? NSPS




     6.4.4.1  Environmental Effects.  Environmentally, the chief




potential impact of promulgating NSPS for S0£ emissions from second-




ary lead smelters will be the reduction of sulfur oxides discharged.




There will be some increase in energy requirements and fuel con-




sumption for control systems and an undetermined additional solid




waste disposal.




     Quantitatively, the estimates of potential environmental impacts




depend on the production rate of plants subject to NSPS.   Since  this




cannot be determined for a future time or even precisely estimated




from available data, it is necessary to indicate the probable effects




as a range of values.  As shown in Table 6-3, the uncontrolled  emis-




sions of S(>2 per year from a single plant  are estimated to range





                                 6-31

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                              TABLE 6-3

                ESTIMATED REDUCTIONS IN TOTAL ANNUAL
                  S02 EMISSIONS FROM FUTURE NSPS
Average rate uncontrolled            95
  S02 emissions, Ib/ton of
  product3

Estimated annual production       6,000         13,000      18,000
  of lead per plant, tons

Estimated uncontrolled              285            618         855
  annual SC^ emitted
  per plant, tons

Tons captured, per 10%               28.5           61.8        85.5
  reduction

Tons captured, 80%                  228            494         684
  reduction

Tons captured, 90%                  257            556         770
  reduction
aRate obtained as the average of separate estimates for blast and
 reverberatory furnaces (see Table 6-2).
                                  6-32

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from under 300 to over 850 tons, depending on assumptions made as to




the plant's annual production.  Tons of S02 removal per plant at a




level of 80 percent reduction accordingly vary from 228 to 684 per




year.  With an average of from three to four additional plants subject




to NSPS each year, the expected effect would then be to reduce S02




emissions by an additional annual amount of between about 700 and




2,700 tons.  At a level of 90 percent captive, an additional amount of




S02 between about 770 and 3,000 tons would be removed each year.




     Increased requirements for energy and fuel may be estimated from




the substantially higher pressure drop required in scrubber systems




for jointly controlling S(>2 and particulate emissions over the very




modest requirements for fabric filters.  The increased pressure drop




may be conservatively estimated at 50 to 80 inches water gauge with




corresponding horsepower increases of between 200 and 300.  To produce




the annual tonnages listed in Table 6-3, plants of about 50,100 and




150 tons/day may be estimated to operate about 2800 hr/yr.  On this




basis, an additional 400 to 600 kWh of energy would be required each




year with a Btu equivalence in the range of 4.2 to 6.4 x 10 •  The




fuel requirements in terms of barrels of oil average about 1000 bar-




rels/plant anually.  This figure represents an infinitesimal increment




to total U.S. oil consumption of over 6.4 billion barrels in 1976 and




is a very small fraction of 1 percent of even the average daily import




of more than 7 million barrels in the same year (Bureau of Mines,




1976).







                                 6-33

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     The question of increased disposal of solid waste from NSPS for




S02 from secondary lead smelters is problematical.  EPA (1973) ori-




ginally estimated that sludge collected from scrubbers could be dried




and the lead recycled.  Data are not available as to how much such




recycling is practiced in the secondary lead industry.




     Recycling of scrubber sludge after drying may or may not be




feasible, depending particularly on what reactive agents are used in




the scrubber.  Problems with the scale and reduced throughput may




constrain recycling.  Most of the dust trapped by fabric filter sys-




tems is reportedly recycled until the dust becomes too contaminated




with lead chloride.  At that time, part of the dust is leached or




landfilled (EPA, 1978b).  The study of priorities for development of




NSPS for additional stationary sources (Habegger et al., 1976)




regarded control of SC>2 from secondary lead furnances as involving a




trade-off between reduction of atmospheric emissions and aggravation




of the solid waste problem.




     In the absence of the necessary specific quantitative data, it




can only be concluded that some  fraction of the total amount of sludge




trapped would require disposal as solid wastes.  Since it is also not




known what fraction of particulate dust trapped by fabric filter sys-




tems is recycled, quantitative comparison on a dry-weight basis of the




solid waste disposal requirements with and without S0£ control is




not possible.  It is likely that the amount recycled from a baghouse




would be substantially higher than that regenerated by drying of




sludge.  One factor militating against recycling of sludge dried from






                                  6-3 A

-------
a scrubber that removes 802 is the presence of a high concentration

of sulfur.

      6.4.4.2  Potential Economic Effects.  The immediate economic

effect of any NSPS for reduction of S02 would be in terms of the

increased cost to secondary lead producers.  As noted previously, the

data are incomplete.  Compared with the expenses of providing scrub-

bing for particulates only, it appears that an increment of 10 to 20

percent is involved, although increases of up to one-third cannot be

ruled out, based on the modeling methodology employed for coal-fired

utility boilers (PEDCo, 1978).  In other words, a plant owner who

faces an increase in annualized costs of $33/ton of product from a

blast furnace for venturi control of particulates might find that

removal of 862 also requires his cost to be $43/ton (30 percent

higher).  This difference of $10/ton represents about 2 percent of the

estimated 1978 price of a ton of lead ($534) escalating the 1976 aver-

age value to 1978 prices.   Higher percentages would result from

different assumptions about the costs for scrubber systems with and

without 802 reduction specifically built in, but preliminary indica-

tions are that the additional cost for 802 control would be in the

range of 1 to 5 percent of the average price of a ton of lead.

     The increased costs may place an inequitable burden on the small

operator. The scale factor for combined scrubber systems is unknown;
 The price of lead has increased over the years but at a rate  less
 than the general inflation rate and less than costs of equipment and
 other materials as pointed out in discussing the fact that  lead
 prices have declined in terms of constant dollars.


                                 6-35

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however, in terms of cost per ton product, it is certain to favor the




large plant.




     Besides the effect on the small operator, there are other impor-




tant questions relating to the economic impacts of NSPS for control-




ling SOo from secondary lead smelters.  One of these is the extent




to which additional costs can be passed on to the consumer.  Limited




evidence suggests that no significant shift in demand would occur




because of cost increases for lead that are less than 10 percent (in




constant dollars).




     It appears that demand for lead will be more strongly influenced




by technologic developments and environmental restrictions that change




usage patterns.  Examples include attrition of the tetraethyl lead




market  for gasoline and the substitution  of other bases ranging from




water to titanium and zinc for interior paints.  Unquantified results




of studies show the demand for lead as largely insensitive to price.




The fact that there is little correlation between price increase and




rise in demand from year to year is consistent with  the hypothesis




that demand for lead is price inelastic (Charles River Associates,




1971; American Metal Market, 1972).




     Perhaps the most significant area of concern relates to the com-




petitive effects of controls for SC^.  The competitive position of




secondary lead vis-a-vis the primary product has been noted, as well




as the  increasing interchangeability of demand for lead from recycled




and virgin material.  At the time of proposing NSPS  for secondary lead




smelters, EPA (1973) noted the relatively higher costs of pollution






                                  6-36

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controls required of the primary industry and reasoned that the NSPS




would not weaken the competitive position of secondary material in the




total lead market.  This conclusion is not likely to be affected by




increased pollution control costs if they were on the order of no more




than 5 percent to secondary lead smelters.




     Within the secondary lead industry, howeverj the competitive




effects are likely to be more significant.  The trend to increasing




centralization of the secondary lead industry has been noted.  Evi-




dence indicates that a larger share of the market is going to large




companies and some small companies are being forced out.  It is prob-




lematic how much this existing trend might be accelerated by increases




on the order of 1 to 5 percent in production costs resulting from NSPS




for S02»  It is true that this range more than covers the net income




margin of small companies.  With a few companies dominating the mar-




ket, large producers might well absorb some or all of the additional




cost with the result that prices would be held down; lead would sell




at a price that did not fully cover increased expenses  for many of the




approximately 20 small operators.  Small  firms would then be operating




at a deficit and in time would be forced  out.




     It is also true that new plants subject to NSPS controls for




S(>2 would be placed at a disadvantage vis-a-vis existing plants.  To




analyze how the resulting cost differential would operate requires




more detailed data concerning control costs and the overall  capital




and annual expenses of new and existing plants, production rates, the
                                  6-37

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financial position of the parent companies and other factors that




affect position in the secondary lead market.  These issues indicate




that in addition to a study of technological feasibility, a comprehen-




sive economic analysis is required in any consideration of possible




NSPS for this pollutant.
                                 6-38

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7.0  CONCLUSIONS




7.1  Retention of Current NSPS




     Any change in current NSPS for secondary lead smelters would be




unwarranted at this time.  These standards are for particulates (0.022




gr/dscf) and for opacity «20 percent for blast and reverberatory




furnaces, <10 percent for pot furnaces).   When the standards were set




in 1974, they were based on control technology available at the time.




There are no indications that the state of this technology has changed




since then.  Best systems of control consisted of baghouses (fabric




filters) and venturi scrubbers, and today these still represent the




best technology for particulate removal.   Efficiencies of collection




systems required to meet current NSPS for particulates are in line




with efficiencies reported elsewhere, with manufacturer estimates of




performance, and with the extremely limited test data available.  The




standards are not too stringent, as evidenced by the fact that they




are being met and by the absence of reported difficulties in achieving




compliance.




     In regard to more stringent standards, there is no substantial




evidence available by which they would be justified.  The sample of




tests in which lower emission rates were achieved is entirely inade-




quate as a basis for any valid inferences about the general feasibil-




ity of meeting stricter standards.  A literature search indicates no




more stringent levels in existence locally as a basis for comparison.




The very small (submicron) size particulates  from reverberatory






                                  7-1

-------
furnaces, against which the efficiency of high-energy venturi scrub-




bers and to a lesser degree of baghouses declines as compared with




larger particles, raises technical questions about how adequate




existing control systems would be in general to meet significantly




stricter standards.




     Even if lower emission rates could be shown as entirely feasi-




ble, potential environmental gains would be marginal.  Lowering the




allowable particulate emissions to half those now permitted would




capture about 1 additional ton/year from a 50-ton/day plant (Table




4-8).  Total reductions from plants newly subject to NSPS in any one




year would not amount to 5 tons.




     From the scarcity of available test data, it is concluded that




there is a strong need to assemble over the immediate future all




obtainable results as they become available.  Analysis of an adequate




data base would be essential in determining whether technologic




improvements in control systems have occurred that are adequate to




support more stringent standards at a  future time.  Detailed data are




needed from tests by which to correlate performance of different con-




trol systems as a function of the type of material charged to the




furnace, particulate size distribution, inlet loading to the collec-




tor, parameters of the system (e.g., air-to-cloth ratios for fabric




filters, pressure drop and ratio of water to air flow for venturi




scrubbers), maintenance and other operating features of the smelter.




The relationship of percentage of opacity in the stack discharge from







                                 7-2

-------
a control system to particulate grain loadings would be of interest.




Physical considerations, as well as the analogy of results in other




industries, suggest that a percentage of opacity lower than 20 or even




10 percent is associated with meeting particulate standards; but




quantititative data are lacking.




7.2  No Specific NSPS for Lead Emissions




     It is concluded that no need exists for specific NSPS for lead




emissions from secondary smelters.  The consensus of available evid-




ence strongly indicates that the current standards for particulates




promote installation of the best systems of control technology for




lead.  The lead content of emissions vented by an adequately control-




led plant (i.e., one which meets or surpasses NSPS for particulates)




is no higher than 23 percent.  The resulting content of lead in the




air at ground level, even at points of maximum downwind concentration,




would not approach the critical point of 2 fig/nr* on a 24-hour aver-




age basis.  Specific NSPS for lead emissions would be essentially




redundant to current standards for particulates.  Considerable proce-




dural involvement and expense to officials, both within the government




and outside, would be required with no commensurate environmental




gain.




     It is also concluded that information regarding the rate and form




of lead emissions from secondary lead furnaces is somewhat incomplete,




in particular in regard to the disposition of lead-bearing particles




of different sizes.  Tests under both laboratory and operating field
                                  7-3

-------
conditions would be useful for comparing the distribution of lead-




bearing particles by size in baghouse catch and in the material vented




from the fabric filter control system.  Most of the available material




indicates that particulate control systems trap at least as high a




percentage of lead particles as that present in the inlet loading; but




the data are fragmentary, represent diverse sources, and are inconsis-




tent with preliminary reports of a more recent test.  Definitive




resolution of any question remaining requires a comprehensive material




balance on lead emissions from furnace to collector outlet.




     A significant conclusion in regard to the effect of particulate




controls is that the rate of lead emissions may have been reduced




about 2 tons/year/plant.  The cumulative reduction in total emissions




due to NSPS is estimated to be about 270 tons since 1974.




7.3  Study of Fugitive Emissions




     It is concluded that inadequate information is available on the




extent of fugitive emissions of lead-bearing particles from secondary




lead smelters.  It is not possible to assess how serious the impact of




such emissions may be in the vicinity of the plants or to determine




whether regulatory standards applying specifically to such emissions




are warranted.  For example, it has been suggested that control of




fugitive emissions from lead smelters may be necessary to meet NAAQ8




for lead (EPA, 1978b).  In addition to this question and the determi-




nation of typical emission rates from fugitive sources, investigation




is warranted into the relative contribution of process- and







                                  7-4

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site-related sources to lead particulate matter in the atmosphere and




soil around secondary smelters, as discussed in Chapter 6*




     It is also concluded that applicable technologies and procedures




for control of fugitive emissions should be investigated with the




specific objective of determining their efficiency quantitatively.




These include techniques such as flash agglomeration and improvements




and/or additions to hooding and venting to prevent escape of parti-




culate matter during smelting.  Among procedures warranting investi-




gation are the effect of maintenance practices, dust storage in open




piles, and dust management around the smelter.  It is concluded that




such investigations would provide information necessary not only to




determine whether fugitive emissions should be specifically regulated




and if so at what level, but also in deciding what form a standard




should take (e.g., in terms of maximum allowable emissions or of




prescribed standards of equipment and procedures).




7.4  Investigation of NSPS for SO? Emissions




     It is concluded that NSPS to control S0£ emissions from sec-




ondary lead smelters appear technologically feasible at this time but




demonstration is lacking.  The total output of S02 is not high from




the industry and more especially from plants that would become newly




subject to NSPS in any one year.  However, the uncontrolled emission




rate in pounds per ton of lead product appears significant in compari-




son with that from controlled sources.  The average or  typical rate of




80 Ib/ton of metal charged from a reverberatory furnace is 20 times
                                 7-5

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the permissible rate per ton of product from sulfuric acid plants (40




CFR 60).  Although the average rate (53 Ib/ton of metal charged) is




lower for blast furnaces, the estimated range extends up to more than




150 Ib/ton.  Control methods are now technologically feasible to




reduce SC>2 emissions by about 80 to 90 percent over the rate of




emissions from the furnace stack.  However, it is not concluded that




NSPS for SC>2 are warranted for secondary lead smelters at this time.




     An important consideration in regard to possible NSPS for SC>2




is potential cost to the secondary lead industry of additional con-




trols.  Information on their cost and effects is inadequate to support




any conclusions.  Best available evidence indicates that reduction of




S02 pollution and simultaneous control of particulates could be




achieved at capitalization costs in the probable range of 10 to 20




percent over the cost of a venturi scrubber system to control particu-




lates.  This increment would not exceed 5 percent of the average price




of a ton of lead product and more likely is within 2 to 3 percent.  It




also appears that this additional expense would have little effect on




the marketability of secondary lead.  Demand for lead from both pri-




mary and secondary sources seems to be relatively inelastic.




     It is concluded that some danger to small firms operating lead




smelters would result from the promulgation of NSPS for S(>2.  It is




also deemed probable that new smelters required to undergo the expense




of providing S02 controls would face a competitive disadvantage
                                  7-6

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relative to existing plants, the extent of which cannot be determined




from current information.  In view of the limited manufacturer's data




obtainable and the generality of the estimates provided, further




investigation of costs is necessary.  In particular, consideration




should be given to effects on* small companies and to the competitive




position of new plants vis-a-vis existing ones.




     Because the uncontrolled rate of S(>2 emissions from secondary




lead smelters appears significant and because transfer of control




technology appears promising, it is concluded that the question of




NSPS for S02 warrants detailed investigation with emphasis on costs




and affordability.
                                 7-7

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8.0  RECOMMENDATIONS




8.1  Current NSPS for Particulates and Opacity




     For the present, NSPS should be retained at the current level of




0.022 gr/dscf for particulates and <20 percent for opacity «10




percent for pot furnaces).




     Prior to the next review, comprehensive data should be gathered




from detailed tests and analyzed to determine performance of control




devices as a function of both system parameters and operating charac-




teristics of the smelter, as indicated in Section 7.1.




8.2  Comprehensive Data on Lead Content of Emissions




     While no explicit NSPS regarding lead emissions from secondary




smelters are recommended at this time, it is recommended that compre-




hensive data be collected on the disposition of lead-bearing particles




emitted from furnaces.  As discussed in Section 7.2, tests under




laboratory and field conditions are recommended with sufficiently




detailed results to construct materials balance of the lead emissions




by blast and reverberatory furnaces and to determine distribution of




lead particles by size in the inlet loading to and output from the




control system.  It is recommended that tests be conducted to define




the emission rate of lead from control systems.




8.3  Fugitive Emissions




     An investigation should be made of the extent to which fugitive




emissions represent a problem at secondary lead smelters controlled




under NSPS.  Research and development should also be conducted into






                                  8-1

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the most effective technologies and procedures for controlling such

emissions from both process- and site-related activities at secondary

lead smelters.  These investigations should be directed toward

developing data by which to determine whether a specific NSPS to

cqntrol fugitive emissions at secondary level plants is warranted and

what form the regulation should take.

8.4  NSPS for SO? Emissions

     It is recommended that action be taken to investigate the

question of NSPS for S02 emissions from secondary lead smelters.

Further recommendations relating to  specific  investigations are:

     •  costs, both capitalization and annualized (including operat-
        ing and maintenance expenses), of such systems with particu-
        lar reference to costs  that  might be  incurred by relatively
        small smelters (less than 50-tons/day capacity) if such new
        plants are brought on-line or existing ones of this size are
        modified or reconstructed.
     •  economic impacts of a regulatory standard  for SC>2.
                                  8-2

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9.0  REFERENCES

American Metal Market,  1972.   Metal Statistics 1972:   The Purchasing
     Guide of the Metal Industries.  65th Edition.   Fairchild
     Publications, Inc.  New York,  N.Y.

American Air Filter Company,  Inc.,  1973.   Manufacturers'  brochures
     supplied by private communications.   Louisville,  Kentucky.

Bechtel Corporation, 1978.   Flue Gas Desulfurization Systems:  Design
     and Operating Parameters, SC<2  Removal Capabilities,  Coal Prop-
     erties and Reheat, Vols. I and II.   Prepared for Office of
     Research and Development, U.S. Environmental Protection Agency,
    ! EPA-600/7-78-030.   Research Triangle Park,  N.C.
    I
Brobst, D.A. and W.P. Pratt,  eds.,  1973.   U.S. Mineral Resources.
 -'  Geological Professional Paper  820.   U.S. Government  Printing
     Office.  Washington, D.C.

Chapman, J.D., and J.C. Sherman, eds., 1973.  Oxford Regional
     Economic Atlas—United States  and Canada.  The Cartographic
     Department of the Clarendon Press.   Oxford.

Charles River Associates, 1971.  The Effects of Pollution Control on
     Nonferrous Metals Industries:   Lead.  Cambridge,  Mass.  NTIS PB-
     207-155.

Chemical Construction Corporation,  1970.   Engineering Analysis of
     Emissions Control Technology for Sulfuric Acid Manufacturing
     Processes.  Final Report.  Public Health Service, National Air
     Pollution Control Administration, Publication No. PB-190-393.
     Vol. I.

Combustion Equipment Associates, 1978.  Personal Communication with
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Cooper, H. B. Jr., and J. C. Sherman, eds., 1973.  Oxford Regional
     Economic Atlas—United States  and Canada.  Oxford University
     Press.  New York, N.Y.

Danielson, J. A. ed., 1973.  Air Pollution Engineering Manual.
     2nd Edition.  U.S. Environmental Protection Agency.  Office of
     Air & Water Programs.  Research^ Triangle Park, N.C.

Davis, W. E., 1973.  Emission Study of Industrial Sources of Lead Air
     Pollutants.  Prepared by W. E. Davis and Associates for U.S.
     Environmental Protection Agency.  Research Triangle Park, N.C.
     NTIS PB-223 652.
                                  9-1

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Engineering-Science, Inc., 1971.  Exhaust Gases for Combustion and
     Industrial Processing.  Washington, D.C.  October 2.

Engineering-Science, Inc., 1977.  Inspection Manual for Enforcement
     of New Source Performance Standards, Secondary Lead Smelters.
     Prepared for U.S. Environmental Protection Agency, Division of
     Stationary Source Enforcement.  EPA-340/1-77-001.  Washington,
     D.C.

Ferb, R. J. and N. J. Stevens, Research-Cottrell, Inc., 1978.
     Scrubber Proves Out for Industrial Size Boiler.  Power
     Engineering.

Fine, P., H. W. Rasher, and S. Wakesberg, eds., 1973.  Operation in
     the Non-ferrous Scrap Metal Industry Today.  National Associa-
     tion of Secondary Material Industries, Inc.  New York, N.Y.

Habegger, J., R. R. Cirillo, and N. F.  Sather, 1976.  Priorities and
     Procedures for Development of Standards of Performance for New
     Stationary Sources of Atmospheric  Emissions.  Prepared for the
     Environmental Protection Agency by the Argonne National Labora-
     tory.  EPA-450/3-76-020.  Research Triangle Park, N.C.

Hardison, L.C., et al., 1970.  Study of Technical and Cost Informa-
     tion for Gas Cleaning Equipment in the Lime and Secondary
     Non-Ferrous Metallurgical Industries.  Industrial Gas Cleaning
     Institute.  Rye, N.Y.  NTIS, PB-198-137.

Hunt, W. F., C. Pinkerton, 0. McNulty,  and J. Creason, 1971.  A Study
     in Trace Element Pollution of Air  in 77 Midwestern Cities.  In:
     Trace  Substances  in Environmental  Health.  IV.  D. P. Hemphill,
     ed., University of Missouri Press, Columbia, Mo.

Kaplan, N.  and M. A. Maxwell, 1978.  Flue Gas Desulfurization of Com-
     bustion Exhaust Gases.  Presented  at the Third National Confer-
     ence,  Interagency Energy/Environment R&D Program. June 1 fit 2.
     Washington, D.C.

Kinkley, M.L., and R.B. Neveril, 1976.  Capital and Operating Costs
     of Selected Air Pollution Control  Systems.  Prepared  for U. S.
     Environmental Protection Agency.   Office of Air and Waste
     Management.  Office of Air Quality Planning and Standards.
     EPA-450/3-76-014.  Research Triangle Park, N.C.

Levine, S.  N., ed., 1978.  The Dow Jones-Irwin Business Almanac.
     Dow Jones-Irwin.  Homewood, Illinois.
                                  9-2

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Linzon, L.N., B.L. Chai, P.J. Temple,  R.G.  Pearson,  and M.S.  Smith,
     1976.  Lead Contamination of Urban Soils and Vegetation  by
     Emissions from Secondary Lead Industries.  Journal of Air Pollu-
     tion Control Association.  Vol.  26, No.  7.

Los Angeles County, 1978.  Personal communication from Mr.
     Williamson, July 7.  Alhambra, Calif.

Mantell, C.L., 1975.  Solid Wastes:  Origin,  Collection,  Processing,
     and Disposal, Chapter V.6:   Particulate  Collection in a  Lead
     Smelting Plant.  John Wiley & Sons.  New York,  N.Y.

MITRE Corporation, 1977.  Standard Support  and Environmental  Impact
     Statement:   National Ambient Air Quality Standard for Lead.
     Vol. I.  MTR-7525.  McLean, Va.

MITRE Corporation, 1978.  Regional Views on NSPS for Selected Cate-
     gories.  MTR-7772.  McLean, Va.

National Institute for Occupational Safety and Health, 1976.   Secon-
     dary Lead Smelters in the United States.  Technical Evaluation
     and Review Branch, Washington, D.C.

Patel, V.P. and L. Gibbs, 1978.  Effects of Alternative New Source
     Performance Standards on Flue Gas Desulfurization System Supply
     and Demand.  Prepared for U.S. Environmental Protection Agency
     by PEDCo Environmental, Inc.  EPA-600/7-78-003.  Washington,
     D.C.

PEDCo Environmental, Inc., 1977.  Summary Report - Flue Gas Desul-
     furization Systems.  Prepared for U.S. Environmental Protection
     Agency.  Research Triangle Park, N.C.

PEDCo Environmental, Inc., 1977a.  Summary Report on S02 Control
     Systems for Industrial Combustion and Process Sources.  Vol. VI.
     Prepared for Industrial Environmental Research Laboratory. U.S.
     Environmental Protection Agency.  Research Triangle Park, N.C.

PEDCo Environmental, Inc., 1978.  Particulate and Sulfur Dioxide
     Emission Control Costs for Large Coal-Fired Boilers.
     EPA-450/3-78-007.

Petkus, E.J., J.W. Lin, and C.G. Jansen, 1978.  Lead Emissions  from
     Industrial Vehicle and Combustion Sources.  Presented at the
     71st Annual Meeting of the Air Pollution Control Association.
     Houston, Tex.  June 25-30.  Department of Environmental Control.
     Chicago, 111.
                                 9-3

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Research-Cottrell, Inc., 1978.   Letter and manufacturer's brochures
     submitted by private communication from Mr. James E. McCarthy.
     Industrial Division.  Bound Brook, N.J.

Roberts, T.M., T.C. Hutchinson, J. Paciga, A. Chattopadhyay,  R.E.
     Jarvis, J. Van-Loon, D.K.  Parkinson, 1974.  Lead Contamination
     Around Secondary Lead Smelters:  Estimation of Dispersal and
     Accumulation by Humans.  Science.  Vol. 186.

Salisbury, J.K., ed., 1967.  Kent's Mechanical Engineers' Handbook,
     Power Volume.  12th Edition.  John Wiley & Sons, New York,
     N.Y.

Scruggs, M., 1977*  Personal Communication.  Monitoring and Data
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Soderberg, H. E., 1974.  Environmental, Energy and Economic Consid-
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     Vol. 16, No. 12.

Spitz, A. W., 1975.  Control of Emissions from Secondary Metals
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     Annual Meeting of the Air Pollution Control Association.
     Boston, Mass.  June 15-20.

Texas Air Control Board, 1974.   A Report of Typical Element Emissions
     from Texas Smelters.  Austin, Tex.

Turner, D. B., 1969.  Workbook of Atmospheric Dispersion Estimates.
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     Washington, D.C.

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     Yearbook, 1971:  Vol. I.  Metals, Minerals, and Fuel.  U.S.
     Government Printing Office, Washington, D.C.

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     Yearbook, 1975 (Preprint).  U.S. Government Printing Office,
     Washington, D.C.

U.S. Department of Interior, Bureau of Mines, 1976a.  Majority of
     the Secondary Lead Smelters.  Washington, D.C.
                                 9-4

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U.S. Department of Interior,  Bureau of Mines,  1977.   Lead-1977.
     Minerals Commodity Profiles,  MCP-9.   Pittsburgh,  Pa.

U.S. Department of Interior,  Bureau of Mines,  1978.   Personal
     Communications with Mr.  J. A. Rathjen,  Washington,  D.C.

U.S. Environmental Protection Agency,  1973.   Background  Information
     for Proposed New Source  Performance  Standards:   Asphalt  Concrete
     Plants.  Office of Air and Water Programs,  Office of  Air Quality
     Planning and Standards.   Research Triangle  Park,  N.C.

U.S. Environmental Protection Agency,  1975.   Compilation of Air
     Pollutant Emission Factors, 2nd Edition.  AP-42.   Office of Air
     and Waste Management.  Research Triangle Park,  N.C.

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     Report.  Office of Air and Waste Management.  Office of  Air
     Quality Planning and Standards.  Research Triangle Park, N.C.

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     Lead Air Emissions.  Office of Air Quality  Planning and
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     Triangle Park, N.C.

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     Generating Units.  EPA-450/2-78-007a. -Research Triangle Park,
     N.C.

U.S. Environmental Protection Agency, 197frd.  Trip Report to Paul S.
     Bergsoe.  Bergsoe and Son Secondary Lead Smelter.  Internal
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     Environmental Research Laboratory, Cincinnati, Ohio.

U.S. Environmental Protection Agency (1979).  Personal  communication
     from Region 4, Atlanta,  Georgia.  January 31.
                                  9-5

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U.S. Interstate Commerce Commission, 1974. ^.Final Environmental
     Impact Statement Ex Parte No. 295 (Sub. No. 1)  Increased
     Freight Rates and Charges, 1973 - Recyclable Materials.
     Prepared by Office of Proceedings, Interstate Commerce
     Commission, with the assistance of The MITRE Corporation.
     Washington, D.C.

Yankel, J., I. H. von Linden and S. D. Walter, 1977.  The Silver
     Valley Lead Study:  The Relationship between Childhood Blood
     Lead Levels and Environmental Exposure.  Journal of the Air
     Pollution Control Association 27(8):763.

Ziradahl, R. L., 1976.  Entry and Movement in Vegetation of Lead
     Derived from Air and Soil Sources.  Journal of the Air Pollution
     Control Association 26(7):655.
                                  9-6

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
1. REPORT NO.
       EPA-450/3-79-015
              3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
              S. REPORT DATE
       A Review of  Standards of Performance for New
       Stationary Sources - Secondary Lead Smelters
              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
       John W. Watson  and Kathryn  J.  Brooks
              8 PERFORMING ORGANIZATION REPORT NO.
                MTR-7871
9. PERFORMING ORGANIZATION NAME AND ADDRESS

  Metrek Division of the MITRE Corporation
  1820 Dolley  Madison Boulevard
  Me Lean, VA   22102
              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                68-02-2526
12. SPONSORING AGENCY NAME AND ADDRESS
              13. TYPE OF REPORT AND PERIOD COVERED
  DAA for Air  Quality Planning and Standards
  Office of Air,  Noise, and  Radiation
  U.  S. Environmental Protection Agency
  Research Triangle Park, NC  27711     	
              14. SPONSORING AGENCY CODE
                EPA  200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
    This report  reviews the current Standards of  Performance for New Stationary
    Sources:   Subpart L - Secondary Lead Smelters.   It includes a  summary of the
    current standards, the status  of applicable control technology,  and the ability
    of secondary lead smelters to  meet the current  standards.  Compliance test
    results are  analyzed and a recommendation made  to retain the current standard.
    Information  used in this report is based upon data available as  of November
    1978.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
a.
                  DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. cos AT I Field/Group
18. DISTRIBUTION STATEMENT

  Release Unlimited
19. SECURITY CLASS (This Report)
  Unclassifffed
21. NO. OF PAGES

     123
                                                20. SECURITY CLASS (Thispage)
                                                  Unclassified
                            22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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