>Note: This is a reference cited in AP 42, Compilation of Air Pollutant Emission Factors, Volume I Stationaryl
\Point and Area Sources, AP42 is located on the EPA web site at www.epa.gov/ttn/chief/ap42/ •
>The file name refers to the reference number, the AP42 chapter and section. The file name !
l"ref02_c01s02.pdf" would mean the reference is from AP42 chapter 1 section 2. The reference may be f
ifrom a previous version of the section and no longer cited. The primary source should always be checked.;
AP-42 Section Number: 12.15
Reference Number:
Title:
Lead Acid Battery Manufacture -
Background Information for Proposed
Standards
EPA 450/3-79-028a
US EPA
November
1979
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TABLE OF CONTENTS (continued)
Page
4.0 EMISSION CONTROL TECHNIQUES 4-1
4.1 Grid Casting Machines and Furnaces 4-2
4.2 Paste Mixer 4-9
4.3 Three-Process Operation (Stacking, Burning,
and Assembly) 4-17
4.4 Lead Oxide Production 4-24
4.5 Lead Reclamation 4-27
4.6 Formation 4-32
4.7 Control Performance Summary 4-38
5.0 MODIFICATIONS AND RECONSTRUCTION 5-1
5.1 General 5-1
5.2 Applicability of 40 CFR 60.14 and 60.15 to
the Lead-Acid Battery Manufacturing Industry 5-4
5.3 Illustrative Examples 5-9
6.0 EMISSION CONTROL SYSTEMS 6-1
6.1 Application of Control Techniques 6-2
6.2 Selected Control Alternatives 6-2
6.3 Effectiveness of Selected Lead Emissions
Control Systems 6-5
7.0 ENVIRONMENTAL IMPACT 7-1
7.1 Air Pollution Impact 7-1
7.2 Water Pollution Impact 7-10
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TABLE OF CONTENTS (continued)
7.3 Solid Waste Impact 7-11
7.4 Energy Impacts 7-20
7.5 Other Environmental Impacts 7-24
7.6 Other Environmental Concerns 7-24
8.0 ECONOMIC IMPACTS 8-1
8.1 Industry Economic Profile 8-1
8.2 Cost Analysis of Alternative Control Systems 8-12
8J3 Other Cost Considerations 8-72
8.4 Economic Impact of Control Alternatives 8-85
9.0 RATIONALE FOR THE PROPOSED STANDARDS 9-1
9.1 Selection of Source for Control 9-1
9.2 Selection of Pollutants and Affected
Facilities 9-1
9.3 Selection of Best System of Emission
Reduction Considering Costs 9-6
9.4 Selection of the Format of the Proposed
Standard 9-11
9.5 Selection of Emission Limits 9-15
9.6 Opacity Standards 9-21
9.7 Modification/Reconstruction Considerations 9-23
9.8 Selection of Monitoring Requirements 9-23
9.9 Selection of Performance Test Methods 9-24
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TABLE OF CONTENTS (continued)
APPENDIX A EVOLUTION OF THE SELECTION OF THE BEST
SYSTEM OF EMISSION REDUCTION A-l
APPENDIX B INDEX TO ENVIRONMENTAL IMPACT
CONSIDERATIONS B-l
APPENDIX B INDEX TO ENVIRONMENTAL IMPACT
CONSIDERATIONS B-l
APPENDIX C SUMMARY OF TEST DATA C-l
APPENDIX D EMISSION MEASUREMENT AND CONTINUOUS
MONITORING °-l
APPENDIX E ENFORCEMENT ASPECTS E-l
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LIST OF FIGURES
No. Page
3-1 Trends in Lead-Acid Battery Shipments and in Gross 3-3
National Product
3-2 United States Shipment of SLI Lead-Acid Batteries 3-7
from 1947 to 1974
3-3 A Lead-Acid storage Battery 3-10
3-4 Components of a Battery Element 3-11
3-5 Process Flow Diagram Showing Uncontrolled Lead 3-13
Emission Factors for Lead-Acid Battery Manufacture
4-1 Particle Size of Particulate Emissions from a Grid 4-3
Casting Operation
4-2 Uncontrolled Grid Casting Emissions 4-5
4-3 Controlled Emissions from Plant D Rotp-Clone 4-6
Controlling Grid Casting and Mixer Emissions
4-4 Graphic Representation of Emissions Vented to Plant D 4-7
Roto-Clone Over a Period of Time
4-5 Particle Size of Particulate Emissions From a Paste 4-11
Mixer
4-6 Uncontrolled Paste Mixing Emissions 4-15
4-7 Controlled Paste Mixing Emissions 4-16
4-8 Particle Size of Particulate Emissions From a Three- 4-19
Process Operation
4-9 Particle Size of Particulate Emissions From a Three- 4-20
Process Operation
4-10 Uncontrolled Three-Process-Operation Lead Emissions 4-21
4-11 Controlled Three-Process-Operation Lead Emissions 4-22
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LIST OF FIGURES (continued)
No. Page
4-12 Emissions from Ball Mill Lead Oxide Production 4-26
Using a Baghouse for Product Recovery (gr/dscf)
4-13 Particle Size of Particulate Emissions From a Lead 4-28
Reclaim Furnace
4-14 Uncontrolled Lead Emissions Exhaust to Spray Tower 4-30
Controlling Lead Reclaim Emissions
4-15 Controlled Lead Emissions from Spray Tower 4-31
Controlling Lead Reclaim Emissions
4-16 Average Uncontrolled Lead Emissions from Tested 4-36
Facilities
4-17 Average Controlled Lead Emissions from Tested 4-37
Facilities
4-18 Average Uncontrolled Lead Emissions from Tested 4-39
Facilities
4-19 Average Controlled Lead Emissions from Tested 4-40
Facilities
5-1 Method of Determining Whether Changes to Existing 5-2
Facility Constitute a Modification or Reconstruction
Under 40 CFR 60.14 and 60.15
7-1 Maximum Ambient Impact - 1-h Maximum 7-3
7-2 Maximum Ambient Impact of Lead-Acid Battery 7-4
Manufacturing Plants for Various Plant Production
Rates - 24-h Maximum
7-3 Maximum Ambient Impact of Lead-Acid Battery 7-5
Manufacturing Plants for Various Plant Production
Rates - Annual mean
8-1 Regional Distribution of Lead-Acid Battery Plants 8-6
8-2 Reported Installed Costs of Fabric Filter Control 8-24
Systems Compared with Estimated Cost Curves Used
in this Study (4th Quarter 1977 Dollars)
ix
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LIST OF FIGURES (continued)
No. Page
8-3 Reported Installed Costs of Wet Scrubber Systems 8-25
Compared with Estimated Cost Curves Used in this
Study
8-4 Cost-Effectiveness of Model Plant Control 8-70
Alternatives
C-l Production Flow Diagram, Plant B C-2
C-2 Production Flow Diagram, Plant D C-8
C-3 Production Flow Diagram, Plant G C-14
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LIST OF TABLES
No. Page
3-1 United States Consumption of Lead (in Gigagrams) 3-4
3-1A United States Consumption of Lead (in Short Tons) 3-5
3-2 Summary of SLI Battery Use; 1974 3-6
3-3 Nationwide Emissions of Lead from the Manufacture 3-14
of Lead-Acid Storage Batteries (1975)
3-4 Typical Formulas for Positive and Negative Battery Pastes 3-17
4-1 Characteristics of Control Devices Tested 4-41
5-1 Annual Asset Guideline Repair Allowance Percentages for 5-4
Specified Facilities per IRS Publication 534 (1975 Edition)
5-2 F.O.B. Price of Various Components for Lead-Acid Battery 5-5
Hanufacturing Facilities
6-1 Summary of Control Systems Applicable to Lead-Acid Battery 6-3
Manufacturing Facilities
6-2 Selected Control Alternatives for Lead-Acid Battery 6-4
Manufacturing Industry
6-3 Uncontrolled Emissions of Lead from Lead-Acid Battery 6-6
Manufacturing Facilities
6-4 Estimated Lead Collection Efficiencies of Selected Control 6-7
Systems
6-5 Effect of Control Alternatives of Lead Emissions from 6-8
Various Sized Battery Manufacturing Plants
6-5A Effect of Control Alternatives of Lead Emissions from 6-9
Various Sized Battery Manufacturing Plants (English Units)
6-6 Effect of Control Alternatives on Lead Emissions Compared 6-10
with SIP Controls
6-6A Effect of Control Alternatives on Lead Emissions Compared 6-11
with SIP Controls (English Units)
xi
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LIST OF TABLES (continued)
No. Page
7-1 Approximate Lead Emission Rates and Maximum Resultant 7-6
Ground-Level Lead Concentration for Two Plant Sizes
7-2 Allowable Ambient Air Concentrations of Sulfuric-Acid 7-9
Mist
7-3 Lead Content of Scrubber Slowdown and Effect on Wastewater 7-12
System of a 6500-BPD Plant (Metric Units)
7-3A Lead Content of Scrubber Slowdown and Effects on Wastewater 7-13
System of a 6500-BPD Plant (English Units)
7-4 Sources, Quantities, and Disposition of Waste Materials 7-14
(Metric Units)
7-4A Sources, Quantities and Disposition of Waste Materials 7-15
(English Units)
7-5 Estimated Daily Process Solid Wastes Generated at Lead-Acid 7-18
Battery Manufacturing Facilities
7-6 Potential Solid Waste Impacts of a Battery Plant Using 7-20
Control Alternative I
7-7 Energy Requirements for Lead-Acid Battery Manufacturing 7-22
Plants and Emission Control Equipment (Metric Units)
7-7A Total Energy Requirements for Lead-Acid Battery 7-23
Manufacturing Plants and Emission Control Equipment
(English Units)
8-1 Consumption of Lead in the United States by Product 8-2
8-2 Leading Domestic Storage Battery Manufacturers 8-3
8-3 Battery Shipments by Domestic Producers 8-8
8-4 Replacement Battery Shipments - Automobiles 8-9
Xll
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LIST OF TABLES (continued)
No. Page
8-6 Selected Control Alternatives for Lead-Acid Battery 8-13
Manufacturing Industry
8-7 Typical Uncontrolled Exhaust Parameters for Battery 8-14
Manufacturing Facilities (Metric Units)
8-7A Typical Uncontrolled Exhaust Parameters for Battery 8-15
Manufacturing Facilities (English Units)
8-8 Uncontrolled Lead Emissions from Various Lead-Acid • 8-16
Battery Manufacturing Facilities
8-9 Air Pollution Control Equipment Costs for Lead-Acid 8-19
Battery Manufacturing Facilities (Metric Units)
8-9A Air Pollution Control Equipment Costs for Lead-Acid 8-20
Battery Manufacturing Facilities (English Units)
8-10 Component Capital Cost Factors for a Fabric Filter 8-22
as a Function of Equipment Cost, Q
8-11 Component Capital Cost Factors for a Wet Collector 8-23
(Scrubber or Mist Eliminator) as a Function of
Equipment Cost, Q
8-12 Items Used in Computing Total Annualized Costs 8-27
8-13 Calculation of Annualized Costs of Air Pollution
Control Systems 8-28
8-14 Utilities and Labor Required for Operation of Various 8-30
Control Devices for Lead-Acid Battery Manufacturing
Facilities (Metric Units)
8-14 Utilities and Labor Required for Operation of Various 8-31
A Control Devices for Lead-Acid Battery Manufacturing
Facilities (English Units)
8-15 Cost of Emission Control Systems for Control 8-36
Alternative I for New Plants
xm
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LIST OF TABLES (continued)
No. Page
8-16 Cost of Emission Control Systems for Control 8-37
Alternaitve II for New Plants
8-17 Cost of Emission Control Systems for Control 8-38
Alternative III for New Plants
8-18 Cost of Emission Control Systems for Control 8-38
Alternative IV for New Plants
8-19 Cost of Emission Control Systems for Control 8-40
Alternative V for New Plants
8-20 Cost of Emission Control Systems for Control 8-41
Alternative VI for New Plants
8-21 Cost of Emission Control Systems for Control 8-42
Alternative VII for New Plants
8-22 Cost of Emission Control Systems for Control 8-43
Alternative VIII for New Plants
8-23 Costs of Control Systems Required to Meet Typical 8-44
SIP Regulations
8-24 Capital Costs of Lead Emissions Control From New 8-45
Lead-Acid Battery Manufacturing Facilities -
100 BPD Plant
8-25 Capital Costs of Lead Emissions Control From New 8-46
Lead-Acid Battery Manufacturing Facilities -
250 BPD Plant
8-26 Capital"Costs of Lead Emissions Control From New 8-47
Lead-Acid Battery Manufacturing Facilities -
500 BPD Plant
8-27 Capital Costs of Lead Emissions Control From New 8-48
Lead-Acid Battery Manufacturing Facilities -
2000 BPD Plant
xiv
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LIST OF TABLES (continued)
No. Page
8-28 Capital Costs of Lead Emissions Control From New 8-49
Lead-Acid Battery Manufacturing Facilities -
6500 BPD Plant
8-29 Net Capital Costs of Control Alternatives for Lead- 8-50
Acid Battery Manufacturing Plants
8-30 Annualized Costs of Lead Controls Allocable to a 8-52
New Source Performance Standard for a New 100 BPD
Plant
8-31 Annualized Costs of Lead Controls Allocable to a 8-53
New Source Performance Standard for a New 250 BPD
Plant
8-32 Annualized Costs of Lead Controls Allocable to a 8-54
New Source Performance Standard for a New 500 BPD
Plant
8-33 Annualized Costs of Lead Controls Allocable to a 8-55
New Source Performance Standard for a New 2000 BPD
Plant
8-34 Annualized Costs of Lead Controls Allocable to a 8-56
New Source Performance Standard for a New 6500 BPD
Plant
8-35 Annualized Costs of Sulfuric-Acid Mist Controls for 8-57
New Facilities
8-36 Component Capital Cost Factors for a Retrofit 8-60
Installation of a Fabric Filter as a Function
of Equipment Cost, Q
8-37 Component Capital Cost Factors for a Retrofit 8-61
Installation of a Wet Collector (Scrubber or Mist
Eliminator) as a Function of Equipment Cost, Q
8-38 Costs of Lead Emissions Control Alternatives for an 8-62
Existing 100 BPD Plant
xv
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LIST OF TABLES (continued)
No.
8-39 Costs of Lead Emissions Control Alternatives for an 8-63
Existing 250 BPD Plant
8-40 Costs of Lead Emissions Control Alternatives for an 8-64
Existing 500 BPD Plant
8-41 Costs of Lead Emissions Control Alternatives for an 8-65
Existing 2000 BPD Plant
8-42 Costs of Lead Emissions Control Alternatives for an 8-66
Existing 65— BPD Plant
8-43 Sulfuric-Acid Mist Control Costs for Existing 8-67
Reconstructed/Modified Battery Formation Facilities
8-44 Annualized Costs Associated with Water Pollution 8-74
Control (4th quarter - 1977 dollars)
8-45 Annualized Costs Associated with Solid Waste Disposal 8-75
for Plants Using Lime Neutralization (4th quarter -
1977 dollars)
8-46 Annualized Costs Associated with Solid Waste Disposal 8-76
for Plants Using Caustic Soda Neutralization (4th
quarter - 1977 dollars)
8-47 Cost Factors and Assumptions for OSHA Compliance 8-77
(Metric Units)
8-47 Cost Factors and Assumptions for OSHA Compliance 8-78
A (English Units)
8-48 Estimated OSHA Compliance Costs for Lead-Acid 8-80
Battery Manufacturing Plants
8-49 Compliance Testing Costs Applicable to New Source 8-82
Performance Standards for Lead-Acid Battery
Manufacturing Facilities
xvi
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LIST OF TABLES (continued)
8-50 Annualized Costs of Compliance with Environmental 8-83
Regulatory Requirements for Typical New Lead-Acid
Battery Manufacturing Plants
8-51 Sulfuric-Acid Mist Control Costs - Existing Plant 8-91
Wet/Dry or Dry Forming
8-52 Incremental Annual Sulfuric-Acid Mist and Lead NSPS 8-92
Control Costs; Reconstructed/Modified Plant - Control
Alternative I
8-53 Incremental Annual Sulfuric-Acid Mist and Lead NSPS 8-92
Control Costs; New Plant - control Alternative I
8-54 Baseline Economics; Capital Investment for Existing 8-106
Lead-Acid Battery Plants; Wet and Dry Formation
8-55 Baseline Economics, Capital Investment for Existing 8-110
Lead-Acid Battery Plants, Wet Formation Only
8-56 Estimated Financial Data for Small Lead-Acid Battery 8-111
Manufacturing Plants Before NSPS Lead and Sulfuric-
Acid Mist Controls
8-57 Estimated Financial Data for Small Lead-Acid Battery 8-112
Assembling Plants Before NSPS Lead and Sulfuric-Acid
Mist Controls
8-58 Return on Investment Impact, Small Lead-Acid Battery 8-114
Plants Cost Pass-Through
8-59 Cost Pass-Through Per Battery, Sulfuric-Acid Mist 8-116
Control Only, Existing Plants
8-60 Return on Investment Impact, Small Lead-Acid Battery 8-119
Plants Cost Pass Through
8-61 Cost Pass-Through Per Battery, Sulfuric-Acid Mist 8-121
and NSPS Lead Controls, Existing Plants
8-62 Return on Investment Impact, Small Lead-Acid Battery 8-122
Plants Cost Pass Through
xvi i
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LIST OF TABLES (continued)
No. Page
8-63 Financial Capability Analysis of Small Lead-Acid 8-125
Battery Plants Assuming No Cost Pass-Through
8-64 Financial Capability Analysis of Small Lead-Acid 8-127
Battery Plants Assuming No Cost Pass-Through
8-65 Financial Capability Analysis of Small Lead-Acid 8-129
Battery Plants Assuming No Cost Pass-Through
8-66 Financial Capability Analysis of Small Lead-Acid 8-130
Battery Plants with Partial Cost Pass-Through
8-67 Financial Capability Analysis of Small Lead-Acid 8-131
Battery Plants with Partial Cost Pass-Through
8-68 Compliance Testing Annualized Costs, Small Plants 8-133
8-69 Return on Investment Impact, Small Lead-Acid Battery 8-134
Plants, Cost Pass-Through, Testing Cost Included
8-70 Return on Investment Impact, Small Lead-Acid Battery 8-135
Plants, Cost Pass-Through, Testing Cost Included
8-71 Return on Investment Impact, Small Lead-Acid Battery 8-136
Plants, Cost Pass-Through, Testing Cost Included
8-72 Financial Capability Analysis of Small Lead-Acid 8-137
Battery Plants, Worst Case Situation, Testing Cost
Included
8-73 Financial Capability Analysis of Small Lead-Acid 8-138
Battery Plants, Worst Case Situation, Testing Cost
Included
8-74 Financial Capability Analysis of Small Lead-Acid 8-139
Battery Plants, Worst Case Situation, Testing Cost
Included
8-75 Financial Capability Analysis of Small Lead-Acid 8-140
Battery Plants with Partial Cost Pass-Through,
Testing Cost Included
xviii
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LIST OF TABLES (continued)
No.
9-1 Selected Control Alternatives for the Lead-Acid Battery 9-7
Manufacturing Industry
9-2 Summary of Alternative Control Systems Costs and Control 9-8
Effectiveness for Lead-Acid Battery Plants (Metric Units)
9-2A Summary of Alternative Control Systems Costs and .Control 9-9
Effectiveness for Lead-Acid Battery Plants (English
Units)
9-3 Recommended Emission Limits for Lead-Acid Battery Plants 9-16
A-l Chronology of Events Leading to the Background Document A-2
for NSPS for Lead-Acid Battery Plants
A-2 Lead-Acid Battery Plants Selected for Investigation A-5
A-3 Processes, Test Locations, and Control Systems Recommended A-6
for Source Testing
C-l Test Results Summary for Plant B (Metric Units) C-6
C-1A Test Results Summary for Plant B (English Units) C-7
C-2 Test Results Summary for Plant D (Metric Units) C-l 2
C-2A Test Results Summary for Plant D (English Units) C-13
C-3 Test Results Summary for Plant G (Metric Units) C-17
C-3A Test Results Summary for Plant G (English Units) C-l 8
xix
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LIST OF TABLES (continued)
No, ' gage
C-4 Test Results Summary for Plant L (Metric Units) C-21
C-4A Test Results Summary for Plant L (English Units ) C-22
C-5 Test Results Summary for Plants B, J, and K (Metric
Units) C-23
C-5A Test Results Summary for Plants B, J, and K (English
Units) C-24
xx
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1.0 SUMMARY
1,1 PROPOSED STANDARDS
The proposed standards would limit atmospheric lead emissions from
new, modified, or reconstructed facilities at any lead-acid battery
manufacturing plant which has .a production capacity equal to or greater
than 500 batteries per day (bpd). The facilities which would be affected
by the standards, and the proposed emission limits for these facilities
are listed below:
Faci1ity Lead Emission Limit
Lead-oxide , .
production 5.0 mg/kg- (0.010 Ib/ton)
Grid casting 0.05 mg/nd (0.00002 gr/dscf
Paste mixing 1-00 mg/m* (0.00044 gr/dscf
Three-process 1.00 mg/n£ (0.00044 gr/dscf
Lead reclamation 2.00 mg/mj (0.00088 gr/dscf}
Other lead-emit- ->
ting operations 1.00 mg/mj (0.00044 gr/dscf)
The emission limit for lead-oxide manufacture is expressed in terms of
lead omissions per kilogram of lead processed, while those for other
facilities are expressed in terms of lead concentrations in exhaust air.
In addition, 0 percent opacity standard is proposed for emissions from
any of these affected facilities. The proposed standards would also require
continuous monitoring of the pressure drop across the control system, to help
insure proper operation of the system. Performance tests would be required to
determine compliance with the proposed standards. A new reference method, Method
1-1
-------
12, would be used to measure the amount of lead in exhaust gases, and Method
9 would be used to measure opacity. Process monitoring would be required
during all tests.
The Administrator considered setting standards of performance for the
lead-acid battery manufacturing industry which would limit sulfuric acid mist
emissions, as well as atmospheric lead emissions. Thus, the emission control
alternatives discussed in this Document include the use of mist eliminators
to control acid mist emissions from dry formation operations. Sulfuric acid
mist standards are not being proposed at this time, however.
1.2 SUMMARY OF ENVIRONMENTAL, ENERGY, AND ECONOMIC IMPACTS
New, modified and reconstructed facilities coming on-line over the next
five years will emit about 95 Mg (104 tons) of lead to the atmosphere in the
fifth year, if their emissions are controlled only to the extent required by
State particulate regulations. At some existing plants, emissions are controlled
to a greater extent than state particulate regulations require. This practice
might be continued at new plants in the absence of the proposed standards of
performance. The proposed standards would reduce potential lead emissions
from facilities coining on-line during the next five years to about 2,8 Mg
(3»1 tons) in the fifth year. This is approximately 97 percent lower than
the emission level which would be allowed under state particulate regulations.
The proposed standards would also result in decreased nonlead particulate
emissions from new plants, since equipment installed for the purpose of
controlling lead-bearing particulate emissions, would also control nonlead-
bearing particulate emissions.
The results of dispersion modeling calculations indicate that the
•j
ambient atmospheric lead standard of 1.5 ug/m (averaged over a calendar
1--2
-------
quarter) will be met at plants compl-ing with the proposed standards.
This is an important consideration, since most lead-acid battery plants
are located in urban areas. Results of EPA dispersion modeling calculations
indicate that the ambient lead standard will not be met in the neighborhoods
of plants controlling emissions only to the extent required by existing
state regulations.
The impact of the proposed standards on the wastewater and solid
waste emissions of a lead-acid battery plant would depend on the technique
used by that plant to comply with the proposed standards. The best
demonstrated system for reduction of lead emissions is the use of fabric
filters. High energy impingement scrubbers could also be used, but
would have higher energy requirements and operating costs than fabric filters,
At plants using impingement scrubbing to control emissions, lead-bearing
wastewater would be generated. This would be treated along with other
plant wastewater prior to being disposed from the plant. The fractional
increase in the lead content of wastewater discharged from a plant using
impingement scrubbing to control all atmospheric lead emissions except
those from the three-process and lead oxide production facilities would be
about 4.5 percent. At plants using fabric filtration to comply with the
proposed standards, the captured pollutant would be reclaimed, and there
would be no increase in wastewater or solid waste emissions due to the
proposed standards.
The energy needed to operate control equipment required to meet the
proposed standards at a new plant would be approximately 2 percent of the
total energy needed to run the plant. The incremental energy demand
resulting from the application of the proposed standards to the battery
1-3
-------
manufacturing facilities expected to come on-line over the next five years
would be about 2,8 Gigawatt hours of electricity in the fifth year. Approximately
4.8 thousand barrels of oil would be required to generate this electricity.
The capital cost of the installing emission control equipment necessary
to meet the proposed standards on all new facilities coming on-line nationwide
during the first five years of the standards would be approximately $8.6
million. The total annualized cost of operating this equipment in the fifth
year of the proposed standards would be about $4 million.
These costs and energy and environmental impacts are considered reasonable,
and are not expected to prevent or hinder expansion of the lead-acid battery
manufacturing industry. Economic analysis indicates that, for plants with
capacities larger than or equal to 500 bpd» the costs attributable to the
proposed standards could be passed on with little effect on sales. The
average incremental cost associated with the proposed standard would be about
30
-------
2. INTRODUCTION
Standards of Performance are proposed following a detailed investigation
of air pollution control methods available to the affected industry and the
impact of their costs on the industry. This document summarizes the
information obtained from such a study. It s purpose is to explain in
detail the background and basis of the proposed standards and to facilitate
analysis of the proposed standards by interested persons, including those
who may not be familiar with the many technical aspects of the industry.
To obtain additional copies of this document or the Federal Rejistej: notice
of orooosed standards, write to EPA Library (MD-35), Research Triangle Park,
North Carolina 27711. Soecify "Lead-Acid Battery Manufacturing, Background
Information: Proposed Standards," document number EPA 450/3-79-028a when
ordering.
2.1 AUTHORITY FOR THE STANDARDS
Standards of performance for new stationary sources are established
under section 111 of the Clean Air Act (42 U.S.C. 7411), as amended,
hereafter referred to as the Act. Section 111 directs the Administrator
to establish standards of performance for any category of new stationary
source of air pollution which ". . . causes or contributes significantly
to, air pollution which may reasonably be anticipated to endanger public
health or welfare."
2-1
-------
The Act requires that standards of performance for stationary
sources reflect, ". . . the degree of emission limitation achievable
through the application of the best technological system of continuous
emission reduction . . . the Administrator determines has been
adequately demonstrated," The Act also provides that the cost
of achieving the necessary emission reduction, the nonair quality health
and environmental impacts and the energy requirements all be taken into
account in establishing standards of performance. The standards apply
only to stationary sources, the construction or modification of which
commences after regulations are proposed by oublication in the Federal
Register.
The 1977 amendments to the Act altered or added numerous orovisions
which apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary
sources which have not already been listed and regulated under standards
of performance. Regulations must be promulgated for these new categories
on the following schedule:
25 percent of the listed categories by August 7, 1980
75 percent of the listed categories by August 7, 1981
100 percent of the listed categories by August 7, 1982
A governor of a State may aooly to the Administrator to add a category
which is not on the "list or may apply to the Administrator to have a
standard of performance revised.
2. EPA is required to review the standards of performance every
four years, and if appropriate, revise them.
2-2
-------
3. EPA Is authorized to oromulgate a design, equipment, work
practice, or operational standard when an emission standard is not
feasible.
4. The term "standards of performance" is redefined and a new term
"technological system of continuous emission reduction" is defined. The
new definitions clarify that the control system must be continuous'and
may include a low-polluting or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard
under section 111 of the Act may be extended to six months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction,
taking into consideration the cost of achieving such emission reduction,
any nonair quality health and environmental empact and energy requirements.
Congress had several reasons for including these requirements.
First, standards with a degree of uniformity are needed to avoid situations
where some States may attract industries by relaxing standards relative
to other States. Second, stringent standards enhance the potential for
long term growth. Third, stringent standards may help achieve long-term
cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future. Fourth, certain tyoes
of standards for coal burning sources can adversely affect the coal
market by driving up the price of low-sulfur coal or effectively
2-3
-------
excluding certain coals from the reserve base because their untreated
pollution potentials are high. Congress does not intend that new source
oerformance standards contribute to these problems. Fifth, the standard-
setting process should create incentives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under section 116 of the Act to establish
even more stringent emission limits than those established under section
111 or those necessary to attain or maintain the national ambient air
quality standards (NAAQS) under section 110. Thus, new sources may in
some cases be subject to limitations more stringent than standards of
performance under section 111, and orospective owners and operators of
new sources should be aware of this possibility in planning for such
facilities.
A similar situation may arise when a major emitting facility is to
be constructed in a geographic area which falls under the prevention of
significant deterioration of air quality orovisions of Part C of the
Act. These provisions require, among other things, that major emitting
facilities to be constructed in such areas are to be subject to best
available control technology. The term "best available control tech-
nology" (BACT), as defined in the Act, means ". . . an emission limitation
based on the maximum degree of reduction of each pollutant subject to
regulation under this Act emitted from or which results from any major
emitting facility, which the permitting authority, on a case-by-case
basis, taking into account energy, environmental, and economic impacts
and other costs, determines is achievable for such facility through
2-4
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application of production orocesses and available methods, systems, and
techniques, including fuel cleaning or treatment or innovative fuel
combustion techniques for control of each such pollutant. In no event
shall application of 'best available control technology1 result in
emissions of any pollutants which will exceed the emissions allowed by
any aoolicable standard established pursuant to section 111 or 112 of
this Act."
Although standards of performance are normally structured in terms
of numerical emission limits where feasible, alternative approaches are
sometimes necessary. In some cases physical measurement of emissions
from a new source may be impractical or exorbitantly expensive. Section
lll(h) provides that the Administrator my promulgate a design or
equipment standard in those cases where it is not feasible to prescribe
or enforce a standard of performance. For example, emissions of
hydrocarbons from storage vessels for petroleum liquids are greatest
during tank filling. The nature of the emissions, high concentrations
for short periods during filling, and low concentrations for longer
periods during storage, and the configuration of storage tanks make
direct emission measurement impractical. Therefore, a more practical
approach to standards of performance for storage vessels has been
equipment specification.
In addition, section lll(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Administrator
must find: (1) a substantial likelihood that the technology will oroduce
greater emission reductions than the standards require, or an equivalent
reduction at lower economic energy or environmental cost; (2) the proposed
2-5
-------
system has not been adequately demonstrated; (3) the technology will not
cause or contribute to an unreasonable risk to the public health,
welfare or safety; (4) the governor of the State where the source is
located consents; and that, (5) the waiver will not prevent the
atttainment or maintenance of any ambient standard. A waiver may have conditions
attached to assure the source will not prevent attainment of any NAAQS.
Any such condition will have the force of a performance standard.
Finally, waivers have definite end dates and may be terminated earlier
if the conditions are not met or if the system fails to oerform as
expected. In such a case, the source may be given up to three years to
meet the standards, with a mandatory progress schedule.
2.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories
of stationary sources which have not been listed before. The Adminstrator,
". . . shall include a category of sources in such list if in his judgement
it causes, or contributes significantly to, air pollution which may
reasonably be anticipated to endanger public health or welfare."
Proposal and promulgation of standards of performance are to follow
while adhering to the schedule referred to earlier.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories. The aporoaeh specifies areas
of interest by considering the broad strategy of the Agency for implementing
the Clean Air Act. Often, these "areas" are actually pollutants which
are emitted by stationary sources. Source categories which emit these
pollutants were then evaluated and ranked by a process involving such
2-6
-------
factors as (1) the level of emission control (if any) already required
by State regulations; (2) estimated levels of control that might be
required from standards of performance for the source category;
(3) projections of growth and replacement of existing facilities for the
source category; and (4) the estimated incremental amount of air pollution
that could be orevented, in a oreselected future year, by standards of
performance for the source category. Sources for which new source
performance standards were promulgated or are under development during
1977 or earlier, were selected on these criteria.
The Act amendments of August, 1977, establish specific criteria to
be used in determining priorties for all source categories not yet
listed by EPA. These are
1) the quantity of air pollutant emissions which each such category
will emit, or will be designed to emit;
2) the extent to which each such pollutant may reasonably be
anticipated to endanger public health or welfare; and
3} the mobility and competitive nature of each such category of
sources and the consequent need for nationally applicable new source
standards of performance.
In some cases, it may not be feasible to immediately develop a
standard for a source category with a high priority. This might happen
when a program of research is needed to develop control techniques or
because techniques for sampling and measuring emissions may require
refinement. In the developing of standards, differences in the time
required to complete the necessary investigation for different source
categories must also be considered. For example, substantially more
time may be necessary if numerous pollutants must be investigated from a
2-7
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single source category. Further, even late in the development process
the schedule for completion of a standard may change. For example,
inablility to obtain emission data from well-controlled sources in time
to pursue the development process in a systematic fashion may force a
change in scheduling. Nevertheless, oriority ranking is, and will
continue to be, used to establish the order in which projects are
initiated and resources assigned.
After the source category has been chosen, determining the types of
facilities within the source category to which the standard will apply
must be decided. A source category may have several facilities that
cause air pollution and emissions from some of these facilities may be
insignificant or very expensive to control. Economic studies of the
source category and of applicable control technology may show that air
oollution control is better served by applying standards to the more
severe pollution sources. For this reason, and because there be no
adequately demonstrated system for controlling emissions from certain
facilities, standards often do not apply to all facilities at a source.
For the same reasons, the standards may not apply to all air pollutants
emitted. Thus, although a source category may be selected to be covered
by a standard of performance, not all oollutants or facilities within
that source category may be covered by the standards.
2.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of oerformance must (1) realistically reflect best demon-
strated control oractice; (?.) adequately consider the cost, and the
nonair quality health and environmental impacts and energy requirements
of such control; (3) be applicable to existing sources that are
2-8
-------
modified or reconstructed as well as new installations; and (4) meet
these conditions for all variations of operating conditions being \
considered anywhere in the country.
The objective of a program for development of standards is to
identify the best technological system of continuous emission reduction
which has been adequately demonstrated. The legislative history of
section 111 and various court decisions make clear that the Administrator's
judgement of what is adequately demonstrated is. not limited to systems
that are in actual routine use. The search may include a technical
assessment of control systems which have been adequately demonstrated
but for which there is limited ooerational experience. In most cases,
determination of the "... degree of emission reduction achievable ..."
is based on results of tests of emissions from well controlled existing
sources. At times, this has required the investigation and measurement
of emissions from control systems found in other industrialized countries
that have developed more effective systems of control than those available
in the United States.
Since the best demonstrated systems of emission reduction may not
be widespread use, the data base upon which standards are developed may
be sonewhat limited. Test data on existing well-controlled sources are
obvious starting points in developing emission limits for new sources.
However, since the control of existing sources generally reoresent
retrofit technology or was originally designed to meet an existing State
or local regulation, new sources may be able to meet more stringent
emission standards. Accordingly, other information must be considered
before a judgement can be made as to the level at which the emission
standard should be set.
2-9
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A process for the development of a standard has evolved which takes
into account the following considerations.
1. Emissions from existing we11-controlled sources as measured.
2. Data on emissions from such sources are assessed with considera-
tion of such factors as: (a) how representative the tested source is in
regard to feedstock, operation, size, age, etc.; (b) aqe and maintenance
of control equipment tested; (c) design uncertainties of control
equipment being considered; and (d) the degree of uncertainty that new
sources will be able to achieve similar levels of control.
3. Information from pilot and orototype installations, guarantees
by vendors of control equipment, unconstructed but contracted orojects,
foreign technology, and published literature are also considered during
the standard development process. This is especially important for
sources where "emerging" technology appears to be a significant alternative.
4. Where possible, standards are developed which oermit the use of
more than one control technique or licensed process.
5. Where possible, standards are developed to encourage or permit
the use of process modifications or new processes as a method of control
rather than "add-on" systems of air pollution control.
6. In aporopriate cases, standards are developed to permit the use
of systems capable of controlling more than one oollutant. As an example,
a scrubber can remove both gaseous and oarticulate emissions, but an
electrostatic precipitator is specific to particulate matter.
7. Where appropriate, standards for visible emissions are developed
in conjunction with concentration/mass emission standards. The opacity
standard is established at a level that will require orooer operation
and maintenance of the emission control system installed to meet the
2-10
-------
concentration/mass standard on a day-to-day basis. In some cases,
however, it is not possible to develop concentration/mass standards,
such as with fugitive sources of emissions. In these cases, only
opacity standards may be developed to limit emissions.
2.4 CONSIDERATION OF COSTS
Section 317 of the Act requires, among other things, an economic
impact assessment with respect to any standard of oerformance established
under section 111 of the Act. The assessment is required to contain an
analysis of:
(1) the costs of compliance with the regulation and standard
including the extent to which the cost of comoliance varies depending on
the effective date of the standard or regulation and the develooment of
less expensive or more efficient methods of compliance;
(2) the potential inflationary recessionary effects of the standard
or regulation1,
(3) the effects on competition of the standard or regulation with
respect to small business;
(4) the effects of the standard or regulation on consumer cost;
and,
(5) the effects of the standard or regulation on energy use.
Section 317 requires that the economic impact assessment be as
extensive as practible, taking into account the time and resources
available to EPA.
The economic impact of a oroposed standard uoon an industry is
usually addressed both in absolute terms and by comparison with the
control costs that would be incurred as a result of compliance with
tyoical existing State control regulations. An incremental approach is
taken since both new and existing plants would be required to comply with
2-11
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State regulations in the absence of a Federal standard of performance.
This approach requires a detailed analysis of the impact upon the
industry resulting from the cost differential that exists between a
standard of performance and the typical State standard.
The costs for control of air pollutants are not the only costs
considered. Total environmental costs for control of water pollutants
as well as air pollutants are analyzed wherever possible.
A thorough study of the profitability and price-setting mechanisms
of the industry is essential to the analysis so that an accurate estimate
of potential adverse economic imoacts can be made. It is also essential
to know the caoital requirements placed on plants in the absense of
Federal standards of performance so that the additional capital requirements
necessitated by these standards can be placed in the proper oersoective.
Finally, it is necessary to recognize any constraints on capital availability
within an industry, as this factor also influences the ability of new
plants to generate the capital required for installation of additional
control equipment needed to meet the standards of performance.
2.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102{2)(C) of the National Environmental Policy Act (NEPA)
of 1969 requires Federal agencies to preoare detailed environmental
impact statements on proposals for legislation and other major Federal
actions significantly affecting the quality of the human environment.
The objective of NEPA is to build into the decision-making orocess of
Federal agencies a careful consideration of all environmental asoeets of
proposed actions.
2-12
-------
In a number of legal challenges to standards of performances for
various industries, the Federal Courts of Aopeals have held that \
environmental impact statements need not be orepared by the Agency for
proposed actions under section 111 of the Clean Air Act, Essentially,
the Federal Courts of Appeals have determined that "... the best
system of emission reduction, . . - require(s) the Administrator to take
into account counter-productive environmental effects of a proposed
standard, as well as economic costs to the industry. . ." On this
basis, therefore, the Courts ". . . established a narrow exemption from
NEPA for EPA determination under section 111."
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to section 7{c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the
quality of the human environment within the meaning of the National
Environmental Policy Act of 1969."
The Agency has concluded, however, that the preparation of environmental
imoact statements could have beneficial effects on certain regulatory
actions. Consequently, while not legally required to do so by section
102(2)(C) of NEPA, environmental impact statements are orepared for
various regulatory actions, inlcuding standards of performance developed
under section 111 of the Act. This voluntary preparation of environmental
imoact statements, however, in no way legally subjects the Agency to
NEPA requirements.
To implement this policy, a separate section is included in this
document which is devoted solely to an analysis of the potential environmental
2-13
-------
impacts associated with the proposed standards. Both adverse and bene-
ficial impacts in such areas as air and water pollution, increased solid
waste disposal, and increased energy consumption are identified and
discussed.
2.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new sources as ". . . any stationary
source, the construction or modification of which is commenced ..."
after the proposed standards are published. An existing source becomes
a new source if the source is modified or is reconstructed. Both modification
and reconstruction are defined in amendments to the general provisions
of Subpart A of 40 CRF Part 60 which were promulgated in the Federal
Register on December 16, 1975 (40 FR 58416). Any physical or operational
change to an existing facility which results in an increase in the
emission rate of any pollutant for which a standard applies is considered
a modification. Reconstruction, on the other hand, means the replacement
of comoonents of an existing facility to the extent that the fixed
capital cost exceeds 50 percent of the cost of constructing a comparable
entirely new source and that it be technically and economically feasible
to meet the applicable standards. In such cases, reconstruction is
equivalent to a new construction.
Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality
criteria have not been issued under section 108 or which has not been
listed asa hazardous pollutant under section 112). If a State does not
-------
act, EPA must establish such standards. General provisions outlining
procedures for control of existing sources under section lll(d) were
promulgated on November 17, 1975, as Suboart 8 of 40 CFR Part 60 (40 FR
53340).
2.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
section 111 of the Act provides that the Administrator "... shall, at
least every four years, review and, if appropriate, revise ..." the
standards. Revisions are made to assure that the standards continue to
reflect the best systems that become available in the future. Such
revisions will not be retroactive but will apply to stationary sources
constructed or modified after the proposal of the revised standards.
2-15
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3.0 THE LEAD-ACID BATTERY INDUSTRY
3.1 GENERAL
The largest single use of lead in the United States is in the
manufacture of lead-acid, or secondary, storage batteries. There are
approximately 190 lead-acid battery plants in the United States, of which
91 have been estimated to be small plants. The six largest companies,
with branch plants distributed across the country, account for over 70
percent of the lead-acid battery market.
Lead-acid battery plants are scattered throughout the country, and
are generally located in highly urbanized areas near markets for their
batteries. Some of the larger plants have secondary smelting facilities,
or lead oxide production facilities, or both; smaller firms tend to
purchase the lead constituents from outside vendors,
3.1.1 Industry Profile.
Two major types of lead-acid storage batteries are manufactured in
the United States: 1) Starting-lighting-ignition (SL!) batteries, used
in automobiles, golf carts, and aircraft, SIC (Standard Industrial
Classification) 36911, and 2) industrial storage batteries for low-
voltage power systems, industrial fork-lift trucks, and the like, SIC
2
36912. SLI units account for more than 80 percent of the market.
3.1,1.1 Relationship of Battery Industry to Overall Economy—
o
Lead-acid battery shipments in 1974 were valued at $1.15 billion,
accounting for 0.08 percent of the 1974 gross national product (GNP) of
3-1
-------
$1397 billion. Annual battery values and the GNP for the period 1960
to 1974 are presented in Figure 3-1, which also depicts the added value
(shipment value minus raw material value).
The gross national product and lead-acid battery values have shown
similar trends since I960, both increasing approximately 280 percent.
Total use of lead by battery manufacturers increased 235 percent during
c
the 14-year period beginning in 1960, The lead-acid battery industry
employed 22,100 workers in 1972. New battery plant and equipment
expenditures for 1972 amounted to $30.8 million. Of this amount* new
Q
machinery and equipment accounted for $21.1 million.
3.1.1.2 Relationship of Battery Industry to Lead Industry--
The battery industry receives lead from two sources: mines and
secondary lead smelters. The storage battery industry consumed 0.77 Tg
q
(850,000 tons) of lead in 1974. United States mine production of
recoverable lead in 1975 was 0.56 Tg (620,000 tons).10 Estimated secondary
lead recovery in 1975 was 0.55 Tg (610,000 tons).11 Scrapped lead-acid
batteries account for the major portion of recovered lead, along with
drosses and residues (lead-containing wastes and impurities that are
processed to recover lead). Approximately 0.17 Tg (190,000 tons) of
imported lead constitute the remainder of lead supplied to the industry
in 1975.12
Lead consumption by individual products in the years 1971 through
1975 is summarized in Tables 3-1 and 3-1A. Lead storage batteries
accounted for almost 0.64 Tg (700,000 tons), or more than half of the
13
total lead consumed in 1975. Metal grids and posts required 0.30 Tg
(327,000 tons), while 0.34 Tg (373,000 tons) of lead was used in lead
oxide for grid pasting.
3-2
-------
1200
vs
o
o
o e*:
«sC
CQ
a: a.
UJ 2E
(— C£3
VALUE OF SHIPMENTS = COST OF MATERIALS +• VALUE ADDED 3Y MANUFACTURER
GKP (CONSTANT DOLLARS)
VALUE OF SHIPMENTS
Figure 3-1. Trends in lead-acid battery shipments and
in gross national product.
-------
t»J
1
Table 3-1. UNITED STATES CONSUMPTION OF LEAD
(in Gigagrams)
18,19
Ammunition
Bearing metals
Brass and bronze
Cable covering
Calking lead
Casting metals
Collapsible tubes
Foil
Pipe, traps and bends
Sheet lead
Solder
Storage batteries
Terne metal
Type metal
White lead
Red lead and litharge
Pigment colors
Other
Gasoline antiknock additives
Miscellaneous chemicals
Annealing
Galvanizing
Lead plating
Weights and ballast
Other uses unclassified
TOTAL
1971
79,4
14.8
18.2
48.0
27.2
6.6
9. 1
4.0
16.5
25,0
63.5
616.7
1.3
18.9
4.3
56.1
12,6
0.7
239,7
0.4
3.7
1.3
0.5
15.8
14.3
1, 298. 6
1972
76.8
14.4
18.0
41.7
20.4
8.5
3.6
4.2
16.1
21.5
64.7
659.2
0.5
18.1
2.6
63.3
14.8
0.3
252.5
0.8
3.9
1,3
O.G
J9.3
22.5
1, 349.6
1973
73.9
14.2
20.6
39.0
18.2
6.5
2.6
4.5
19.3
21.2
65.1
698.0
2.4
19.9
1.3
81.2
15.4
0.4
248,9
0.9
3.C
J .2
0.7
18.9
19.7
1,397.6
1974
79.0
13.3
20.1
39.4
17.9
6.8
2.3
4 .0
14.9
19.3
60.1
772.8
2.1
IB. 6
1.8
87,2
15.7
0.7
227.3
0.6
3.7
1.5
0.5
19.4
21.9
1,450.9
1975
68,1
11.1
12.2
20.0
13.0
7.0
2.0
2.9
12.9
22.6
62.0
634.5
1.4
14.7
2.3
59.3
9.6
0.2
189.2
0.2
2.4
1.]
0.3
18.2
19.3
1,186.8
-------
Table 3-1A,
OJ
I
01
UNITED STATES CONSUMPTION OF LEAD
(in short tons)
18,19
Ammunition
Bearing metals
Brass and bronze
Cable covering
Calking lead
Casting metals
Collapsible tubes
Foil
Pipe, traps and bends
Sheet lead
Solder
Storage batteries
Tecne metal
Type metal
White lead
Red lead and litharge
Pigment colors
Other
Gasoline antiknock additives
Miscellaneous chemicals
Annealing
Galvanizing
Lead plating
Weights and ballast
Other uses unclassified
TOTAL
1971
87,567
16, 285
20,044
52,920
29,993
7, 281
10,041
4, 417
18,174
27,607
70,013
679, 803
1,409
20, 812
4,731
61,838
13,916
773
264, 240
401
4,068
1, 395
582
17,453
15,751
1, 431, 514
1972
84, 699
15,915
19,805
45,930
22,483
7,139
4,020
4,592
17,780
23,667
71,289
726,592
504
19,944
2,814
69,799
16,264
377
278, 340
849
4,329
I, 397
638
21,302
24, 826
1,485, 254
1973
81,479
15,657
22,735
43,005
20,057
7 , 220
2,8GO
4,985
21,291
23,394
71,770
769,447
2,658
21,922
1,479
89,577
16,963
477
274,410
944
3,974
1,294
744
20,848
21,749
1,541,209
1974
87,090
14,609
22,240
43,426
19,739
7,507
2,488
4,404
16,455
21,294
66,280
851,881
2,300
20,516
1,996
96,163
17,336
718
250,502
708
4,097
1 ,664
498
21 ,418
24,098
1,599,427
1975
75,081
12 , 184
13,404
22 ,099
14,296
7,711
2,216
3,205
14,233
24 ,859
57,344
699,414
1,511
16,211
2,498
65,457
10,618
499
208,605
181
2,629
1,228
376
20,018
21,221
1,297,098
-------
3.1.1.3 Battery Usage and Sales Forecast-
Total battery shipments of 54.5 million SLI units in 1974 represented
the first annual decline since 1967. » Figure 3-2 shows the shipments
of SLI units (replacement, original equipment, and imported batteries)
since 1947. Shipments of replacement units remained relatively constant.
The decline in new car sales accounted for the total decrease.
Table 3-2 summarizes SLI battery use. SLI units account for 80
percent of the total lead-acid battery market in 1974.17 Industrial
batteries account for the remaining 20 percent. Approximately 80 percent
22
of the SLI units argjjsed in.automobi1 es.
TABLE 3-2. SUMMARY OF SLI BATTERY USE: 197423
Portion of SLI
Classification market, %
Automobile 80
Heavy duty/commercial . 14
Golf carts 2
Light utility 2
Marine 1
Miscellaneous 1
Several sources provide forecasts for the lead-acid battery
industry. One of the trade organizations for this industry, the Battery
Council International (BCI), predicts an annual growth rate of approximately
24
3 percent through 1979. Another source estimates an average employment
increase of 2.4 percent per year in the storage battery industry through
1985.25
3-6
-------
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70
60
50
30
20
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74S 49 ~0 5! 52 53 54 55 5G 57 SH 59 BO 61 G2 63 64 65 Go 67 68 59 70 71 72 73 74 75 7B 77 78 73 20 8 32 J3 S-
YEAR
Figure 3-2. United States shipments of SLI
lead-acid batteries from 1947 to 1974. " '''
------- An error occurred while trying to OCR this image.
-------
or 6 cells (6 or 12 volts). Lead add storage batteries range in size
and weight. It is estimated that an average battery weighs 18.1 kg (40
Ib), of which 11.8 kg (26 1b) is lead. The electrodes are made of lead,
and the electrolyte consists of a solution of sulfuric acid and water.
The cathode consists of lead peroxide and the anode consists of porous
or spongy lead. Both the anode and the cathode are converted to lead
sulfate when the battery is discharging. Many complicated chemical
reactions take place inside a lead-oxide battery during discharge,
resulting in neutralization of the two plates and weakening of the
electrolytic solution by formation of water. Figure 3-3 shows the
components of a battery.
The electrodes, or plates, consist of two parts: (1) an inactive
lead grid, which provides mechanical support for the active portion (the
plate) and a conductive path for the electric current, and (2) a lead
oxide sulfate paste, which is applied and bonded to the grids. Other
materials in the lead-acid battery include plastic, wood, or rubber
separators and the outer case materials, which are usually vulcanized
rubber, polypropylene, nylon, or acrylics. Figure 3-4 shows the arrange-
ment of battery components in an element.
Consumer attention has recently been directed toward the waterless
or "maintenance free" batteries. These batteries are typically supplied
without vent plugs or provisions for adding water. Though they appear
to be totally sealed, they are always vented in some way, usually by
small holes in the top of the battery case. These batteries are practically
identical to the conventional battery except in appearance; they all use
lead-lead peroxide plates in a sulfuric acid electro!ite. There are
3-9
-------
VENT PLUG
GASKET
VISUAL LEVEL FILL
PLATE STRAP
PLATE
BRIDGE
CELL COVER
.TERMINAL POST
PROTECTED CELL
CONNECTOR
HARD RUBBER CASE
SEDIMENT CHAMBER
Figure 3-3. A lead-acid storage battery,
3-10
-------
NEGATIVE PLATE GROUP-,
SEPARATORS
POSITIVE PLATE GROUP
\
POSITIVE PLATE' '
-•CELL TERMINAL
/PLATE STRAP
NEGATIVE PLATE
Figure 3-4. Components of a battery element
(shown pulled apart).
3-11
-------
subtle differences in the lead alloy used in some of the plates (usually
a substitution of calcium for some of the antimony) and generally they
do consume so little water during normal operation that water addition
is usually unnecessary during the life of the battery. However, manufacturing
processes for these batteries, and the attendant emissions, are for all
practical purposes identical to those for the conventional battery.
Therefore, this document makes no distinction between this style of
battery and conventional batteries.
Lead oxide (gray or black lead) is used in preparing the active
materials. Many battery plants prepare the oxide in-house, and several
processes are used.
A process flow diagram for the manufacture of lead-acid storage
batteries is shown in Figure 3-5, with emission factors for uncontrolled
process operations. As the figure indicates, this study encompasses
only the battery manufacturing process and production of lead oxide
(PbO); it does not include lead smelting operations.
Battery manufacturing begins with grid casting and paste mixing.
The grids are generally cast in doublets (two grids per casting) from
molten lead, to which 6 to 12 percent antimony has been added to provide
hardness. These grids are coated with either positive or negative paste
formed (a process discussed later), cut into two separate grids (a
process called slitting) and then sent to be assembled into dry- or wet-
type batteries.
Lead emission factors are shown in Figure 3-5, and estimated
nationwide emissions are presented in Table 3-3. The lead emission
factors for grid casting, paste mixing, and battery assembly are derived
3-12
-------
CO
I
(O.OZ)
PM PTOBBOJQK
raoouct mcanst
(10,0)
t 6.W1
It* WA\ \
wit 8
0.4." ^J^f
{O.M) [0]
i
r— ^— -t
i J >
LtAB ( ' J
IKSOIS CSID G.,n (Rifl HMf IHflUI lltrwril
— . CASIInk — CASTING ~~" fWISXfi "" iUCll.lS WliHIKC Aiil.-WK
— PROCESS
— IWWIST smwt
DRY BATTERY LINE
4 Grams (pounds) of lead emissions per kilogram (ton) of lead charged.
b Kilograms (pounds) of lead emissions per 1000 batteries. i«wio
WET BATTERY LINE
Figure 3-5. Process flow diagram showing uncontrolled
lead emission factors for lead-acid battery manufacture.
-------
Table 3-3. NATIONWIDE EMISSIONS OF LEAD FROM THE MANUFACTURE
OF LEAD-ACID STORAGE BATTERIES (1975)
to
i
Process
Lead oxide
production
Grid casting
Lead reclamation
Paste mixing
Three-process
operation
Throughput, a
Gg (ton} Pb
338 (373,000)
397 (327,000)
6.2 (6,800)e
338 (373,000)
635 (700,000)
Estimated
average control
efficiency, b
%
c
50
80
90
90
Uncontrolled
emission factor,
g/kg (Ib/ton)
of lead throughput
0.01 (0.02!
0.07 (0.139)d
2.97 (5.9)
0.86 (1.72)d
0.56 (1.13)d
Total emissions for 1975
Estimated
actual emissions ,
Mg
3.4
10.3
3.6
29.0
35.9
81,5
(ton)
(3.7)
(11.4)
14.0)
(32.0)
(39.6)
{90.0}
a Based on 1975 data.29
Based on information obtained £rom battery manufacturers and control agencies throughout the
study.
C
Emission factor is based on controlled emissions; fabric filters are a part of the process.
Based on test data in units of pounds of lead emissions per 1000 batteries and assumption of an
average of 11.8 kg (26 Ib) of lead per battery. Half is assumed to be in the castings and half
in the paste.
e
Estimated at 1 percent of total lead throughput.
-------
from data obtained in tests performed as part of this study. Measurements
of controlled and uncontrolled lead emissions were performed at selected
plants manufacturing lead-acid batteries. (Reference to the individual
plants in this report is by alphabetical code). Quantitative data on
emissions of sulfuric acid mist from the formation process are not
available.
Except for the lead oxide manufacturing facility, the participate
pollutant catch from the control systems, whether wet or dry, is reclaimed
by a lead smelter. The particulate captured from the lead oxide manufacturing
operation is used in the paste mixer.
3.2 GRID CASTING
Techniques for casting of grids vary with the alloy used, the type
of molds, and mold preparation before casting. Molten lead alloy.ingots
are melted in a gas-fired lead pot at approximately 370°C (700°F). The
furnace is often equipped with a hood to vent the fumes to a control
device or to the atmosphere.
In some grid casting operations, melting pots are attached directly
to the casting machines. The molten lead flows from the pots directly
into the molds, where the grids are formed and then are ejected, trimmed,
and stacked. Some facilities feed the molding machines from a central
pot furnace, from which the molten lead is either pumped or fed by
gravity. Pumping may cause air to be entrained in the molten lead,
resulting in problems at the molding machines. Entrained air is not a
problem with grid casting machines that are fed by gravity flow.
Emissions from the grid casting operations are generally low; even
uncontrolled facilities can meet the most stringent state particulate
3-15
-------
regulations. Some manufacturers control emissions from this operation
and others do not. Exhausts from the grid casting furnace are usually
vented to the atmosphere to protect workers from the lead emissions.
The areas around the casting machines are generally unvented.
Testing of the grid casting facility at Plant D (see Chapter 4,
Section 4.1) indicated uncontrolled lead concentrations ranging from 0.9
to 5.9 mg/m3 (0.00039 gr/dscf to 0.0026 gr/dscf, 0.049 to 0.34 Ib/hr).
At Plant D, the grid casting facility is operated for 24 hours each day
and the production capacity is 4000 bpd. The measured lead emissions
are equivalent to 408 g (0.9 Ib) per 1000 batteries, or approximately
51.1 g/hr (0.113 Ib/hr) for a typical 2000 bpd plant.
3.3 PASTE MIXING
The paste mixing operation, a batch-type process, is done with a
muller, Day, or dough-type mixer. From 272 to 1361 kg (600 to 3000 Ib)
of lead oxide is added to the mixer; water and sulfuric acid are then
added, and the mixture 1s blended to form a stiff paste. Because reactions
of the process are exothermic, mixers are usually water-jacketed and
air-cooled to prevent excessive temperature buildup which causes the
paste to become stiff and difficult to apply to the grids. Approximately
1 weight percent of expander (generally a mixture of barium sulfate,
carbon black, and organics) is added to batches of paste for negative
plates. Carbon black also provides color identification for the
negative paste. A duct system vents the moisture-laden exhaust gases
from the mixer. The duration of the mixing cycle depends on the type of
mixer, ranging from 15 minutes to an hour. Typical formulas for positive
and negative pastes are shown in Table 3-4.
3-16
-------
TABLE 3-4. TYPICAL FORMULAS FOR POSITIVE AND
NEGATIVE BATTERY PASTES^1
Ingredient Positiye Negative
Lead oxide, kg (Ib)272 (600)272 (600)
Dyne! fiber, kg (Ib) 0,068 (0.15) 0.068 (0.15)
Expander, kg (Ib) None 1.90 (4.2)
Water, liter (quart) 23 (25) 26 (28)
H2S04 (1.375-1.400 s.g.)» 25 (26) 21 (22)
liter (quart)
The major emissions from paste mixing occur during charging of the
dry ingredients to the mixer. The high-emissions phase is about the
first 10 minutes of a 60-minute mixing cycle. The emissions are in the
form of lead oxide, with small amounts of other paste constituents such
as Dynel, organics, and carbon black.
Source tests were performed at Plant D where the mixer was vented
to a baghouse during materials charging and to a Roto-Clone during
mixing. The baghouse also controlled the plate slitting operation, and
the Roto-Clone also controlled the grid casting operation. Two tests
run at the baghouse inlet during charging showed uncontrolled lead
emissions of 115 and 34 mg/m3 (0.050 and 0.015 gr/dscf, 10.4 Ib Pb/hr
and 2.99 Ib Pb/hr). A single test to determine emissions from the
slitting process indicated lead emissions of 43 mg/m (3.88 Ib/hr,
0.0188 gr/dscf). On the basis of these data, an emission factor for the
total mixing operation (both charging and mixing) is estimated to be
approximately 5.1 kg (11.2 Ib) of lead per 1000 batteries, or 0.636
kg/hr (1.40 Ib/hr) for a typical 2000 bpd plant.
3-17
-------
3.4 THREE-PROCESS OPERATION - STACKING/BURNING/ASSEMBLY
(After the plates are cured, they are normally sent to the three-
process operation, which includes plate stacking, burning, and assembly
of elements into the battery case.|\Some plants are equipped with an
associated plate slitter, which cuts the double plates apart. At most
plants the plates are parted by hand, after which they are stacked in an
alternating positive and negative block formation with separators sandwiched
between .each plate to insulate the oppositely charged plates while
permitting free ionic flow. These separators are made from materials
such as wood, treated paper, plastic, or rubber. Although machines have
been designed to stack the plates and separators automatically, hand
stacking is common. /
/
, Leads (pronounced leeds) are welded to the tabs of each positive
plate and each negative plate, fastening the assembly (element) together.
This is the burning operation. An alternative to the welding or burning
process is the cast-on-strap process, in which molten lead is poured
around and between the plate tabs to form the connection! Then a positive
f ]
and a negative terminal are welded to the elements The completed elements
are then assembled into battery cases either before formation (wet
batteries) or after formation (dry batteries). The difference between
wet and dry batteries is explained in Section 3.5. I
Most lead emissions are generated during plate stacking and burning
or casting operations. Handling of plates between process steps also
generates considerable lead emissions. Typically, operators straighten
stacks by striking them against a grated surface. Upon impact, particles
of paste become airbopne. Work areas are generally vented to collect
these particles and to protect the health of the workers.
3-18
-------
Source tests at Plants B and D, with capacities of 4500 and 4000
bpd respectively, indicate that uncontrolled lead emissions from the
o
three-process operation range from 20 to 54 mg/m (0.0087 to 0.023 '
gr/dscf, 1.37 to 6,31 Ib/hr) during full operation.* These tests indicate
total three-process emissions, since testing of each process step in the
facility is not feasible. On the basis of these data (presented completely
in Chapter 4), an estimated emission factor for the three-process operation
is 6.67 kg (14.7 Ib) of lead per day for each 1000 bpd capacity, or
0.835 kg/hr {1.84 Ib/hr) for a typical 2000 bpd plant.
3.5 FORMATION
( During formation the inactive lead oxide-sulfate paste is chemically
converted into an active electrode. Formation is essentially an oxidation-
reduction reaction, in which the lead oxide in the positive plates is
oxidized to lead peroxide and in the negative plates are reduced to
metallic lead. This is accomplished by placing the unformed plates in a
dilute (10-25 percent)32 sulfuric acid solution and connecting__the
positive plates to the positive pole of a direct current JjcJ_sour-ce-afld
the negative plates to the negative pole of the dc source/)
During the formation process, hydrogen is released in the form of
small bubbles, which carry sulfuric acid with them as they break through
the surface of the solution and enter the atmosphere above the container.
The process, therefore, is a source of sulfuric acid mist emissions.
*Emissions data for the plate slitting operation at Plant D are included
in the mixer emissions data since they are also vented to the baghouse
that controls mixer exhaust.
3-19
-------
Charging rate and temperature affecn the emissions of sulfuric acid
mist, which generally increase with increasing temperature and rate of
charge. Also, as the process nears the end of the formation cycle, the
release of hydrogen bubbles increases. Emissions therefore increase
with time.
3.5.1 Wet Formation Process
(in manufacture of wet lead-acid batteries, the elements are assembled
into the case before forming. It is common practice to place the cells
in the battery case,Jplace the lid on the battery, and add sulfuric
acid. The plates are then formed within the battery casev After formation,
the spent acid is dumped from the battery and new acid is added. With
addition of a boost charge the unit is ready for use, requiring only
decoration and manufacturer's markings A
Wet formation generally takes 1 to 4 days. Most plants use a 36-
to 48-hour forming cycle. The charging rate is high during the first 24
to 36 hours and lower during the remaining 12 hours. The ampere rates
depend on the battery size.
Emissions from wet formation processes are usually not controlled
or ducted to a stack. Therefore, no data are available on quantitative
emissions from the wet formation process. However, because of the slow
charging rate, the fact that there is a lid or cap on the battery during
formation, and the absence of a strong acid odor at wet formation processes,
emissions from the process are believed to be small.
3.5.2 Dry Formation Process
\ The plates used in dry batteries are formed in several ways. Some
plates are individually formed in tanks of sulfuric acid and then assembled.
3-20
-------
Most, however, are assembled into elements before formation.] \The completed
\elements are then formed by placing the elements in large tanks of \
sulfuric acid and by then making an electrical connection to form the
elements'^ Some manufacturers place the assembled elements directly in
the battery case for formation. /Thereafter, they remove the formed
elements, dump the acid, rinse ana dry the cases and elements, reassemble
them, and ship the batteries dry.) Dry formation typically last 16
hours, with the plates or elements loaded into tanks during the day
shift, and formed during the evening and night shifts.
When forming batteries by the dry formation process, the acid mist
can be controlled by the use of mist eliminators or scrubbers, but is
commonly controlled by application of some sort of cover over the acid
bath or receptable. The cover is usually of a surface foaming agent
such as Alkonol or Dupanol.
Two dry formation processes have been sampled by EPA. The first
test did not yield any valid results because the process was not operating
properly (one of the three formation circuits was inoperative). Also,
emissions from the control device were not detectable when EPA Reference
Method 8 was used to collect emissions over a two hour sampling period.
The second EPA test (Plant L) showed uncontrolled emissions toward the
end of the cycle to average 66 mg/m3 (0.029 gr/dscf, 0.70 Ib/hr). This
formation room formed 20,000 battery plates over a 16 hour period.
3.6 LEAD OXIDE PRODUCTION
The lead monoxide used in battery paste production is called lead
oxide, black oxide, or battery oxide. The typical lead oxide contains
approximately 70 percent PbO. The balance is free metallic lead. Lead
3-21
-------
oxide is produced either by the ball mill process or Barton process.
Each of the lead oxide manufacturing processes incorporates a
baghouse for product recovery, since the value of the product is relatively
high. Air-to-cloth ratios of these fabric filters generally are about
3/1, whether the filters are designed for product recovery or for emissions
control. As a result, emissions from the lead oxide production facility
are low.
3.6.1 Ball Mill Process
In the ball mill process oxidation is initiated by heat generated
by tumbling pure lead pigs (ingots) in a mill. During the tumbling
action the lead oxide that forms on the surface of the lead pigs and
fine particles of unoxidized lead is broken off, forming a fine dust
that is removed from the mill by a circulating air stream. The larger
fraction is ground further in a hammermill. Air flow through the mill,
the temperature of the charge, and the weight of the charge are controlled
to product a specified ratio of lead oxide to finely divided metallic
lead. The product is conveyed by totally enclosed screw conveyors to
storage bins. Enough product is entrained in the mill exhaust gases to
justify gas cleaning for product recovery. Fabric filtration is always
a part of the process.
Tests performed at Plant B (shown in Appendix C) yielded average
lead emissions of 0.475 g/kg (0.0095 Ib/ton) of lead input. This plant
operates two ball mill production lines equipped with fabric filters,
one with an air-to-cloth ratio of 2/1 and the other with a ratio of 4/1.
The filters are vented to a common stack.
3-22
-------
3.6.2 Barton Process
In the Barton process, molten lead is fed to a circular pot and
stirred rapidly. A series of baffles within the pot atomize the lead
into extremely small droplets, which are then oxidized by an air stream
directed over the surface of the molten lead. The resulting lead oxide
is conveyed by the air stream to a fabric filter where the product is
removed. The particle-size distribution, apparent density, and reactivity
of the oxide are controlled by the temperature maintained in the pot and
by the volume and speed of the air stream that carries away the reacted
products. The larger particles are captured in a cyclone prior to the
fabric filter and pulverized in a hammermill. They are then conveyed
and collected by another fabric filter.
3,7 LEAD RECLAMATION
Lead reclamation is the process whereby relatively clean lead scrap
is remelted and cast into pigs for use in the process. The melting is
/>
generally done in a pot-type furnace. /Scrap, in the form of small parts
or defective grids and plates, is charged to the furnace,. This is often
done sporadically, only when enough material is available for charging.
Emissions from pot-type furnaces tend to be minimal. The lead is melted
at relatively low temperatures and emissions usually are visible only
when oily scrap or floor sweepings are charged. Source tests on Plant
G's lead recovery process show uncontrolled lead emissions averaging 298
g/kg (5.9 Ib/ton) of scrap input.
Many of the smaller plants have no lead reclamation facilities and
send out the scrap for reclamation. No figures exist which indicate the
amount of scrap which is reclaimed at battery plants nationwide. However,
3-23
-------
based on observations made during plant visits under this study, it
would appear that approximately 5 percent of the lead that enters the
industry's process stream winds up as scrap and that one-fifth of the
battery manufacturing capacity, nationwide, recycles its lead in nonsmelting
processes, i.e., a pot-type furnace. The net result is an estimated
nonsmelting recycle rate of 1 percent of all lead charged to the battery
manufacturing processes nationwide.
3-24
-------
REFERENCES FOR SECTION 3
1. Data developed under EPA contract No. 68-02-2804 in Support of Lead
Ambient Air Standard.
2 Burkard R.A. A Report by the BCI Statistical Committee. Replacement
Battery; Industry Forecast 1975-1979. Globe-Union, Inc. Milwaukee,
Wisconsin, p. 1.
3, Share of Market for Storage Batteries, 1975. Economic Information
Systems, Inc. New York City. p. 5.
4 U.S. Office of Business Economics. Survey of Current Business.
u!s. Government Printing Office. Washington, D.C. May 1975. p.
5.
5. The Storage Battery Manufacturing Industry, 1973-1974 Yearbook.
Battery Council International. Burlingame, California. 1974. p.
83.
6. U.S. Bureau of the Census. 1972 Census of Manufacturers. U.S.
Government Printing Office. Washington, D.C. 1974. p. 18.
7. Ibid. p. 19.
8. Ibid.
9. Annual Review 1975, U.S. Lead Industry. Lead Industries Association,
Inc. New York City. April 1976. p. 6.
10. Ibid. p. 5.
11. Ibid.
12. Ibid.
13. Lead Industry Monthly Mineral Industry Surveys. Bureau of Mines.
May 1976. p. 7.
14. Ibid.
15. Op. cit. Ref. 5. p. 82.
16 Breese, F. (ed.) 1975 National Petroleum News Factbook Issue.
67:142-3. Mid-May 1975. p. 118.
3-25
-------
17. Thakker» B. Screening Study to Develop Background Information and
Determine the Significance of Emissions from Lead Battery Manufacture.
Vulcan-Cincinnati, Inc. Prepared for the U.S. Environmental Protection
Agency under Contract No. 68-02-0299, Task No. 3. December 1972.
p. 1.
18. Op. cit. Ref. 9. p. 6.
19. Op. cit. Ref. 13. p. 7.
20. Op. cit. Ref. 5. p. 82.
21. Op. cit. Ref. 16. p. 118.
22. Op. cit. Ref. 2. p. 1.
23. Ibid.
24. Ibid. p. 5.
25. U.S. Bureau of Labor Statistics. United States Economy 1985
Outlook. U.S. Government Printing Office, Washington, D.C.
Bulletin 1809. 1974. p. 57.
26. Hamilton, W.F. A Survey of the Economic Impact of Various Levels
of Lead Removal Upon Selected Industries. Office of Air Quality
Planning and Standards. Environmental Protection Agency. October
19, 1973. p. 6-1.
27. Op. cit. Ref. 2. p. 5.
28. Ibid.
29. Op. cit. Ref. 13. p. 7.
30. Hehner, N.E. Storage Battery Hanufacturing Manual. Independent
Battery Manufacturing Association, Inc. Largo, Florida. 1970. p.
14.
31. Ibid.
32. Ibid. p. 30.
3-26
-------
4,0' EMISSION CONTROL TECHNIQUES
The lead-acid battery industry currently applies various participate
controls with efficiencies ranging from 50 to 99.8 percent. An estimated
60 percent of these control devices used are baghouses with efficiencies
ranging from 96 to 99.8 percent; the remaining 40 percent consists of
venturi scrubbers, packed bed scrubbers, impingement and entrapment
scrubbers, and cyclones with reported efficiencies ranging from 50 to 98
2
percent.
Manufacturers often vent a number of processes to the same control
device via a collection system of ducts and hoods. The control systems
used at individual plants depend upon plant layout and economics of product
recovery. Sections 4.1 through 4.5 describe emission control techniques
applicable to facilities in the lead-acid battery industry. These sections
also present the results of source tests performed for this study and
other applicable data.
For this background study, emisions tests were conducted at four
lead-acid battery plants (plants B, Ds 6, and L). Measurements of lead
emissions from controlled sources were conducted according to the proposed
EPA Reference Method 12—Determination of Inorganic Lead Emissions from
Stationary Sources, EPA Reference Method 8, was used to measure emissions
of sulfuric acid mist from formation processes.
4-1
-------
In a prior study, lead emissions were tested at three plants (plants
B, 0, and K). The method used to measure lead emissions in these tests was
similar to Method 12.
The results of emissions tests are presented in Appendix C and summarized
in this chapter. The ranges of emission concentrations are depicted as
data bars in several figures. These figures allow comparison of lead emission
concentrations detected in the emission tests.
4.1 GRID CASTING MACHINES AND FURNACES
Emissions from grid casting furnaces are often uncontrolled, and many
plants vent this facility to the surrounding work space rather than
directly to the outsiderair/ Some plants have used low-energy wet scrubbers
to control these exhausts. There are no known applications of fabric
filters on this facility.
Particle size data for particulates emitted from grid casters are
presented in Figure 4-1.
4.1.1 Scrubbers
An impingement and entrainment jscrubber-»_such as the type N Roto-
Clone, is a common device for controlling grid casting emissions. These
units are relatively small, with moderate power requirements (1245 Pa or
5 in. W.G. pressure drop) and low water requirements (makeup water typically
•3
less than 0.134 1/m or 1 gal./lOOO acf). Liquid-to-gas ratios generally
range about 2.6 1/m (20 gal./lOOO acf) of exhaust. Collection efficiency
is generally about 90 percent as indicated by EPA tests at Plant D.
Multiwash centrifugal or cascade scrubbers are also used. These
•3
units typically accomodate up to 1415 m /min (50,000 acfm) with water
injection requirements as low as 0.4 1/m3 (3 gal./lOOO acf).
Frequently, grid casting machines and furnaces are vented along with
other operations, such as small parts casting and lead reclamation, to a
single low-energy scrubber.
4-2
-------
10
9
8
7
6
1 T
1 T
g
u
1.0
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2
0.1
0,09
0.08
0.07
0.06
0.05
0.04
0.03
0.02
0.01
J I
J_
I
1
1
I
J I
10 15 20 30 40 50 60 70 80 85
CUMULATIVE PERCENT LESS THAN STATED H1CRON SIZE
90
95
98
Figure 4-1. Particle size of particulate emissions
from a grid casting operation.
4-3
------- An error occurred while trying to OCR this image.
-------
*^
u
MISSIONS, gr
UJ
a
tu
UJ
— 1
1
o
o
z
U.UiUUU
0.01800
0.01600
0.01400
0.01200
0.01000
0.00800
0.00600
0.00400
0.00200
0
PLANT
PROCESS
KEY: '
4) EPA NSPS TEST
4^ AVERAGE
O OTHER
~
-
-
c
-
-
—
1 — H
-
_
p
~®r o ID »-^-«
/ 1 ^~-S ^LX ^y
D J D D
GRID GRID GRID CASTING GRID CASTING
CASTING CASTING AND FULL AND MIXING**
40. 0
36.0
32.0
"E
28.0 "
o
24.0 id
c
uul
.. i
_J
O
Q:
15. C |
LJi
=
12.0
8.0
4.0
AVG, DSCFM
14.900 530
MIXER CYCLE*
16,100
16,200
* Includes time during which mixer was charged,
** Excludes time during which mixer was charged.
Figure 4-2. Uncontrolled emissions from grid casting and
combined grid casting and mixing.
At Plant D both grid casting and paste mixing exhausts
were vented in common duct. See Figure 4-4.
4-5
-------
0.00100
0.00090
0.00080
0-00070
*-
u
kfl
XI
i.
°1 0.00060
vi
O
ts\
V)
5 0.00050
UJ
_J
O
^ 0.00040
o
ct
»-
O
u
0.00030
0.00020
0.00010
PLANT °
PROCESS
AVG. OSCFH
KEY: '
f) EPA KSPS TEST
J^ AVERAGE
"
>-
—
-
-
-
C C|
tto.. * -
1
D "" D D
GRID GRID CASTING GRID CASTING
CASTING AND FULL AND MIXING**
MIXER CYCLE*
16,700 17,200 16,400
2.00
,0
.60,
1.40
1.20
1.00
0.80
0.60
0.40
0.20
* Includes time during which mixer was charged.
** Excludes time during which mixer was charged.
Figure 4-3. Controlled emissions from grid casting and from
combined grid casting and mixing.
a At Plant D both grid casting and paste mixing exhausts were
vented in a common duct. See Figure 4-4.
4-6
-------
GRID CASTING EMISSIONS
MIXER
EMISSIONS*
MIXER
EMISSIONS*
MIXER
EMISSIONS*
MIXER
EMISSIONS*
ONE COMPLETE
HI XING CYCLE
* Gases vented from mixer to Roto-Clone only during that portion of the
cycle in which the inpredients are actually mixed.
** During that portion of the mixing cycle in which the ingredients are
charged to the mixer, the mixer is venter! to a haghnuse*—not to the
Roto-Clone.
Figure 4-4, Graphic representation of emissions
vented to Plant D Roto-Clone over a period of time.
4-7
-------
lead emissions may be attributed to this melting pot. However when there
are no parts being cast there is virtually no activity at this facility.
Also the pot temperature is kept just below the melting point of lead
thereby avoiding the formation of lead fumes. Therefore it is estimated
that these emissions are negligible in relation to the grid casting emissions.
Test results relative to mixer emissions (which occurred concurrent with
the grid casting emissions) are discussed in Section 4.2.
In another study, grid casting emissions were tested at plant J. Uncon-
2
trolled lead emissions from this plant ranged from 2.70 to 7.05 mg/m (11.8 to
30.8 gr/dscf) with an average value of 4.39 mg/m (19.2 gr/dscf). The grid
casting facility at this plant was not equipped with any emission control
equipment.
4.1.2 Fabric Filters
As previously stated, there are no known applications of fabric
filters on this facility. This is because of the potential blinding from
mold release agents and the spark hazard from oil and powdered cork. The
spark hazard has been minimized by using spark arresters in the control
network in other metallurgical processes, and can be eliminated by simply
recycling only clean scrap to the grid casting pots.
Another reason industry is reluctant to use fabric filters .to control
emissions from grid casting furnaces is the fear that mold release agents,
most notably sodium silicate and acelylene soot, will cause fabric blinding
and render the filter ineffective. Sodium silicate is commonly used in
the industry to prevent the lead from sticking to the grid molds. It is
applied by spraying an aqueous suspension of the material directly onto
the molds.
4-8
-------
The reason operators surmise that this will blind the fabric is its
physical characteristics. It is a slimy substance which does not appear
to dry readily. However, in practice, fabric blinding apparently does not
occur. A major manufacturer which supplies sodium silicate to battery
manufacturers successfully uses fabric filters to control emissions from
his sodium silicate spray dryers, and reports no major operational or
3
maintenance difficulties.
Another technique used by some manufacturers to prevent lead from
sticking to the molds is called acetylene burning. This is simply the use
of an acetylene torch, without oxygen, to produce soot. This soot is
blown onto the molds with the torch and produces an oily, carbonaceous
film which acts as the mold release agent. This method is somewhat
archaic and not used, or used very infrequently, by many major manufacturers.
One major manufacturer uses this method only when manufacturing batteries
4
for submarines. Another manufacturer states that only one of his ten
plants uses acetylene burning. When asked why only one of the ten plants
uses the technique, the company's representative stated that this is
simply the method they had gotten used to and they saw no reason to force
a change. EPA could not locate an installation which uses fabric filters
to control acetylene soot. However, there are apparently several viable
alternatives to acetylene burning at battery plants and this need not be a
deterrent to the use of fabric filters. Based on the performance of
fabric filters on the three-process_op.e,ca-t*0n—(discussed in Section 4.3)
an air-to-cloth ratio of about 6/1 should be adequate to control this
process to 99percent lead removal. No data are available for this
specific application, however.
4-9
-------
4.2 PASTE MIXER
Both baghouses and scrubbers are used to control paste mixing emissions.
Some plants vent the mixer to a baghouse during the material charging
phase and then to a wet collector during the final "wet" mixing phase.
Most plants use only a scrubber.
Typically when two control devices are used, other operations are
controlled by the same devices. For example, at Plant D, a baghouse
controls the mixer during the charging period of the mixing cycle and it
also controls the plate slitting machine at all times. The wet collector
at Plant D is a Type N Roto-Clone that controls the paste mixer during the
mixing period of the cycle and also controls the grid and small parts
casting machines and furnaces at all times. Use of the Roto-Clone during
the mixing cycle prevents possible plugging of the bags by the moist
exhaust. The exhaust stream is transferred from one control device to the
i
other via an automatically operated damper located at the mixer hood. <
Particle size for particulate emissions from the paste mixer at Plant i
D are presented in Figure 4-5.
4.2.1 Scrubbers . j
An impingement entrainment scrubber such as the Type N Roto-Clone is j
troljiJ.xing^pfiralljoiis^-^These units are relatively !
small, (in the range of 30 to 300 m3/min [1,000 to 10,000 acfrn]) with a
pressure drop of approximately 1245 Pa (5 in. W.G.). Makeup water is
2
generally less than 0.134 1/m (1 gal./lOOO acf) and liquid-to-gas ratios
generally are about 2.6 1/m3 (20 gal./lOOO acf) of exhaust. Most of the
water loss is due to evaporation; about 20 percent results from recirculation
tank blowdown. Collection efficiency is approximately 90 percent, as
indicated below.
4-10
-------
10
9
8
7
6
5 -
EMISSIONS DUCTED TO
FABRIC FILTER
(INCLUDES SLITTING)
EMISSIONS DUCTED TO SCRUBBER
(INCLUDES, GRID CASTING)
o
V
u
"e
1.0
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2
0.1
0.09
0.08
0.07
0.06
0.05
0.04
0.03
0.02
0.0
J L
J_
J L
_L
10 15 20 30 40 50 60 70 80 85 90
CUMULATIVE PERCENT LESS THAN STATED MICRON SIZE
98
Figure 4-5.
particle size of particulate emissions
from a paste mixer.
4-11
-------
4,2.1.1 Test Data--
All paste mixing source tests under this program were run at Plant D.
Source tests were run at the inlet and outlet of the Roto-Clone,
having a pressure drop of 1245 Pa (5 in. W.6.), both continuously (including
the time when the mixer exhausts were ducted to the baghouse) and during
the mixing portion of the cycle only. Two inlet samples and four outlet
samples were taken during full mixing cycles; two inlet samples and three
outlet samples were taken during mixing only. Figures 4-2 and 4-3 show
the results of these tests. During full mixing cycles (the continuous
3
tests), uncontrolled lead emissions at the inlet were 2.4 and 25.4 mg/m
(10.6 x 10~4 and 111 x 10~4 gr/dscf, 0.153 and 1.47 Ib/hrh the controlled
lead emissions ranged from 0.21 to 0.27 mg/m (0.9 to 1.2 x 10" gr/dscf,
0.013 to 0.017 Ib/hr). The two sets of tests run concurrently indicated
Roto-Clone removal efficiencies for lead of 98.8 and 89.5 percent. Uncontrolled
lead emissions measured during the mixing portion of the cycle only (keep
in mind that all Roto-Clone data include emissions from the grid casting
operation) were 1.6 and 3.2 mg/m (7.0 x 10 and 13.9 x 10 gr/dscf,
0.09 and 0.20 Ib/hr). Controlled emissions ranged from 0.16 to 0.32 mg/m
(0.7 x 10"4 to 1.4 to 10~4 gr/dscf, 0.0096 to 0.021 Ib/hr). Roto-Clone
efficiencies during the two sets of tests run concurrently were 89.6 and
89.7 percent.
As the figures indicate, results of the tests at the Roto-Clone show
no clear difference in lead emissions in relation to the operating mode of
the processes vented to the control device. Results of the source tests
for controlled lead emissions indicate that the Roto-Clone can reduce lead
concentrations to less than 0.34 mg/m (1.5 x 10 gr/dscf) (approximately
0.02 Ib/hr at this plant). Furthermore, efficiency calculations indicate
\
that a properly maintained wet collector can control approximately 90
'percent of the lead emissions from grid casting and paste mixing.
4-12
-------
In a previous study, paste mixing emissions were tested at plant J. At
this plant, the entire mixing cycle is controlled by a Schneible multistage
impingement scrubber with a pressure drop of 500 Pa (2 in. W.G.). The lead
removal efficiency of this scrubber was 86 percent. The inlet and outlet
grain loadings of lead averaged 77.3 and 10.8 mg/m (338 x 10" and 47.0 x
-4
10 gr/dscf), respectively. The measured exhaust rate was approximately
5.4 m3/min {190 dscfm).
While the efficiencies of the Cascade scrubber and Roto-Clone {86 and
90 percent respectively) at Plants J and D are about the same, comparisons
are difficult regarding the relative efficiencies of the two devices. The
lead particulate concentration of the inlet stream at Plant J is an order
of magnitude higher than the concentration at Plant D and it is generally
accepted that the more concentrated the exhaust stream, the more efficient
the control device.
4.2.2 Fabric Filters
r \
I Fabric filters with air-to-cloth ratios ranging from 4/1 to 8/1 arej
used to control particulate and lead emissions from the charging phase of
paste mixing. The bags are typically made from or!on felt, polyester,
cotton sateen, dacron, or wool. Pressure drops across the bags are 249 to
1494 Pa {1 to 6 inches W.G.).
There appear to be no technological reasons why fabric filters
cannot be used to control emissions from the entire mixing cycle. This is
currently being done at at least one facility. However, the fabric
filter at this facility does not have provisions for preventing the paste
mixer gas from falling below its dew point in the baghouse. Consequently,
this installation occasionally experiences a .high pressure drop across the
fabric filter, apparently because of the moisture which combines with the
particulate to form a mud cake which blinds the bags.
4-13
-------
Condensation of moisture in fabric filters is a potential problem
o
which has been overcome by other industries. The solution usually
involves insulation of the baghouse and all ductwork leading to it, and
often requires the installation of a small auxilliary heater-to keep the
gas temperature above its dew point. This auxilliary heat is sometimes
needed only during startup or shutdown of the facility. To provide a
margin of safety, it is recommended that the gas temperature be maintained
g
50-75° F above its dew point.
4.2.2.1 Test Data—
The mixer at Plant D is vented to a baghouse during the dry materials
charging portion of the mixing cycle and while the mixer is idle. This
baghouse has no provisions for preventing condensation of moisture.
Therefore, as explained in Section 4.2, the gases are diverted to a
scrubber during the portion of the cycle when moisture is evolved. The
same baghouse continuously controls the slitting operation. The slitter
divides the pasted grids into two plates. Slitting is not common to all
lead-acid battery manufacturers and is considered an affected facility
under "other lead-emitting operations." Many plants break the pasted
grids into two plates after curing.
Source tests were run at the inlet and outlet of the Plant D baghouse.
One test was run during slitting only, one was run during the full mixing
cycle (including the times when the mixer was vented to the scrubber), and
two were run during mixer charging only. Figures 4-6 and 4-7 show the
results of these tests.
Prior to the tests, lead emissions from the slitting operations
were expected to be negligible when compared with the emissions from
4-14
-------
0.05000
0.04000
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fj
f) EPA NSPS TEST i
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m!TLI,vrR SLITTING SLITTING AND SLITTING AND
ULL MIXER FULL HIXER CYCLE MIX£R CHARGING
-100
-80
-60
IT
c
40 S
AVG. DSCFM
CYCLE
927
24,000
22,900
23,900
Figure 4-6. Uncontrolled paste mixing and slitting emissions
a
At Plant D both grid casting and paste mixing exhausts
were vented in a common duct. See Figure 4-4. The
slitting station exhausts were also vented to the same
common duct.
4-15
-------
VALUE OFF SCALE; AVERAGE
TEST VALUE IS 10.8
(0.004? gr/scf)
0.00100
0,00090
0,00080
0.00070
tn
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°1 0.00060
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0.00020
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PLANT
PROCESS
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f) EPA NSPS TEST
J^ AVERAGE
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~
_
(D
i 3
M— M
1 f
€ W
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—
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"" ,1 D D D
SLITTING SLITTING SLITTING AND SLITTING AND
FULL MIXER FyLL MIXER CYCLE MIXER CHARGING
-2.CO
-1.CO
-1.60
-1.--50
-1.00
-0,80
-0.60
- 0.40
-0.20
CYCLE
AVG. OSCFM 909 2^,200 2«,80C
24,iDO
Figure 4-7. Controlled paste mixing and slitting emissions.
a At Plant D both grid casting and paste mixing exhausts
were vented in a common duct. See Figure 4-4. The
slitting station exhausts were also vented to the same
common duct.
4-16
-------
materials charging.10 However, the source test conducted during slitting
•3
indicated inlet and outlet concentrations of 43.0 and 0.94 mg/m (188 x
10"4 and 4.1 x 10~4 gr/dscf, 3.88 and 0.060 Ib/hr), respectively.
3
Concentrations during the full mix cycle were 66.6 and 1.2 mg/m
{291 x 10"4 and 5.1 x 10"4 gr/dscf, 5.72 and 0.108 Ib/hr) at inlet and
outlet, respectively. Two tests were run at the baghouse during materials
charging and slitting only. One indicated concentrations of 116 and 1.2
mg/m3 (505 x 10"4 and 5.1 x 10"4 gr/dscf, 10.4 and 0.106 Ib/hr) at the
inlet and outlet, respectively; the other test indicated inlet and
Q 4 -4
outlet concentrations of 33.6 and 1.4 mg/m (147 x 10~ and 5.9 x 10
gr/dscf, 2.99 and 0.124 Ib/hr), respectively.
Because of the small number of tests for each operating mode and
the variability of the data, it is impractical to estimate mixer emissions
by difference; that is, by subtracting the emissions attributable to
slitting. However, the source tests do indicate that a baghouse controlling
emissions from the materials charging and slitting operations can reduce
lead concentrations to less than 1.37 mg/m3 (6.0 x 10"4 gr/dscf) (approximately
0.125 Ib/hr at Plant D). Calculations of removal efficiency also show
that a properly maintained baghouse controlling these processes can
reduce lead emissions by at least 98 percent.
4.3 THREE-PROCESS OPERATION (STACKING, BURNING AND ASSEMBLY)
\Well-controlled lead-acid battery plants use fabric filters or
\ " -v
scrubbers to control the three-process operation, jMost plants vent the
stacking, burning, and assembly operations into a common duct prior to
cleaning the gases. Other plants clean exhausts from paste mixing and
the three-process operation with a common system.
4-17
-------
Particle size data for participate emissions from the three-process
operations at Plants B and D are presented in Figures 4-8 and 4-9.
4.3.1 Fabric Filters
Based on plants surveyed by EPA, the industry typically uses shaker-
type fabric filters having air-to-cloth ratios of 6/1 to 7/1 to control
three-process emissions. Hood design is very important because of the
large number of emission points (stacking, burning, and assembly usually
are performed at several stations).
4,3.1.1 Test Data—
The three-process operation facilities at Plants B and D were
tested, with results as shown in Figures 4-10 and 4-11. Plant capacities
are 4500 and 4000 bpd at B and D, respectively. During the tests, Plant
B averaged 1660 batteries during 7 hours of production and Plant D
averaged 1600 batteries during approximately 7 hours of production.
Air-to-cloth ratios of the baghouses are 6.5/1 and 3.3/1 at Plants B and
D, respectively. Three-process production is essentially the same at
both plants.
Three pairs of tests at the baghouse inlet and outlet were performed
at Plant B, which processes both wet and dry batteries in the three-
process operation. The plates and separators at this plant are stacked
at four manual stacking stations and two automated stations. The stacks
are processed on two automatic element assembly units (cast-on-strap [or
COS] machines) and on a proprietary system. Lead concentrations at the
baghouse inlet were 30.0, 33.6, and 19.9 mg/m3 (131 x 10"4, 147 x 1Q~4,
and 87 x 10~4 gr/dscf, 1.99, 2.30, and 1.37 Ib/hr) in the three tests.
Outlet concentrations were 0.44, 0.07, and 0.04 mg/m3 (1.94 x 10"4,
4-18
------- An error occurred while trying to OCR this image.
-------
(A
I
u
10
9
8
7
6
1.0
0,9
0.8
0.7
0.6
0.5
0.4
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0.09
0.08
0.0
0.06
0.0
0.04
o.o:
0.0
0.0
I I L
_L
JL_J L
10 15 20 30 40 50 60 70 80 85
CUMULATIVE PERCENT LESS THAN STATED MICRON SIZE
90
95
98
Figure 4-9. Particle size of particulate emissions
from a three-process operation.
4-20
-------
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0.0250
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41 93
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40.0 £
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=
10.0
AVG. DSCFM 18,100 12,000 32,400
Sample point not included in average because of process
equipment dov/ntime during test.
Figure 4-10. Uncontrolled three-process-operation
lead emissions.
4-21
-------
0.00050
»*-
% 0.00040
"O
en
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2 0.00030
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PLANT
KEY:
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AVG. OSCFM 16,600 20,500 12,000 27,100
3 r-iw^l*. n/i.;.** ««+ .-! «/•! nrlorl in av/orane hpran^P nf nrOCPSS
equipment downtime during test.
Figure 4-11. Controlled three-process-operation
lead emissions.
4-22
-------
0.32 x 10"4, and 0.19 x 10"4 gr/dscf, 0.0347, 0.0056, and 0.0033 Ib/hr).
The average lead concentrations at the baghouse inlet and outlet, \
respectively, were 27.9 and 0.19 mg/m3 (122 x 10~4 and 0.82 x TO"4
gr/dscf, 1.87 and 0.015 Ib/hr), giving an average control efficiency of
99.2 percent.
Three pairs of tests were also performed at the inlet and outlet of
baghouses controlling three-process operations at Plant D. The three-
process facility at Plant D consists of three production lines. Two of
the lines are equipped with mechanical stackers and COS machines. The
otter line has a mechanical stacker, and the elements are joined by
manually burning the leads, (pronounced leeds). Baghouse inlet concentrations
were 40.0, 53.3, and 2.4 mg/m3 (175 x 10"4, 233 x 10"4, and 10.6 x 10"6
gr/dscf; 5.09, 6.31, and 0.29 Ib/hr). The outlet concentrations were
0.55, 1.0, and 0.66 mg/m3 (2.4 x 10"4, 4.4 x 10"4, and 2.9 x 10"4
gr/dscf; 0.071, 0.093, and 0.071 Ib/hr). The markedly lower concentrations
at the inlet in the third test apparently are attributable to process
down-time during the test. The outlet lead emissions were not significantly
affected. The average inlet and outlet concentrations, respectively,
over the two sets of tests were 46.7 and 0.82 mg/m3 (204 x TO"4 and 3.6
x 10 gr/dscf; 5.7 and 0.082 Ib/hr), giving an average control effici-
ency of 98.6 percent.
In tests performed earlier at Plants B and 0 the controlled lead
emissions averaged 0.15 and 0.13 mg/m3 (0.67 x 10"4 and 0.56 x 10"4
gr/dscf), respectively. Uncontrolled lead emissions at Plant J averaged
4.3 mg/m (18.7 x !0~ gr/dscf), indicating a baghouse efficiency of 97
percent.
4-23
------- An error occurred while trying to OCR this image.
-------
4.4.1.1 Test Data—
The lead oxide production facility at Plant B was tested, with
results as shown in Figure 4-12. Lead oxide is produced by two ball
mills, each followed by two baghouses which-provide participate control
and also collect the product. One ball mill is controlled by two baghouses
in parallel having air-to-cloth ratios of 2/1 and pressure drops of 249
to 498 Pa (1 to 2 inches W.G.h the other ball mill is controlled by two
baghouses in parallel having air-to-cloth ratios of 4/1 and pressure
drops of about 1494 Pa (6 inches W.G.). Exhausts from all four baghouses
are combined and released to the atmosphere through a single stack. The
normal feed rate to each ball mill is 189 grams of lead per second (1500
pounds per hour), input for the two mills totaling 378 g/sec (3000
Ib/hr); the feed rate can be increased as required to 314 grams per
second (2500 pounds per hour) to give a total rate of 624 g/sec (5000
Ib/hr). Throughout the tests, the lead feed rate was 189 g/sec (1500
Ib/hr) through each ball mill, totaling 378 g/sec (3000 Ib/hr).
Three tests were run at the common outlet of the four baghouses
associated with lead oxide production. No tests were performed at the
baghouse inlets. The lead concentrations in the three tests were 1.1,
2.3, and 1.1 mg/m3 (4.9 x 10"4, 9.9 x 10"4, and 4.9 x 10"4 gr/dscf;
0.010, 0.022, and 0.011 Ib/hr), giving an average lead concentration of
1.5 mg/m (6.6 x 10 gr/dscf, 0.014 Ib/hr). These values are equivalent
to emissions of 3.17, 6.35, and 3.17 grams (0.007, 0.014, and 0.007
pounds) of lead per ton of lead input to the process. Tests at Plant B
in 1974 indicated average lead emissions of 0.39 mg/m (1.7 x 10
gr/dscf, 0.0026 Ib per ton of lead input).11
4-25
-------
VALUE OFF SCALE; AVERAGE
TEST VALUE IS 71.9 mg/mj
(0,0314 gr/dscf)
U.UUIUU
0.00090
0.00080
v 0.00070
u
V,
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£ 0.00060
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0.00010
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PLANT
re. DSCFH
FACILITY
<4 KEY:
1
1 C EPA NSPS TEST
j
1 ^ AVERAGE
1 V
1 O OTHER
I
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1
1
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B 8 K
2,530 2,710 1220
BALL MILL BALL MILL BARTON POT
2.00
1.80
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1.40 g"
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0.80
0.60
0.40
0.20
Figure 4-12. Emissions from lead oxide production
using a baghouse for product recovery.
4-26
-------
The test results show that operation of baghouses in a control
recovery system can reduce lead emissions from a ball mill lead oxide
production facility to less than 1.1 mg/m (5.0 x 10" gr/dscf).
The only data available on lead emissions from a baghouse-controlled
Barton Process are from tests performed in 1973 at a lead oxide manufacturing
17
plant. These data show emissions at the baghouse outlet averaging
71,9 mg/m3 (314 x 10"4 gr/dscf or 0.45 Ib/ton of lead input). This
level is significantly higher than those obtained in tests of ball mill
emissions. However, the test report did not specify air-to-cloth ratio,
or fabric type so no conclusions can be drawn regarding Barton Process
versus ball mill lead oxide production emissions. No other test data on
Barton pot emissions are available.
4.5 LEAD RECLAMATION
The exhaust gas stream from the lead reclamation process is
similar to the grid casting and small parts casting exhaust gases in
that both are characterized by high temperatures and lead fumes. Since
these gas streams are similar in character it is not uncommon to vent
these processes to a common control device.
Particle size data for particulates emitted from a lead reclamation
furnace are presented in Figure 4-13.
4.5.1 Scrubbers
/ Lead reclamation furnaces are generally controlled with low-energy
wet\scrubbers\ Low-energy multistage or Roto-Clone-type wet collectors
are used most frequently, with pressure drops less than 2 kPa (8 inches
W.G.) and liquid-to-gas ratios of 0.4 to 0.7 1/m3 (3 to 5 gal./lOOO
acf).
4-27
-------
O
L.
U
10
9
8
7
e
5-
1.0
0.9
0.8
0
0
0
0.4
0.3
0.
0.
0.0!
0.08
o.o:
O.Oi
0.0
0.04
0.0
0.0
0.0
i—r
J L
JL
_L
I I I
10 15 20 30 40 50 60 70 80 85 90
CUMULATIVE PERCENT LESS THAN STATED MICRON SIZE
95
98
Figure 4-13. Particle size of particulate emissions
from a lead reclaim furnace.
4-28
-------
The lead reclamation facility at Plant G is controlled with a
cascade scrubber. Tests of uncontrolled and controlled lead emissions
gave the results shown in Figures 4-14 and 4-15, respectively. Charges
of scrap lead during three tests were 431, 404, and 508 kg (950, 890,
and 1120 Ib). The liquid-to-gas ratio ranges from 0.53 to 0.70 1/m3
(4 to 5 gal./lOOO acf) of exhaust at a pressure drop of 498 to 747 Pa (2
to 3 in. W.G.). This scrubber also controls the small parts casting
facility, which was not operating during the tests.
Three tests for lead were run at both the inlet and outlet of the
cascade scrubber. Lead concentrations at the inlets were 175, 214, and
293 mg/m3 (765 x TO"4, 937 x 1Q~4, and 1280 x 10~4 gr/dscf; 2.10, 2.69,
and 3.72 Ib/hr). Concentrations at the outlet were 2.2, 4.3, and 3.9
mg/m3 (9.4 x 10"4, 19 x 10"4, and 17 x 10~4 gr/dscf; 0.028, 0.059, 0.050
Ib/hr). Average inlet and outlet concentrations were 229 and 3.4 mg/m
(1000 x 10~4 and 15 x 10~4 gr/dscf, 2.8 and 0.046 Ib/hr), respectively.
These values indicate an average control efficiency of 98,3 percent.
The test results demonstrate that a low-energy scrubber can reduce
emissions from lead reduction to average less than 3.7 mg/m (16 x 10~
gr/dscf, 0.05 Ib/hr) at a plant with a facility of this size.
4.5.2 Fabric FiHers
A survey of plants performed by EPA indicates that fabric filters
are not used on lead reclamation facilities at lead-acid battery plants.
They are, however, applied to hot exhaust streams in other industries.
Examples are baghouse applications for control of emissions from electric
arc furnaces and sinter plant windboxes in the iron and steel industry.
Tests of baghouses at Plants B and D indicate that a lead collection
4-29
-------
0.1800
0.1600
0,1400
0 . 1 200
2
c/1
s:
UJ
o 0.1000
O
U
0.0600
0 , 0400
0.020
O EPA MSPS TEST
4~ AVERAGE
PLANT
AVG. OSCFH
G
3,300
CO
60
20
280
e
CT>
O
t/1
240
200
60
120
80
40
o
D£
Figure 4-14. Uncontrolled lead emissions exhaust to
a cascade scrubber controlling lead reclaim emissions
4-30
-------
H™.
u
i/1
-u
-^
L.
C*
.
t/5
O
^n
v^
y
tJ-J
0
UJ
_J
Q
1 1 1
-J
O
0£
1—
E,.
O
CJ
AVG.
u.uu<:uu
0.00180
0.00160
0.000140
0.00120
0.00100
0.00080
0.00060
0.00040
0.00020
o
„ KEY:
i | i.) EPA NSPS TEST
; j J^ AVRAfF
; ! c
•^ i i *,
1 j
i i
i i
— : i
I i
; 1
t i
j I
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— 1 !
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1 1
[ 1
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i \
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4.0
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£1
UJ
2.4 o
«3t
^tJ
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?.0 ^
g
o
i^ji
1.6
1.2
0.80
0.40
PLANT G
DSCFM 3,600
Figure 4-15. Controlled lead emissions from
a cascade scrubber controlling lead reclaim emissions
4-31
-------
efficiency in excess of 98 percent can be achieved. These devices
controlled exhaust gases from the three-process operation stations and
had air-to-cloth ratios of 6/1 and 3/1 respectively.
4.6 FORMATION
As explained in Chapter 3, formation processes are divided into two
categories, those which form in the battery case and those which form in
open tanks. Formation processes do not emit lead, but are a source of
sulfuric acid mist. Battery plates formed inside the battery case are
formed slowly (1 to 4 days) and are usually destined for wet-charged
batteries. Battery plates formed in open tanks are formed more rapidly
(usually 16 hours) and are used to make dry-charged batteries. The type
of emissions control for these processes depends on whether or not the
formation area is enclosed.
Very little data on emissions from formation processes are available
from any source. However, based on observations during plant inspections,
the processes which appear to generate much higher emissions are those
which form the plates in open vats. This is also evidenced by the fact
that most companies which form the battery plates inside the assembled
battery have no ductwork to remove emissions from the work area, and
there appears to be no concern about industrial hygiene from either
plant or government personnel. Plants which do duct the emissions from
the work area (those which form in an open vat) have a more acute emission
problem. These plants typically use either foam, scrubbers, mist eliminators,
or combinations of these control techniques to minimize emissions to the
production area and the outside air. Following are emission control
practices used for formation processes.
4-32
-------
4.6.1 Control Techniques
4.6.1.1 Good Work Practice-
When the formation area is not vented to a control device, such as
when the battery is formed after complete assembly, the operator should
form the batteries slowly and keep every battery filler cap on the
battery at all times during the formation period. This minimizes emissions
to the work area, and hence to the atmosphere. One large battery manufacturing
company leaves the top of the battery case off during the assembly
process and does not install the top until after formation is complete.
During formation, a dummy, reuseable cover is placed on top of the
batteries being formed. This helps to reduce emissions since much of
the sulfuric acid mist impinges on the slave cover and condenses back
into the battery.13
4.6.1.2 Water Sprays--
Many plants which form in the battery case (wet formation) spray
the batteries with water during the formation process. The spray may
absorb some sulfuric acid mist but is primarily used to keep the temperature
of the batteries lower than it would normally be since, as experienced
in Chapter 3, sulfuric acid mist emissions increase proportionally with
14
acid temperature during formation.
4.6.1.3 Ceramic-Disk Caps--
One manufacturer who forms the batteries while they are completely
assembled in the case has a patented battery filler cap which has a
ceramic disk on the inside of the cap. The only escape for the gas is
through the cap, and this manufacturer claims that the disk absorbs
hydrogen (which is a carrier for the sulfuric acid mist), thus virtually
4-33
-------
eliminating sulfuric acid mist emissions generated during formation.
The acid is dumped from the battery after formation and the batteries
are centrifuged to remove any remaining acid. After centrifuging, the
"wet" batteries are filled with fresh acid and the "dry" batteries are
15
shipped as is.
4.6.1,4 Foam Covers--
Some companies which form the batteries in open tanks (dry formation)
cover the tanks with a layer of foam. Two foaming agents typically used
are Alkonol and Dupanol. These foaming agents control sulfuric acid
mist by collecting the mist particles from the surface of the sulfuric
acid solution before they can escape into the formation room. Three
formation processes using foam were surveyed by EPA. Subjective measurements
of the mist cloud above forming tanks and the characteristic acid odor
in the forming room suggested a decrease in acid mist emissions when
foam is used. Emission measurements at one plant (Plant L) did not
confirm a reduction in emissions (see Section 4.6.2 and Appendix C).
4,6.1.5 Scrubbers--
The only companies which use scrubbers are those which form the
batteries in open vats (dry formation). The scrubbers used by these
companies are typically low energy type scrubbers, such as the Heil fume
washer (a scrubber and mist eliminator), and several non-commercial
designs. Plants which use scrubbers either enclose the formation tanks
and duct the emissions to the scrubber, or they form the battery in a
room which can be closed off. The emissions in the room are then ducted
to the scrubber.
4.6.1.6 Mist Eliminators--
4-34
-------
Some companies which form their batteries in open vats use mist
eliminators rather than scrubbers. A popular brand used by this industry
is the Tri-Mer scrubber. This mist eliminator catches the mist particles
as they go through a fan separator followed by a packed tower. The
packing is then periodically washed (called flushing) on a schedule
ranging from once per day to two or three times per shift.
4.6.2 Test Data
Two open vat-type (dry) formation processes have been sampled by
EPA. The first test did not yield any valid results because the process
was not operating proper.ly (one of three formation circuits was inoperative).
Also, emissions from the control device were not detectable when EPA
Reference Method 8 was used to collect emissions over a two-hour sampling
period. Uncontrolled emissions were not sampled at this plant.
The second formation process (Plant L) was sampled during four
separate sixteen-hour cycles. The emission control on formation at this
plant consisted of the use of foam in combination with a scrubber/mist
eliminator. Samples were taken at the inlet and outlet of the scrubber/mist
eliminator during three formation cycles when foam was in use and one
cycle when foam was not applied. Because emissions from the formation
process increase towards the end of the sixteen-hour cycle, only samples
taken during the last five hours of each cycle were analyzed for average
emissions. These results are shown in Figures 4-16 and 4-17. Acid mist
emissions without the use of foam were 65 mg/m (0.028 gr/dscf, .66
Ib/hr) before the scrubber and 1.6 mg/m3 (0.0007 gr/dscf, 0.02 Ib/hr)
after the scrubber/mist eliminator. With the use of foam, emissions
2
averaged 66 mg/m (0.029 gr/dscf, 0.70 Ib/hr) before the scrubber and
4-35
------- An error occurred while trying to OCR this image.
-------
0.00220
0.00200-
0.00180
. 0.00160
o
to
0.00140
0.00120
0.00100
0.00080
0.00060
0.00040
0.00020
PLANT
AVG. OSCFM
KEY:
O EPA NSPS TEST
-H AVERAGE
5.000
4.500
4.000
3.500 2
3.000 *
a
t_j
«x
2.500
2.000 i
1.500
1.000
0.500
L
3180
Figure 4-17. Controlled formation emissions.
4-37
-------
2.3 mg/m3 (0.001 gr/dscf, 0.03 Ib/hr) after control. Additional detail
on these tests is presented in Appendix C.
4.7 CONTROL PERFORMANCE SUMMARY
Figures 4-18 and 4-19 respectively, show average uncontrolled and
controlled lead emissions from all processes tested during the EPA test
program. Table 4-1 summarizes control equipment parameters during these
tests. Details of the tests are presented in Appendix C.
The lead-acid storage battery industry generally uses low energy
scrubbers to control production processes which evolve gases containing
moisture or possible spark hazards. EPA has concluded that fabric
filters can be used to control all lead emitting processes, provided
that necessary precautions are taken to prevent moisture condensation
and sparks. This conclusion is partially based on the similarity of
emission characteristics (especially particle size) of all battery
manufacturing processes for which we have emission data. Also, fabric
filters are commonly used to control emissions from other industries
having similar moisture and spark hazards.
4-38
-------
I
CO
U.ULMOU
O.OOT40
0.00120
o
•n
™ 0.00100
ISt
0
in
S 0.00080
a
s
a
j 0,00060
o
QC
i-
1
0.00040
0.00020
0
PROCESS
1 1 t T 1 I 1 1 ! I
~
_
_
i t
— • "-
, , ' '
H- ^^
1 l 1 1 I < t 1 l 1
GRID GRID GRID SLITTING SLITTING SLITTING THREE-PROCESS PbO LEAD
CAST CAST CAST AND FULL AND MIXER OPERATION PRODUCTION RECLAIM
AND AND MIX CHARGING
FULL MIXING
MIX
. CONTROL8 R R R BH BH BH BH BH BH CS
PLANT DDDDDDBDBG
Figure 4-18. Average controlled lead emissions from tested facilities (gr/dscf)
-------
i
-P»
o
0.12
«.
0
•8 o.io
t.
ot
1 0,08
«/»
|H*
31
HI
3 0,06
0
Lll
_1
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o
z
ra
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0
PROCESS
1 1 I 1 1 1 -T- i '
— -
-
-
i 1
_-«-MI | >-i-t i ' I 1 1 1 1
SI? 81? 88 *mi" OB &TSS "SSBF JSftn
AND AND MIX CHARGING
FULL MIXING
MIX
PLANT
Figure 4-19. Average uncontrolled lead emissions from tested facilities (gr/dscf)
-------
Table 4-1. CHARACTERISTICS OF CONTROL DEVICES TESTED
Grid casting
Paste mixing
Materials charging
Mixing
Three- process
opo rat ion
Lend oxide
fnattufacturi ng
Lead reclamation
Generic type
of control
device
Impingement and
entrainment
scrubber
Baghouse
Impingement and
entrainment
scrubber
Baghouse
Baghouse
Centrifugal and
imp infjeniont
scrubber
Source
(plant)
code
D
D
D
B
D
B8
G
Test Program Information
Specific
type of
device
Type N
Roto-Clone
Shaker type
Type N
Roto-Clone
Pulse jet type
Shaker type
Shaker type !2S
Pulse jet
type (2)
Cascade
scrubber
» Lead removal
efficiency ,
percent
90
98
90
99.3
98.6
b
98. 3C
Air-to-
cloth
ratio
N/A
3/1
N/A
6/1
3/1
4/1
2/1
N/A
Water- to-
gas ratio,
(gal/1000 acf)
2.6 (203
(in motion)
;J/A
2.6 (20)
{in motion)
[I/ A
N/A
N/A
H/A
0.53 to 0.70
(4-5!
Pressure
drop,
Pa
(in. W.G.)
1245 (5)
249 (1)
1245 (5)
1245 (5)
498 (2)
249- (1-2)
498
1494 (6)
498- (2-1!
741
Four baghouses ducted to Gomroon stack.
i'.o inJot tests taken. Baghouses ar^ considered process equipircnl. (for product rorovoryl v
fourc*? tests show 98 percent efficiency for this low-energy scrnbbt.-r.
Marufacturers1 trade names have In?en used herein for purposes of clarity only. iho us«s iht
shall not be deemed as an endorsement of ;my particular brand of equipment or substanw by
cor*t!-ol devices.
ri-t.,1
KI'A.
-------
REFERENCES FOR SECTION 4
1. Boyle, T.F., and R.B. Reznlk, Source Assessment Document
No. 17, Lead-Acid Batteries. Monsanto Research Corporation.
Prepared for the U.S. Environmental Protection Agency under
Contract No. 68-02-1874. June 1976. (Preliminary report).
p. 50.
2. Ibid.
3. Private Communication between Mr. Lee Beck of the U.S. En-
vironmental Protection Agency and Mr. Walter G. Schleyer of
Philadelphia Quartz Company, December 28, 1977.
4. Private Communication between Mr. Lee Beck of the U.S. En-
vironmental Protection Agency and Ms. Elizabeth Mahaffee of
ESB Battery Company, Inc., December 28, 1977.
5. Private Communication between Mr. Lee Beck of the .U.S. En-
vironmental Protection Agency and Mr. Robert Nicholi of
Globe-Union, Inc., December 28, 1977.
6. Kulujian, N. Test 74-BAT-l, ESB Incorporated, Milpitas,
California. PEDCo-Environmental Specialists, Inc. Prepared
for U.S. Environmental Protection Agency under Contract No.
68-02-0237, Task No. 28. March 1974. p. 9.
7. Trip Report, Standard Electric Company, San Antonio, Texas.
PEDCo-Environmental Specialists, Inc. Prepared for the U.S.
Environmental Protection Agency under Contract No. 68-02-
2085. December 10, 1975.
8. Lindsey, A.M., and Segars, R. Control of Particulate Emis-
sions from Phosphate Rock Dryers. Environmental Protection
Agency, Region IV, Atlanta, Georgia. January, 1974. p. 6.
9. Control Techniques for Particulate Air Pollutants, Environ-
mental Protection Agency, Publication No. AP-51. January,
1969. p. 125.
10. Private Communication between Mr. Lee Beck of U.S. Environ-
mental Protection Agency, and Mr. Robert Nicholi of Globe-
Union, Inc. April 20, 1976.
4-42
-------
11. Report on Source Testing of Five Process Stacks for ESB-
[ Canada, Limited, Mississauga, Ontario. Enviroclean, Limited.
' Willowdale, Ontario, August, 1974.
; 12. Participate and Lead Emission Measurements from a Lead Oxide
t Plant. Monsanto Research Corporation. Prepared for the
' U.S. Environmental Protection Agency under Contract No.
68-02-0226, Task No. 10, 1973. p. 17.
, 13. Private Communication between Mr. Lee Beck of U.S. Environ-
5 mental Protection Agency and Mr. Leland Robinson, Delco-Remy
Division of General Motors Corporation. January 12, 1977.
14. Private Communication between Mr. Lee Beck of U.S. Environ-
mental Protection Agency and Mr. Robert Nicholi of Globe-
Union, Inc. January 13, 1977.
15. Ibid.
4-43
-------
5.0 MODIFICATIONS AND RECONSTRUCTION
5.1 GENERAL
New Source Performance Standards apply to new, modified, and reconstructed
facilities. Therefore, existing facilities are not affected until a
modification or reconstruction is determined to have taken place. The
definitions of modification and reconstruction are presented in the
general provisions applicable to all New Source Performance Standards in
40 CFR 60.14 and 60.15 and are discussed in this chapter.
A step-by-step approach to determining whether a physical or
operational change constitutes a modification or reconstruction under
the regulations is shown in Figure 5-1. Following are simplified definitions
of some of the terms used in the regulations:
0 Source - Generally an entire plant or process consisting of
more than one facility.
0 Facility - A particular operation within a source. For
example, in a lead-acid battery plant, the grid casting
operation, the paste mixing operation, the three-process
operation, etc., would be considered as separate facilities.
° Affected Facility - One that is subject to the emission
limitations of an NSPS. An affected facility is one that is
newly built or one that has been modified or reconstructed.
5-1
-------
START
M1S1IK FHCIUTT
MINI* M IIISTIK
samce
IWKKM. o*
CHANGE IK TW f Mil IT*
ESTIHME FIJED OPITM. COSTS,
Of r« NE« CQWOKEKTS, *
rruu C*PIT*I COST
MQUIMD TO COKSTUUCT Ml
CHllHtf M* FK1UT!. S
60.1S(t>KO
U1
I
N>
IECTNOIOGICM.IY AW
tOHOHUU.1 FEMIIlt
TO WET UmiUUE
NSPS.
M.H!(2)
TES
m
mSTIHS tMUITt
UCCMS M MFEC1ED
F»C!Lm "
-0
YES
n
ws
C > 0
; _
D,S 1
NO
»
TOT»l EH15SIOR MTt
FROM 1HC FAC1LITT
IS tNCRE*SEO
CWCUIUTE CUCIIAL £1
!U«E, 0, 0 rS THE f
'OF THE IAS HE. 101!
AND THE ANNUAL »SSf
LINE WPAH *LLOI
PERCtNTACE
NO
CHANGES ARE ROUT IRC
WINTEMUICC, »EP»I8
OR RtPLMEMEKT
Mil
KKDi-
iMOUCT
MS 15
GUIDE-
WHCE
*
CAlCUUU TOTU. UPtKDlIUW
FOB THE CHANGE. C
»
CHANCE IS AH IRCREkSE
IN PMOWIICW RATE
CHM&E IS M I"CRf«S[
I* NOUtSOf «HMtlQM
M.14(t!(»
res
•0
OMKE IS THE USE OF
Ml AlTEHNltf. FUEL OB
NATE«I*L TO* HH1M
THE FM11H* US
OCSIWtO TO UTllllt
US
*0
FINISH
CKMGI CONSISTS OF ««-
1X6 OR UStW Ml •!»
mitUTMIT CMTWX.
StSFJH *tlCN IS HOT
LESS IH»IROI»«NT*LL»
tEREFIUM.
I
COMSISTS OF
con. cMmistwi n«
SECIIO* 111(11)15) OF
!ME CIEWI »)« Wt
F«ellitj fs not tttoei In b* moiliftid ««l H not sulijtct la «SPS.
Figure 5-1. Method of determining whether changes to existing
facility constitute a modification or reconstruction
under 40 CFR 60.14 and 60.15.
-------
5.1.1 Reconstruction
Irrespective of any change in pollutant emission rates, a replacement
of components of an existing facility may be deemed a reconstruction of
that facility if (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.
5.1.2 Modification
If a physical or operational change results in an increase in the
rate of emission to the atmosphere of any pollutant to which an NSPS
applies, the facility is deemed to be modified. Certain exceptions
apply* as shown in Figure 5-1.
When the purpose of the change in a facility or operation is to
increase production rates and such change causes an increase in emission
rates, the facility is deemed modified only if the total expenditures
(both capital and expense dollars) attributable to the change exceed the
product of the facility's "1012 Basis" and the "Annual Asset Guideline
Repair Allowance Percentage (AASRAP)." The first figure is determined
in accordance with Internal Revenue Code Section 1012. Very simply
stated, it may be thought of as the initial cost, or basis, of the
facility. The latter figure Is given in Internal Revenue Service Publica-
tion 534 (latest edition). Table 5-1 lists the AASRAP values applicable
to various facilities for which NSPS regulations have been promulgated.
5-3
-------
TABLE 5-1. ANNUAL ASSET GUIDELINE REPAIR ALLOWANCE
PERCENTAGES FOR SPECIFIED FACILITIES PER IRS
PUBLICATION 534 (1975 EDITION)
Facility AAGRAP
Nitric acid production unit 5.5
Sulfuric acid production unit 5.5
Lead smelter cupola 4.5
Catalytic cracking unit at 7.0
a petroleum refinery
Electric arc furnace 8.0
5.2 APPLICABILITY OF 40 CFR 60.14 AND 60.15 TO THE LEAD-ACID
BATTERY MANUFACTURING INDUSTRY
5.2.1 Capital Costs of Facilities
In general, the cost of any piece of equipment represents approximately
25 to 33 percent of the total installed capital costs. Cost breakdowns
for a typical installation are given in Tables 8-10 and 8-11, Estimated
capital costs associated with the purchase of various components are
shown in Table 5-2. As mentioned earlier, the replacement of components
may be considered a reconstruction if 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. Thus the
replacement of a rotary mill in a lead oxide manufacturing facility
would not be considered a reconstruction where the fixed capital cost of
the mill is $45,000 and the total fixed capital costs of an entirely new
facility would approximate $125,000.
5.2.2 Roujnne Ma1ntenance, Repair, and Repiacement
Routine maintenance, repair, or replacement of components are
specifically exempted under section 60.14(e)(l). Therefore it is important
5-4
-------
Table 5-2. F.O.B. PRICE OF VARIOUS COMPONENTS FOR LEAD-ACID
BATTERY MANUFACTURING FACILITIES
Facility
Grid casting
Paste mixing
Three-process
operation
Formation
PbO manufacturer
Lead reclamation
Component
Furnace
Grid casting machine
Small parts casting
machine
Mixer
Mixer
Mixer
Automatic stackers
Automatic burning
Automatic assembly
Rectifiers
Rotary mill
Conveyors and storage
Baghouse
Pot furnace
Capacity
1814 kg (4000 Ib)
2492 kg (5500 Ib)
18 grids/min
252 kg/sec (2000 Ib/hr)
630 kg/sec (5000 Ib/hr)
1134 kg/sec (9000 Ib/hr)
170 plates/min
4 btry/rain
100 btry/shift
800 btry/shift
3500 bpd
1 tph
111 m3/min (4000 cfrn)
Other specs j Cost, $a
Includes motor
Includes motor
Includes motor
With motor
$ 2,350
5,210
13,600
8, 360
13,300
24 ,000
33,100
21,900
6,480
3,440
14 ,600
10,400
15,700
8 ,350
11,500
5,220
i
en
These estimates are based on mid-1976 dollars and are quotations obtai.ned from vendors by
telephone and from various cost estimating and equipment pricing guides. Costs for spec i. P.it--
installations will vary. These figures can be used for "order of magnitude" estimates only.
-------
to consider the physical changes that constitute routine maintenance,
repair, or replacement.
Grid casting furnaces require periodic inspection and annual repairs
such as relining. These furnaces are normally relined only five or six
times and then are replaced. Grid casting machines are highly mechanized
and therefore require periodic inspection and replacement of small parts
and an annual complete overhaul. With a good maintenance program, a
grid casting machine can operate for many years.
Paste mixers usually require considerable maintenance because
operators tend to overload the equipment. Gears, shafts, drives, and
other movable parts cannot sustain the mechanical attrition and must be
replaced. The paste mixer shell and other stationary hardware can last
for many years, however, requiring very little maintenance. Like the
grid casting machine, the paste machine is highly mechanized and requires
periodic inspections and annual overhauls. Replacement of chains,
bearings, and drives is common.
Automatic stacking machines, burning machines, and group assembly
machines require continual maintenance. Conveyor chains, bearings, and
small parts are periodically replaced. These machines are also cleaned
periodically and overhauled annually. At plants where the stacking,
burning, and assembly are done manually, little if any routine maintenance
is required.
Equipment for forming dry batteries may corrode during the years
and eventually need replacement. Where batteries are formed in their
cases, corrosion is not a problem. Although rectifiers can burn out if
they are not adequately cooled, this is unlikely; they typically require
5-6
------- An error occurred while trying to OCR this image.
-------
similar). Use of various alternate materials as binders and expanders
also may increase emissions from the mixer. Even old paste is sometimes
ground for use in the negative paste mix. Under section 60.14(e){4)»
such a change in the use of materials would not be deemed a modification
if the mixer was designed to accommodate the alternative material.
5,2.4 Useof Different Control Device
Section 60.14{e)(5) provides an exemption where an increase in
pollutant emission rate is due to the addition or use of any system or
device whose primary function is the reduction of air pollutants and it
is determined by the Administrator of EPA that such system is not less
environmentally beneficial than the original system. An example of this
is replacement of a 99.9 percent efficient scrubber (from which lead-
contaminated water emanates) with a 99.7-percent-efficient dry collector
such as a fabric filter. Replacement of the same scrubber with a 70-
percent-efficient cyclone would be considered less environmentally
beneficial and thus a modification.
5.2.5 Increase_ij_Prpductlon Rate Accomplished Without a Capital
Expenditure
If the purpose of a physical or operational change is to increase
the production rate and if such change results in an increase in emission
rate, the facility will be considered a modified facility only if the
total costs associated with the change constitute a capital expenditure.
If the total costs are lower than those constituting a capital expenditure,
such change is not considered a modification (section 60.14[e][2]).
Capital expenditure is the product of the IRS Regulation 1012 Basis and
the Annual Asset Guideline Repair Allowance Percentage (AAGRAP}. The
1977 Edition of IRS publication 534 sets the AAGRAP at 5.5 percent for
5-8
-------
the lead-acid battery industry. Simply stated, therefore, if the total
cost of the change exceeds 5.5 percent of the original cost of the
facility, the change could constitute a modification.
5.3 ILLUSTRATIVE EXAMPLES
The enforcement division of the appropriate EPA regional office
should be contacted whenever a source has questions regarding modifications
and reconstruction. Their judgment will supercede any general examples
that can be given in a document such as this. However, some examples
are offered below, showing how the regulation might apply to the lead-
acid storage battery industry.
As one example, consider a grid casting facility with a 1012 basis
jr
of $515,000. If the furnace is changed to increase production and the
change results in an increase in the emission rate to the atmosphere of
any pollutant to which a standard applies, the change will be considered
a modification if the cost exceeds $28,325 (5.5 percent of $515,000).
As another example, if a plant operator replaces the motor, paddle
wheel and shell of his paste mixer, the repaired mixer will be subject
to the new source performance standards, even if emissions to the atmosphere
are not increased. This is assuming that the cost of the new components
of the repaired mixer "exceeds 50 percent of the fixed capital cost that
would be required to construct a comparable entirely new facility [mixer]"
and that "it is technically and economically feasible to meet the
applicable standards" (Section 60.15).
5-9
-------
REFERENCES FOR SECTION 5
1. Federal Register, Vol. 40, No. 242. Tuesday, December 16, 1975.
p, 58416.
2. Private Communication between David Augenstein of PEDCo Environmental,
Inc., Cincinnati, Ohio, and Sam Hurley of Winkel Machine Co., Inc.
Kalamazoo, Michigan. January 1976.
3. Private Communication between David Augenstein of PEDCo Environmental,
Inc., Cincinnati, Ohio, and George Tiegel of the Tiegel Manufacturing
Co. Belmont, California. January 1976.
4. Private Communication between David Augenstein of PEDCo Environmental,
Inc., Cincinnati, Ohio, and John Collinson of ESB Canada Limited,
Toronto, Ontario. February 1976.
5. Private Communication between Donald Henz of PEDCo Environmental,
Inc., Cincinnati, Ohio, Lee Beck of U.S. Environmental Protection
Agency, and Robert Stuart of Globe Union, Canby, Oregon. June 14,
1976.
5-10
-------
6.0 EMISSION CONTROL SYSTEMS
This chapter describes emission control systems that are considered
likely candidates to represent the best system of emission reduction.
An emission control system is a combination of a production process or
type of process equipment (Chapter 3) and an emission control technique
(Chapter 4). In the lead-acid battery industry there are no significant
differences in types of process equipment that would limit the use of
one control technique and dictate use of another. For most of the
process operations, however, there is the choice of providing a wet
collector or a fabric filter. None of the operations requires the use
of a series of control devices, such as cyclone, baghouse, and after-
burner. (When a baghouse is preceded by a cyclone at a lead oxide
production facility, the cyclone is considered part of the process
equipment. The baghouse is also part of the process to the extent of
economic removal of valuable lead-oxide from the stack gas. The capacity
of the baghouse to remove lead oxide beyond the point where it is economical
is considered capacity added for emission control).
Given the definition of a control system as consisting of a production
process together with a specific control technique, the next step is to
develop a set of control "alternatives"; these are strategies for combining
the various processes with the available control techniques to achieve
optimum reduction of lead emissions throughout an entire plant. The
selected alternatives, or strategies, discussed in this chapter are
6-1
-------
later considered in terms of their environmental impacts (Chapter 7) and
economic impacts (Chapter 8).
6.1 APPLICATION OF CONTROL TECHNIQUES
The applicability and performance of a control technique with
respect to a specific facility or group of facilities depend on the
characteristics of the exhaust gas and particles, and on the operational
characteristics of the control device and the facility. Other lead-
emitting operations, such as slitting or lug breaking, can be ducted to
any device controlling lead emissions from another facility. Table 6-1
summarizes the control systems that are, or could be, applied to well-
controlled facilities in lead-acid battery manufacturing plants.
6.2 SELECTED CONTROL ALTERNATIVES
As discussed earlier, some facilities may be vented to common
control systems. The possible combinations are many. Eight control
alternatives for lead emissions are presented in Table 6-2. Control
alternatives I through V are applicable to plants of production capacity
greater than 500 batteries per day. Small plants (production capacity
less than 500 bpd) typically do not have lead oxide manufacture and lead
reclamation facilities. Also, it is expected that the economic impact
of requiring emission controls on small plants will be more severe than
on larger plants. Therefore, control alternatives VI, VII, and VIII are
presented to give consideration to small producers of lead-acid batteries.
Selection of these eight alternatives is based on current applications,
engineering judgement, and in the cases of systems I, VI, and VII,
technology transfer. It is emphasized that these alternatives are not
equally effective in abating lead emissions. All eight alternatives
include a "Tiber mist eliminator for acid mist control.
6-2
-------
Table 6-1. SUMMARY OF CONTROL SYSTEMS APPLICABLE TO
LEAD-ACID BATTERY MANUFACTURING FACILITIES
Facility
Grid casting
furnace
Grid casting
machine
Paste mixer
Three-process
operation
Lead reclamation
furnace
Formation
Lead oxide mill
Control technique
Impingement
and entrain-
ment scrubber
1245 PA (in W.G. )
2.6 1/m3
(20 gal/1000 acfm)
X
X
X
X
X
Cascade scrubber
.498 - 747 Pa
(2-3 in W.G. )
0.14-0.67 1/m3
(4-5 gal/1000 acf)
X
Fabric
filter
6/1 A/C
pulse jet
xd
X
X
X
xa
Fabric
filter
2/1 A/C
shaker
X
Mist
eliminator
X
en
I
U)
Based on technology transfer.
-------
Table 6-2. SELECTED CONTROL ALTERNATIVES FOR
LEAD-ACID BATTERY MANUFACTURING INDUSTRY
Plant
size ,
BPD
_—
500,
2000,
&
6500
r
100
4 d
250
Control
alternative
I
II
III
IV
V
VI
VII
VIII
Facilities
ft, B, F
C, E
G
D
B, C, E
F
A
G
D
C, E
A, B, F
G
D
A, B, C
E
F
G '
D
A, B, C, F
E
G
D
A, B, C
E
G
A, B, C, E
G
A, B, C
E
Control system
Fabric filter, 6/} A/C
Fabric filter, .6/1 A/C •
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Impingement and entraintnent
scrubber
Mist eliminator
Fabric filter, 2/1 A/CC
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Impingement and entrainraent
scrubber
Mist eliminator
Fabric filter, 2/1 A/CC
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
, Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 6/1 A/C
Mist eliminator
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Facilities key: A - grid casting furnace,- B - grid casting
machines; C - paste mixer; D - lead oxide manufacturing;
E - three-process operation; F - lead reclamation furnace;
G - formation.
Facilities are vented to common control systems as shown.
Small plants (500 bpd or less) are assumed to have no lead
oxide manufacturing facilities.
Plants smaller than 500 BPD are assumed to have no lead reclama-
tion facilities.
6-4
-------
Electrostatic precipitators and higb energy scrubbers are commonly
used to control particulate emissions from other industries. They are
not considered in any of the control alternatives in this study because
they are not used in the lead-acid storage battery industry, and have no
economic or environmental advantage over fabric filters.
6.3 EFFECTIVENESS OF SELECTED LEAD EMISSIONS CONTROL SYSTEMS
Approximate uncontrolled lead emission rates of the facilities used in
lead-acid battery plants are presented in Table 6-3. These have been
calculated using emission testing data presented and discussed in Chapter 4.
The emission reduction which would result from the use of any one of the
selected control alternatives can be calculated using the collection
efficiencies of the control system components (see Table 6-4). Tables 6-5
and 6-5A compare the expected lead emission rates of 500, 2000, and 6500 bpd
plants using control alternatives I through V and 100 and 250 bpd plants
using alternatives VI through VIII with the approximate emission rates of
plants using no emission controls. Tables 6-6 and 6-6A compare the expected
lead emission rates of plants using the selected control alternatives with
the expected emission rates of plants controlling emissions only to the
extent required by typical State regulations. State Implementation Plan
(SIP) regulations generally limit particulate emissions from a process to a
percentage of the throughput of the process. In order for a lead-acid
battery plant to comply with typical SIP regulations, emissions from the
paste mixing and lead reclamation facilities generally must be controlled
(uncontrolled emissions from lead oxide production facilities, grid
casting facilities and three-process facilities generally do not exceed
SIP limits). SIP emission rates presented in Tables 6-6 and 6-6A were
6-5
-------
en
I
CPi
UNCONTROLLED EMISSIONS OF LEAD FROM
a
Table 6-3.
LEAD-ACID BATTERY MANUFACTURING FACILITIES
Facility
code
A
B
C
D
*
E
F
Facility description
Grid casting furnace
Grid casting machine
Paste mixing
PbO manufacturing
Three- process operation
Lead reclamation
Lead emissions
lig/ro
(gr/sc£)
h
Q.Q940
(0.00116)
1,07
(0.0132)
i
0.107
(0.001325C
1.33
(0.0163)
8.14
(0.10)
g/1000 btry
(lb/1000 btry)
u
408 X
(0.90)D
5079
(11.2)
53
to.ii6)c
6666
(14.7)
349
(0.77)
g/kg Pb throughput
(Ib/ton Pb throughput)
0.01
{Q,G2r
2.95
(5.9)
b
Based on .source test data from Plants B, D, and G.
Facilities A and B were vented to a single control device. It is estimated that
50 percent emanates from each facility. Figures represent emissions from both facilitit
This number is twice the value measured in tests at the outlet of a well-controlled
facility.
-------
TABLE 6-4. ESTIMATED LEAD COLLECTION EFFICIENCIES
OF SELECTED CONTROL SYSTEMS
Control device
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Lead collection efficiency, %
50'
99
90
It is estimated that well-controlled lead oxide manufacturing
facilities emit only half as much lead as one designed only
for economical recovery of lead oxide. Hence only a 50 per-
cent efficiency is stated.
6-7
-------
Table 6-5. EFFECT OF CONTROL ALTERNATIVES ON LEAD EMISSIONS
FROM VARIOUS SIZED BATTERY MANUFACTURING PLANTS
Control
alternative
I
II
III
IV
V
VI
VII
VIII
Plant
size,
bpd
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
TOO
250
100
250
100
250
Lead emissions, kg/day
Uncontrol led
6.25
25.1
81.6
6.25
25.1
81.6
6.25
25.1
81.6
6.25
25.1
81.6
6.25
25.1
81.6
1.22
3.04
1.22
3.04
1.22
3.04
Control led
0.063
0.29V
0.988
0.088
0.388
1.311
0.098
0.424
1.43
0.326
1.31
4.38
0.326
1.31
4.41
0.0122
0.0304
0.0122
0.0304
0.0615
0.1540
percent
removal
99.0
98.8
98.8
98.6
98.4
98.4
98.4
98.3
98.3
94.8
94.8
94.6
94.8
94.8
94.6
99.0
99.0
99.0
99.0
94.9
94.9
Table 6-2 describes the selected control alternatives.
6-8
-------
Table 6-5A, EFFECT OF
FROM VARIOUS SI
CONTROL ALTERNATIVES ON LEAD EMISSIONS
ZED BATTERY MANUFACTURING PLANTS
(English Units)
Control
alternati ve
I
II
III
IV
V
VI
VII
VIII
Plant
size,
bpd
500
2000
6500
500
2000
5500
500
2000
6500
500
2000
6500
500
2000
6500
100
250
100
250
TOO
250
Lead emissions, Ib/day
Uncontrol 1 ed
13.8
55.3
180
13.8
55.3
180
13.8
55.3
180
13.8
55.3
180
14.8
55.3
180
2.68
6.70
2.68
6.70
2.68
6.70
Control led
0.138
0.665
2.18
0.193
0.885
2.89
0.214
0.940
3.15
0.718
2.88
9.67
0.718
2.88
9.73
0.0268
0.0670
0.0268
0.0670
0.136
0.339
percent
removal
99.0
98.8
98.8
98.6
98.4
98.4
98.4
98.3
98.3
94.8
94.8
94.6
94.8
94.8
94.6
99.0
99.0
99.0
99.0
94.9
94.9
a Table 6-2 describes the selected control alternatives.
6-9
-------
Table 6-6. EFFECT OF CONTROL ALTERNATIVES ON LEAD EMISSIONS
COMPARED WITH SIP CONTROLS
Control
alternative
I
II
III
IV
V
VI
VII
VIII
Plant
size,
bpd
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
100
250
100
250
100
250
Lead emissions, kg/day
SIP Controls NSPS Controls
3,81
15.3
49.8
3.81
15.3
49.8
3.81
15.3
49.8
3.81
15.3
49.8
3.81
15.3
49.8
0.76
1.90
0.76
1.90
0.76
1.90
0.063
0.291
0.988
0.088
0.388
1.311
0.098
0.424
1.43
0.326
1.31
4.38
0.326
0.31
4.41
0.0122
0.0304
0.0122
0.0304
0.0615
0.154
Percent
Improvement
98.3
98.0
98.0
97.7
97.4
97.4
97.4
97.2
97.2
91.4
91.4
91.1
91.4
91.4
91.1
98.4
98.4
98.4
98.4
91.9
91.9
aTable 6-2 describes the selected control alternatives.
6-10
-------
Table 6-6A. EFFECT OF CONTROL ALTERNATIVES ON LEAD EMISSIONS
COMPARED WITH SIP CONTROLS
(English Units)
Control
alternative
I
II
III
IV
V
VI
VII
VIII
Plant
size,
bpd
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
100
250
100
250
100
250
Lead emissions
8.38
33.7
109
8.38
33.7
109
8.38
33.7
109
8.38
33.7
109
8.38
33.7
109
1.67
4.18
1.67
4.18
1.67
4.18
, lb/day
0.138
0.665
2.18
0.193
0.885
2.89
0.214
0.94
3.15
0.718
2.88
9.67
0.718
2.88
9.73
0.0268
0.067
0.0268
0.067
0.136
0.339
Percent
Improvement
98.3
98.0
98.0
97.7
97.4
97.4
97.4
97.2
97.2
91.4
91.4
91.1
91.4
91.4
91.1
98.4
98.4
98.4
98.4
91.9
91.9
aTable 6-2 describes the selected control alternatives.
6-11
-------
obtained by assuming 90 percent control of paste mixing and lead reclamation
emissions. AH of the emission rates predicted in Tables 6-5, 6-5A, 6-6,
and 6-6A were calculated with the assumption that 500 bpd plants do not
have lead oxide production facilities and plants smaller than 500 bpd
do not have lead oxide production or lead reclamation facilities.
6-12
-------
7.0 ENVIRONMENTAL IMPACT
The projected impacts of each alternative control system on ambient
air, water quality, solid waste, energy demand, and other concerns are
discussed in this chapter. These are presented in terms of incremental
impacts and are compared with the impacts of uncontrolled sources and
sources controlled to meet existing State regulations.
7.1 AIR POLLUTION IMPACT
7.1.1 LeadEmissions
Lead acid rates from lead-acid battery plants of various sizes are
discussed in Chapter 6. The ambient impacts of these emissions, and
their health impacts and national impacts, are discussed below. Existing
standards which apply to lead acid battery plants are also discussed.
7.1.1.1 Ambient Impact--
A point source atmospheric dispersion model, CRSTER, was used to
approximate ambient concentrations of lead around typical 500 and 6500 bpd
lead acid battery plants.
The single-source CRSTER model is a steady-state, Gaussian-plume-
dispersion model designed for point-source applications. It calculates
pollutant concentrations for each hour of a year at 180 selected receptor
sites. The hourly concentrations are averaged to obtain concentration
estimates for time increments of specified length, such as one hour, 24
hours, and 1 year.
Input to the model consists of the pollutant source characteristics
and a file of hour-by-hour dispersion conditions. The source characteristics
7-1
-------
include the emission rate, stack height, stack diameter (inner), and
stack-gas temperature and exit velocity. The file of hour-by-hour
dispersion conditions is developed by a pre-processor program from
weather observations recorded over a 1-year period. Currently, the
weather data are from 1964 records.
The lead emission rates used as input to the model were based on
data from the EPA test program. The 500 bpd model plant does not include
a lead oxide mill or lead reclamation facility, and emissions estimated
from the test data for a 6500 bpd model plant include emissions from
lead reclamation, slitting, and the lead oxide mill.
Figures 7-1, 7-2, and 7-3 and Table 7-1 present the maximum impacts
on ambient air of emissions from battery plants with and without NSPS
controls. Emission rates used for the uncontrolled cases are those for
plants controlling emissions only to the extent required by SIP particulate
regulations (see Table 6-6). The emission rates used for the controlled
cases are those for plants using control alternative 1 (fabric filter
control of all lead emissions).
7.1.1.2 Health Effects of Lead Emissions-
Airborne lead is believed to contribute to increased lead levels in
2
man. However, it is outside the scope of this study to detail health
effects. The reader is directed to the EPA document titled "Air Quality
3
Criteria for Lead" for a comprehensive discussion of the health effects
of lead emissions.
7.1.1.3 Nationwide Emissions of Lead--
U.S. total lead consumption in 1975 was 1200 Gg (1,270,000 tons) of
which 617 Gg (680,000 tons) was used in storage batteries. Total
7-2
-------
50
CO
en
3
O
o
«t
CL
CO
s: OA
«C 20
1000
2000
3000 4000 5000 6000
PLANT CAPACITIES, bpd
aContro11ed only to the extent required by typical SIP regulations.
Figure 7-1. Maximum ambient impact of lead-acid battery manufacturing
plants for various plant production rates - 1-hour maximum.
7-3
-------
50
40
13
o
30
<
O-
UJ
20
X
-------
50
30
-------
Cn
Table 7-1. APPROXIMATE EMISSION RATES3 AND MAXIMUM RESULTANT
GROUND-LEVEL LEAD AND SULFURIC-ACID MIST
CONCENTRATIONS FOR TWO PLANT SIZES
Maximum
Lead Sulf uric-acid lead ambient
Control Plant emissions, mist emissions, Averaging concentrations,
status size, bpd g/sec g/sec time y/m
. 500 0.13 .007 one-hour
Uncontrolled 24-hour
annual
6500 0.58 0.096 one-hour
24-hour
annual
500 0.0022 0.0004 one-hour
24-hour
Control! edc annual
6500 0.0114 0.005 one-hour
24-hour
annual
31
19
4
88
41
8
1
2
1
Maximum
H2SO. ambient
concentr|tions,
yg/m
3
1
13
3
<}
1
Data basis: EPA source test program.
Subject to SIP particulate regulations on paste mixing and lead reclaim.
cPer control alternative 1 (see Table 6-2).
-------
annual atmospheric emissions of lead are estimated at 194 Gg (214,000
tons),* of which approximately 82 Mg (90 tons) originate from battery
manufacturing processes (See Chapter 3.0).
7J.I.4 Current Standards for Lead--
3
The ambient criteria standard for lead is 1.5 mg/rrr averaged over a
calendar quarter. In Ontario, Canada, lead emissions may not impart a
*3
calculated downwind concentration of more than 10 ymg/m (30 minutes)
using the Pasquill-Gifford equations. Measured downwind concentrations
may not exceed 5 yg/m3 (24-hour) and 2 yg/m3 (30-day). Montana and
2
Pennsylvania have set ambient air standards for lead at 5 pg/m (30-
day). Reportedly the most stringent standard is that of the USSR,
•3
0.7 yg/m , 24-hour average.
7.1.2 Sulfuric-Acid Mist Emissions.
Both the wet and dry formation processes generate sulfuric acid
mist. Emission data are sparse. One report indicates an emission rate
of 14 kg (30 Ib) of sulfuric acid (H2S04) mist per 1000 batteries.
Another report8 estimates an emission factor of 19 kg (42 Ib) acid mist
per 1000 batteries.
A
In wet formation, battery plates are formed in individual, preassembled
battery cases. Based on plant observations, the slow rate of charging
(one to four days), and the fact that there is usually a lid or cap on
the assembled battery, sulfuric acid mist emissions to the atmosphere
\
from wet formation are believed to be small.j
^Estimated from Reference 5 and 6 by the following method:
1975 lead .consumption 197Q em1ss1ons = 1975 lead emissions
1970 lead consumption
7-7
-------
\During dry formation, battery plates are formed prior to battery
assembly in open vats over a shorter formation cycle (16 hours) and
therefore emissions are more of a problem.) Because the release of
hydrogen bubbles in the formation process increases with time, emissions
are greater towards the end of the cycle.
EPA tests on the dry formation process at a 6000 battery per day
plant showed average uncontrolled sulfuric acid mist emissions of 66
mg/m during the last 5 hours of the formation cycle (about 1.1 kg [2.4
Ib] of sulfuric acid mist per 1000 batteries). Emissions of sulfuric
acid mist can generally be controlled 95 to 99 percent by use of fiber
mist eliminators.
7,1.2.1 Ambient Impact--
As with lead, the CRSTER model was used to approximate the ambient
concentrations of sulfuric-acid mist. The emission rates used as input
to the model were based on EPA test data from a dry formation process at
Plant L. Figures 7-1, 7-2, and 7-3, and Table 7-1 indicate the maximum
impacts on ambient air of emissions from uncontrolled and well controlled
sources. It was assumed that a well controlled formation facility would
be equipped with a mist eliminator that was 95 percent efficient for
sulfuric acid mist collection.
7.1.2.2 Health Effects of Sulfuric-Acid Mist Emissions--
Short-term human exposure to sulfuric-acid mist can cause temporary
and permanent damage to the lungs and bronchial tubes. Long-term exposure
can cause skin damage, infTarnation of the eyes, mouth, and stomach, and
Q 10
permanent tooth damage. *
7.1.2.3 Current Standards for Sulfuric Acid Mist--
7-8
-------
Emissions of sulfuric acid mist from formation processes are
generally unregulated. One State limits these emissions to 357 mg/ra
(0.156 gr/dscf). However, the concentrations of acid mist in exhausts
12
from wet formation rooms are generally below this level. Table 7-2
lists the allowable ambient air concentrations of sulfuric acid mist in
several jurisdictions.
TABLE 7-2. ALLOWABLE AMBIENT AIR CONCENTRATIONS
OF SULFURIC ACID MIST
Jurisdiction
Allowable concentration for-
various average times,
"
Maximum
ge
T-
hr
"24 -nr
Montana
Missouri
New York
30
10
100
7.1.3 Secondary Air Pollution Impact
All of the control alternatives described in Section 6 (see Table
6-2) would require the use of fans to drive exhaust gases through particle
collection devices. These fans would require electrical energy, and,
because relatively low concentrations of lead are emitted at lead-acid
battery plants, the amount of energy required to collect 1 pound of
pollutant would be high.
The generation of electricity results in a certain amount of air
pollution, therefore, standards of performance for the lead-acid battery
manufacturing industry would have a negative secondary air pollution
impact. This impact can be estimated using the power requirements of
*These figures do not include energy used by of lead removed by SIP control
equipment (see section 7.1.1).
7-9
-------
emission controls and the proposed standards of performance for new,
13
modified, and reconstructed electric utility steam generating units. For
each kilogram of lead collected as a result of NSPS controls (Alternate I),
approximately 23 grams of NO , 40 grams of SOp, and 3 grams of particulate
matter would be emitted at a power plant. For each kilogram of mist
collected, approximately 83 grams of N0x, 144 grams of SO,,, and 12 grams
of particulate matter would be emitted at a power plant. Thus, although
there would be a negative secondary air pollution impact associated with
the proposed standards, this impact would be small compared with the
beneficial primary impact.
7.2 WATER POLLUTION IMPACT
Assessing the impacts of the control alternatives on water pollution
requires data on uncontrolled effluent characteristics, excluding wastewater
streams from air pollution control devices. The increase in pollutant
loadings and discharge flow attributed to the application of wet collectors
can then be determined and compared with the uncontrolled levels.
7.2.1 Effluent Characteristics
A typical lead-acid battery manufacturing plant generates approximately
250 liters (66.5 gal) of wastewater per battery manufactured. This waste-
water contains approximately 2 to 4 percent sulfuric acid, by weight,
and less than 0.0025 percent lead by weight. This water can be completely
neutralized, and more than 90 percent of the lead can be removed in
wastewater treatment facilities,
7.2.2 Incremental Pollutant Loadings Due to Air Pollution
Control Systems
The acid scrubbed from exhausts from the formation process adds to
the overal] burden of wastewater treatment. Essentially all of this,
7-10
-------
however, can be neutralized to the point that, for all practical purposes,
no increase in pollution results from the formation facility controls.
Incremental lead loadings to the in-plant raw wastewater from wet
collection devices can be estimated by assuming 90 percent collection
efficiency of the wet collectors and 90 percent removal of lead in the
scrubber liquor recirculation facility. At a recirculation rate of 0.5
1/m3 (4.0 gal/1000 acf) and 5 percent recirculation tank overflow, a
total increase in hydraulic flow and the concentration can be determined
and compared with the manufacturing effluent data. Tables 7-3 and 7-3A
show these parameters for four of the control alternatives described in
Table 6-2 as applied to a 6500 bpd plant.*
7.2.3 Summary of Hater Pollution Impact
Where wet collection techniques are used to control atmospheric lead
emissions, the increase in lead discharged to municipal sewage systems
or surface waters is predicted to range from 0.43 to 4.6 percent, depending
on the control alternative selected. The increase in flow rates into a
waste treatment system is anticipated to range from 1.1 to 2.4 percent.
Where fabric filtration is used to control lead emissions, there will be
no impact on water emissions. Therefore, it is concluded that control
of the airborne pollutants will have no significant impact on water
pollution.
7.3 SOLID WASTE IMPACT
7.3.1 Sources of Waste Materials
Tables 7-4 and 7-4A show the sources, quantities, and disposition
of waste materials based on production of 1000 batteries. All solid
*Control alternative I does not incorporate wet control devices and
therefore does not contribute to water pollution.
7-11
-------
Table 7-3. LEAD CONTENT OF SCRUBBER BLOWDOWN AND EFFECT ON WASTEWATER
SYSTEM OF A 6500-BPD PLANT (METRIC UNITS)
Control
Alternative3
II
III
IV
V
Scrubber
controlled
exhaust
453
708
977
977
effluent .
lead content,
kg /day
3.24
4.43
34.2
34,2
Scrubber blowdown
Quantity,0
1pm
12
19
26
26
Lead
concentration ,
rag/liter
18.5
16,3
90.9
90.9
Lead
content,
kg/yr .
80
110
854
854
Increase
in total
plant effluent, %
Plow£
1.1
1.7
2.4
2.4
Lead9
0.43
0.60
4.6
4.*
" See Table 6-2.
Assuming 90% collection efficiency.
c ' 3
Assuming 540 1/m recirculation rate and 5% overflow or blowdown.
Directly from recirculation tank prior to final treatment.
e Assuming 90% efficient wet collector and 90% lead removal in recirculation tank.
Based on 240 m"* wastewater/1000 batteries (63,500 gal wastewater/1000 batteries).
g Based on 11.3 kg lead/1000 batteries (25 Ib lead/1000 batteries).
-------
Table 7-3A. LEAD CONTENT OF SCRUBBER SLOWDOWN AND EFFECTS ON
WASTEWATER SYSTEM OF A 6500-BPD PLANT (ENGLISH UNITS)
I
u>
Control
Alternative
II
III
IV
V
Scrubber
controlled
exhaust, acfm
16,000
25,000
34,500
34,500
effluent .
lead content.
Ib/day
7.14
9.77
75.3
75.3
Scrubber slowdown
Quantity,0
gpm
3.2
5.0
6.9
6.9
Lead .
concentration ,
mg/1
18.5
16.3
90.9
90.9
Lead
content,
TPY
0.089
0.122
0.941
0.941
Increase
in total
plant effluent, %
£
Flow
1.1
1.7
2.4
2.4
Lead9
0.43
0.60
4.6
4.6
See Table 6-2 for a description of each Control Alternative; Control Alternative I is
not shown since it utilizes only dry control devices and does not add to the plant's
hydraulic flow.
Assuming 90% collection efficiency.
Assuming 4.0 gal./acf recirculation rate and 5% overflow or blowdown.
Directly from recirculation tank prior to final treatment.
e Assuming 90% efficient wet collector and 90% lead removal in recirculation tank.
Based on 63,500 gal. wastewater/1000 batteries.
9 Based on 25 Ib lead/1000 batteries.
-------
Table 7-4. SOURCES, QUANTITIES, AND DISPOSITION
OF WASTE MATERIALS (METRIC UNITS)16
Type of waste
Dusts, dross, and
rejected materials
Lead and lead
oxide paste
Lead and lead
oxide in rise
waters
Rejected plates
Rejected assembled
elements
Raw wastewater
solutions
Sludges
Air contaminants
Source
Grid
manufacturing
Paste
preparation
Pasting area
Plate curing
Three-process
Pasting area
formation
battery
rinsing
Wastewater
treatment
Total plant
Quantity
Kg/1000 batteries
544 kg Pb
36 kg Pb/PbO
90 kg Pb/PbO in
1% solution
180 kg PbO
362 kg Pb
180 kg PbO
362 kq Pb
190 m3
2-4% H2SO4
6-11 kg Pb
Caustic neutral-
ization - 10 kg
Lime neutralization
- 13.4 Mg
0.4-2 kg Pb/PbO
Disposition
Reclaim
Reclaim
Wastewater
treatment
Reclaim
Reclaim
Wastewater
•treatment
Landfill
Reclaim
7-14
-------
Table 7-4A. I SOURCES, QUANTITIES, AND DISPOSITION
OF WASTE MATERIALS (ENGLISH UNITS)16
Type of waste
Dusts, dross, and
rejected materials
Lead and lead
. oxide paste
Lead and lead
oxide in rinse
waters
Rejected plates
Rejected assembled
elements
. Raw wastewater
solutions
Sludges
Air contaminants
Source
Grid
manufacturing
Paste
preparation
Pasting area
Plate curing
Three-process
Pasting area
formation
battery
rinsing
Wastewater
treatment
Total plant
Quantity
lb/1000 batteries
1200 Ib Pb
SO Ib Pb/PbO in
200 Ib Pb/PbO in
It solution
400 Ib PbO
800 Ib Pb
400 Ib PbO
800 Ib Pb
50,000 gallons
2-4% H2SO4
13-25 Ib Pb
Caustic neutral-
ization - 22 Ib
Lime neutral-
ization 29,400 Ib
1-5 Ib Pb/PbO
Disposition
Reclaim
Reclaim
Wastewater
treatment
Reclaim
Reclaim
Wastewater
treatment
Landfill
Reclaim
7-15
-------
wastes excluding wastewater treatment sludges are recycled directly to
the manufacturing facilities, reclaimed in the plant, or shipped to a
smelter.
Wastewater streams containing lead and sulfuric acid are treated fay
caustic or lime neutralization facilities. Lime treatment produces very
large quantities of sludge, whereas caustic neutralization generates
little solid waste. Caustic treatment is more costly than lime neutralization.
7.3.2 Waste Characterization
This discussion concerns only the waste generated by manufacturing
processes and does not consider nonprocess waste generated in the form
of rubbish.
7.3.2.1 Lead Items--
Defective lead parts such as grids, posts, and connectors are
returned to the grid-casting lead pots or the small-parts lead pot.
Plates are either sent to a smelter or separated by a tumbler into paste
and grids. In the latter case, the paste is frequently used as an
ingredient in the paste mixer and the grids are remelted in the reclamation
furnace.
7.3.2.2 Separators--
Rejected separators may be used as spacers or shims in blocking the
element in the container. Generally, separators that have become saturated
with sulfuric acid must be discarded. This disposal accounts for very
little solid waste, however.
7.3.2.3 Containers and Covers—
The current trend is toward polypropylene containers and covers,
although some manufacturers still use rubber. Defective containers must
be discarded. Polypropylene containers can be used as fuel in lead
7-16
-------
blast furnaces and therefore are often sent to a smelter. Some plants
send cases to the manufacturer for recycling. In short, defective
polypropylene cases do not enter the solid waste stream.
Rubber containers can break rather easily if dropped. Broken
containers must be discarded, since they are not useful as fuel nor can
they be recycled. Defective covers usually contain lead bushings, which
are separated from the covers and sent to a smelter. Scrapped rubber
containers and covers are treated as rubbish and are generally landfilled.
7.3.2.4 Finished Batteries-
Batteries that are found to be defective when they are partially or
fully assembled are sent to a smelter for recycling. They do not enter
the solid waste stream at the battery manufacturing facility.
7.3.2.5 Paste-
Positive paste that becomes contaminated must be discarded or used
as an ingredient for negative paste. If the paste becomes hard or
lumpy, it cannot be softened and must be discarded. This paste is sent
to a smelter for refining.
7.3.2.6 Sulfuric Acid—
If sulfuric acid is discharged from a plant and is neutralized with
lime, solid waste is generated at the effluent treatment facility.
Well-managed operations seldom discard sulfuric acid. The acid dumped
from wet charged batteries after the formation process is used in place
of water to make acid of higher specific gravity, which is used for the
final fill of the batteries. Thus the "used" acid is actually shipped
out in the wet batteries.
7.3.2.7 Sludge--
Virtually all the process-related solid waste results from the
treatment of battery plant effluent, which results from acid leakage and
7-17
-------
spillage, washing and rinsing of dry battery elements, and housekeeping
(hosing the floors). A typical plant generates approximately 250 liters
I Q
(66.4 gallons) of wastewater per battery produced. This effluent is
neutralized by treatment with lime or caustic soda. The former produces
large amounts of sludge, approximately 13 Mg (15 tons) per 1000 batteries
manufactured. Caustic soda treatment produces less than 11.3 kg (25 Ib)
of sludge per 1000 batteries manufactured. Regardless of the neutralization
method, the sludge contains approximately 2.5 kg (5.6 Ib) Pb(OH)2 and
5.3 kg (11.7 Ib) PBSO^ per 1000 batteries manufactured. Table 7-5
summarizes the process solid wastes generated at various-sized lead-acid
battery manufacturing facilities.
TABLE 7-5. ESTIMATED DAILY PROCESS SOLID WASTES
GENERATED AT LEAD-ACID BATTERY MANUFACTURING FACILITIES
Type of waste
P
500
Sludge (lime treatment), 6.5 (7.5)
Mg (tons)
Sludge (caustic soda 5.5 (12)
treatment), kg (Ib)
Pb(OH)2, kg (Ib)
PbS04, kg (Ib)
7.3.3 Incremental
1.3 (2.8)
2.6 (5.8)
Solid Waste Impact
lant size, bpd
2000 6500
26 (30) 84.5 (97.5)
22 (48) 73 (160)
5.0 (11.2) 16.5 (36.4)
10.6 (23.4) 34.5 (76.1)
The increase in solid waste production due to increase emissions
control will be slight. The largest increase is in sludge generated by
lime treatment of the blowdown from the formation facility control
system. Smaller increases are due to collection of air pollutants at
7-18
-------
the power plant that generates electricity to power the battery plant's
control devices.
The amount of sludge produced at the lime wastewater treatment
facility is proportional to the amount of sulfuric acid neutralized.
Most plants can reuse the acid collected by mist eliminators used to
control emissions from the formation process. If the acid mist is
diluted or contaminated, however, it must be discharged through the
waste treatment system. An addition of 94 kg/day (208 Ib/day) of acid
mist from a wet collector controlling the formation operation at a 6500
bpd plant will produce an additional 14.5 kg (32 Ib) of sludge per day.
Therefore, the increase in solid waste expected from waste treatment
sludge is only 0.15 percent.
Wastewater streams from other air pollution control devices will
not increase the volume or change the composition of the sludge. Also,
sludge production will be insignificant at a 6500 bpd plant that uses
caustic to treat effluents from the formation process.
The solid wastes from dry collection of lead air pollutants are
sent to in-plant or outside reclamation furnaces or smelters for lead
recovery. These wastes are collected at the rate of 13.4 to 25 kg (29.6
to 54,8 Ib) of lead per 1000 batteries produced, depending upon the
control alternative applied.
Additional solid wastes resulting from generation of electricity
for the control systems can be as much as 9.1 Hg (10 tons) per year for
a coal-burning plant with sulfur oxides controls.
Table 7-6 summarizes the maximum solid waste impacts due to the
NSPS. These figures are based on a battery plant using control alternative
7-19
-------
I (see Table 6-2) and served by a coal-fired utility. The data indicate
that solid waste production will not increase by more than 0.5 percent.
TABLE 7-6. POTENTIAL SOLID WASTE IMPACTS OF A BATTERY
PLANT USING CONTROL ALTERNATIVE I
Quantity
Mg/yr per 1000 bpd
(TPY/1000 bpd) capacity
Source
Uncontrolled
Increase
with controls
Disposition
Waste treatment
(lime)
Air pollution
3360 (3700)
0
5.0 (5.5)
6.3 (6.9)
landfill
recovery
control (fabric
filter)
Power plant
4.5 (5.0)
landfill
Total
3360 (3700) 15.8 (17.4)
7.4 ENERGY IMPACTS
i
Any of the alternative control systems installed to comply with a
new source performance standard will require electricity. The major
portion of the electrical energy is needed to operate the fans installed
to overcome the pressure drop across the control systems. Lesser amounts
of electrical energy are needed for motors that operate the pumps in
scrubber control devices and the shaking mechanisms in fabric filters.
The additional fan energy requirements for the control systems described
in Chapter 6.0 are reitterated (from section 7.1.3) below:
Plant Size
(bpd)
100
250
500
2000
6500
Power Requirements (MVlhr/yr)
Lead Controls Acid Mist Controls
17
17
28
80
252
7.5
7.5
9.6
40
129
7-20
-------
These requirements are based on pressure-drops of 1245 kPa (5 in. W.S.)
for lead emission control equipment, and 620 kPa (2.5 in. W.S.) fors
reclaimation emission controls are not included since existing state
regulations (SIP's) require control of these emissions. Also, energy
requirements to overcome duct pressure drops are not included, since
ducting to ventialte process exhausts is required to meet OSHA standards.
Finally, the above figures do not include energy requirements of lead
oxide manufacture emission controls, because such controls are required
for product recovery.
Tables 7-7 and 7-7A compare the eneagy requirements (in terms of
cal's and Btu's respectively) for 100, 250, 500, 2000, 6500 bpd plants
for the four following entities: process; exhaust; SIP control; NSPS lead
control; and NSPS acid mist control. Process energy demands are based
on reported total plant energy requirements of various sized battery
plants less estimated energy requirements for exhaust, SIP control, and
NSPS control. Exhaust energy demands were estimated using typical
exhaust rates and assuming an average 620 kPa (2.5 in. W.G.) ductwork
pressure drop for all process exhaust streams. Energy demands for SIP
control are based on a 1245 kPa (5 in. W.G.) pressure drop. Energy require-
ments for product recovery equipment for lead oxide manufacturing processes
are considered process energy. Finally, all demands for electrical energy
(fan requirements) are expressed in terms of the amount of thermal energy
required to generate the needed electricity (assuming a power plant
efficiency of 34 percent).
Projections for 1985 lead-acid battery industry-wide energy usage were
made by assuming that energy demands will increase at the same rate as
7-21
-------
TABLE 7-7. ENERGY REQUIREMENTS FOR LEAD ACID BATTERY MANUFACTURING
PLANTS AND EMISSION CONTROL EQUIPMENT (METRIC UNITS)
Manufacturing
processes
ro
PO
Plant
size, bpd
100
250
500
2000
6100
Gcal/yr
1,680
4,200
8,400
13.200
27,900
Equivalent
oil,
kl/yr
167
416
833
1,310
2,780
Process and plant
exhaust
Gcal/y>"
45.2
45,2
63.4
193
584
Equivalent
oil,
kl/yr
4,55
4,55
6.36
19.1
58.3
SIP controls
Gcal/yr
4.1
4.1
33.0
81.2
198
NSPS Lead controls3
Equivalent
oil,
kl/yr Gcal/yr
0.41
0.41
3.29
7.95
19.6
43
43
69.9
203
638
Equivalent
on.
kl/yr
4.73
4.73
7.10
20.1
32.3
NSPS Acid
fical/yr
19,0
19.0
24.0
101
326
M1st controls
Equivalent
oil,
kl/yr
2,09
2.09
2.44
10.1
32.3
Excludes energy required for SIP controls.
-------
TABLE 7-7A. ENERGY REQUIREMENTS FOR LEAD ACID BATTERY MANUFACTURING
PLANTS AND EMISSION CONTROL EQUIPMENT (ENGLISH UNITS)
ro
LO
Manufacturing
processes
Plant
size, bpd
100
250
500
2000
6500
109 Btu/yr
6.6
16.5
33
52
no
Equivalent
oil,
1000 ga/yr
180
190
220
.347
734
Process ana plant
exhaust
109 Btu/yr
0.18
0.18
0.25
0.76
2.30
Equivalent
on,
1000 ga1/yr
1,20
1.20
1.18
5.04
15.4
SIP controls
1Q9 Btu/yr
0.02
0.02
0.13
0.3E
0.78
Equivalent
oil,
1000 gal/yr
0.11
0.11
0.87
2.10
5.18
NSPS Lead controls8
109 Btu/yr
0.18
0.18
0.24
0.80
2.5
Equivalent
oil,
1000 gal/yr
1.25
1.25
1.66*
5.32
16.7
NSPS Acid Mist controls
109 Btu/yr
0.08
0.08
0.13
0.40
1.3
Equivalent
oil,
1000 gal/yr
0.55
0.55
0.86
2,66
8.53
Excludes energy required for SIP controls.
-------
industry manufacturing capacity (i.e., 40 percent from 1975 to 1985).
This would mean that the 1975 estimated industry energy requirements 1.2
Pcal/yr (4.8 trillion Btu/yr) or 0.21 Tg or coal or 0.12 Gl of residual
oil (0.23 million tons of coal or 0.76 million barrels of residual oil)
will increase to 1.7 Pcal/yr (6.7 trillion Btu/yr) by 1985. Energy which
would be required to meet New Source Performance Standards represents about
3.2 percent of this figure, or 52 Tcal/yr (210 million Btu/yr). Approximately
35 Tcal/yr (140 million Btu/yr would be needed to control lead emissions
while 17 Tcal/yr (70 million Btu/yr) would be needed to control acid mist
emissions. Note that each control alternative has the same energy
demand and the various control alternatives do not effect makeup air.
The NSPS energy requirements are in addition to energy demands for the
process exhaust and SIP control.
7.5 OTHER ENVIRONMENTAL IMPACTS
Application of a control system could cause no significant increase
in noise, heat, or static electrical energy. None of the eight plants
visited in this study reported problems regarding these environmental
hazards.
7.6 OTHER ENVIRONMENTAL CONCERNS
7.6.1 Irreversibleand Irretrievable Commitment of Resources
Increased emission control of the battery industry would result in
a trade off of environmental gains at the expense of energy losses. All
the control devices required to bring battery manufacturing facilities
into compliance with increased emissions control requirements must be
powered by electrical energy. These power requirements result in an
irretrievable commitment of coal, oil, natural gas, or nuclear fuel as
7-24
-------
an energy source for power plants. Section 7,4 discusses the energy
penalties associated with lead-acid battery plant control strategies^
7.6.2 Environmenta? Impact of Delayed Standards
Delay in setting of standards will allow the construction of new
battery facilities without controls. Manufacturers may, however, in
anticipation of SIP regulations for lead, install control equipment on
both new and existing facilities.
At present, most state regulations do not specifically regulate
lead-acid battery facilities. A few states have standards regulating
lead-bearing particulates from secondary nonferrous operations. Other
states have ambient air standards for sulfuric acid, and one state
20
specifically limits emissions of sulfuric acid from the stack.
Concentrations of sulfuric acid in formation exhausts are too low to
require controls under the regulations of that state.
A delay of one year in the adoption of the NSPS will result in the
nationwide emission of approximately 4 Mg (4.4 tons) of lead over and
above that permitted by anticipated SIP regulations.
A delay in promulgation of a New Source Performance Standard for
sulfuric acid mist may cause only a slight increase in uncontrolled acid
mist emissions, since many new installations tend to control exhausts from
dry formation processes.
7,6.3 Environmental Imp_act of No Standard
As mentioned earlier, most states do not now regulate emissions of
lead or sulfuric acid from lead-acid battery manufacturing facilities.
In the absence of SIP regulations, "no standard" would cause lead and
sulfuric acid mist emissions from these plants to increase as lead-acid
7-25
-------
battery production increases. Also, the increased process venting
requirements, due to the recently established OSHA lead-in-air standard
of 50ug/m3, may increase lead emissions to the atmosphere. However,
with the promulgation of a lead ambient air quality standard, the increase
in lead emissions would be less severe.
7-26
-------
REFERENCES FOR CHAPTER 7
1. Turner, D.B. Workbook of Atmospheric Dispersion Estimates.
Cincinnati, Ohio. U.S. Health, Education, and Welfare, Public
Health Service. Revised 1970. p.- 38.
2. Buckely, J. (Chairman). EPA's Position on Health Implication of
Airborne Lead. U.S. Environmental Protection Agency. Washington,
D.C. November 1973. p. VIII-1 - VIII-8.
3. Air Quality Criteria for Lead. U.S. Environmental Protection
Agency. Publication No. EPA-600/8-77-017. December, 1977.
4. Annual Review, 1975, U.S. Lead Industry. Lead Industries Association,
Inc. New York City. April 1976. p. 6.
5. Ibid. p. i.
6. Compilation of Air Pollutant Emission Factors. U.S. Environmental
Protection Agency. Research Triangle Park, North Carolina.
Publication No. AP-42. April 1973. p. A-2.
7. Thakker, B. Screening Study to Develop Background Information and
Determine the Significance of Emissions from Lead Battery Manufacture.
Vulcan-Cincinnati, Inc. Prepared for the U.S. Environmental Protection
Agency under Contract No. 68-02-0299, Task No. 3. December 1972.
p. 16.
8. Boyle, T.F., and R.B. Reznik. Lead-Acid Batteries, Source Assessment
Document No. 17. Prepared by Monsanto Research Corporation, Dayton,
Ohio, for the U.S. Environmental Protection Agency. Cincinnati,
Ohio. Contract No. 68-02-1874. June 1976 (Draft), p. 42.
9. Air Quality Criteria for Sulfur Oxides. National Air Pollution
Control Administration. Washington, D.C. Publication No. AP50.
April 1970.
10. Documentation of the Threshold Limit Values for Substances in
Workroom Air. Cincinnati, Ohio, American Conference of Governmental
Hygienists, 1971. pp. 239-240.
11. New Jersey Administrative Code, Title 7, Chapter 27 - Subchapter 7.
New Jersey State Department of Environmental Protection. November
21, 1966. p. 3.
7-27
-------
12. Private Communication Between Donald Henz of PEDCo Environmental,
Inc., Cincinnati, Ohio, and Allen Edwards, New Jersey Air Pollution
Control Agency, Central Field Office. April 27, 1976.
13. Federal Register, Vol. 43, No. 182. Tuesday, September 19, 1978.
p. 42154.
14. Assessment of Industrial Hazardous Waste Practices, Storage and
Primary Batteries Industries, VERSAR, Inc. Springfield, Virginia.
Prepared for U.S. Environmental Protection Agency under Contract
No. EPA 68-01-2276. September 1974. p. 132.
15. Ibid.
16. Ibid. p. 131.
17. Ibid. pp. 88-89.
18. Ibid. p. 132.
19. Ibid.
20. Op cit. Reference 12. p. 3.
7-28
-------
8.0 ECONOMIC IMPACTS
8.1 INDUSTRY ECONOMIC PROFILE
8.1.1 Introduction
The lead-acid storage battery industry is the largest
single consumer of lead in the United States. In 1977, the
industry accounted for approximately 945,000 short tons of
lead, which is 59.7 percent of the total 1,582,000 short tons
of lead consumed domestically.1 Total U.S. lead supplies
in 1977 originated from imports (14.4%), secondary production
(44.7%), refinery production (32.8%) and inventory (8.0%).2
Traditionally, lead-acid batteries account for;
90 percent of total storage battery sales. Because of the
flourishing activity in the U.S., some foreign concerns are
attempting to penetrate the market. Britain's Chloride group
and France's SAFT have purchased a few small U.S. battery
makers, and Germany's leading battery producer, Varta AG,
is moving into Canada and looking toward entrance into the
U.S. market.
8.1.2 Number, Size of Plants and RegionalDistribution
The industry in this country is dominated by six com-
panies. Table 8.2 indicates that these six manufacturers hold
over 70 percent of the market, the top four accounting for 60
percent of industry sales.3'4
There are approximately 190 lead-acid battery plants in
8-1
-------
Table 8.1
CONSUMPTION OB' LEAD IN THE UNITED STATES
BY PRODUCT^
(in thousand short tons)
1977
Metal Products
Ammunition
Brass and Bronze
Cable Covering
Sheet Lead
Solder
Storage Battery Grids, etc.
Storage Battery Oxide
Other
Amount
68.3
16.7
15,
16,
64,
459,
486,
59.1
Percentage
4.3%
1.1
1.0
1.1
4.1
29.0
30.8
3.7
Pigment s
White Lead
Red Lead and Litharge
Pigment Colors
Other
6.6
78.0
14.7
.6
.4
4.9
.9
.04
Chemicals
Gasoline Antiknock Additives
Miscellaneous Chemicals
232.9
.1
14.7
Miscellaneous uses
Annealing
Galvanizing
Lead-plating
Weights and Ballast
Other Uses Unclassified
2.7
1.4
.5
19.1
39.5
.2
.09
.03
1.2
2.5
Total
1,582.1
100.0*
*Does not add to 100 because -of rounding.
8-2
-------
Table 8.2
LEADING DOMESTIC STORAGE BATTERY MANUFACTURERS3
Estimated
Share of
1974 sales U.S. Market
Parent Co./Address Branch Plant Location million, $
ESB, Inc.
Philadelphia, Pa.
General Motors Corp,
Delco-Remy Div.
Detroit, Mich.
Gould, Inc.
Chicago, 111.
Los Angeles, Calif.
Milipitas, Calif.
Woodland, Calif.
Denver, Colo.
Fairfield, Conn.
Atlanta, Ga.
Warsaw, 111.
Logansport, Ind.
Burlington, Iowa
Minneapolis, Minn.
Kansas City, Mo.
Omaha, Neb.
Buffalo, N.¥.
Cheektowaga, N.Y.
Raleigh, N.C.
(2 plants)
Allentown, Pa.
Philadelphia, Pa.
Sumter, S.C.
Memphis, Tenn.
Dallas, Tex.
Racine, Wise. •
Anaheim, Calif.
Muncie, Ind.
Olathe, Kan.
New Brunswick, N.J,
Fitzgerald, Ga.
City of Industry,
Orlando, Fla.
Kankakee, 111.
Leavenworth, Kan.
Howell, Mo.
St. Paul, Minn.
(3 locations)
Trenton, N.J.
Zanesville, Ohio
Salem, Ore.
Memphis, Tenn.
Dallas, Tex.
Lynchburg, Va.
241.3
21.0
204.6
17.8
Cal
151.1
13.1
8-3
-------
Table 8.2 Continued
Estimated
1974 sales
Share of
U.S. Market
Parent Co./Address Branch Plant Location million, $
Globe-Union, Inc.
Milwaukee, Wise.
Northwest Indus-
tries, Inc.
General Battery
Div.
Chicago, 111.
Eltra Corp.
New York, N.Y.
Fullerton, Calif.
Middletown, Del.
Tampa, Fla.
St. Joe, Mo.
Atlanta, Ga.
Geneva, 111.
Louisville, Ky.
Owosso, Mo.
Oregon City, Ore.
Candy, Ore.
Garland, Tex.
N. Bennington, Vt.
Selma, Ala.
Stratford, Conn.
Salina, Kansas
Frankfort, Ind.
Portland, Ore,
Reading, Pa.
Toledo, Ohio
Greer, S.C.
Dallas, Tex.
Hamburg, Pa.
Laureldale, Pa.
Attica, Ind.
Brookston, Ind.
Vincennes, Ind.
Oklahoma City, Okla
Reading, Pa.
Laureldale, Pa.
Temple, Pa.
East Point, Ga.
Manchester, Iowa
1,
82.0
7.4
78.5
6.8
62.1
5.4
8-4
-------
the U.S., of which about 91 have been estimated to be small
plants* (less than 500 bpd).5 These 190 plants are scattered
throughout the country and are generally located in highly
urbanized areas near the market for their batteries. Figure
8-1 shows the regional distribution of these 190 plants.
Of the approximately 91 small plants, 31 are classified
as assemblers. As will be considered in section 8.4.4, assem-
blers purchase all of the materials and parts that are required
for a battery and assemble these parts into a finished battery.
They generally perform all of the functions of the small manu-
facturer except grid casting and pasting. The impact of the
sulfuric acid mist control and lead NSPS control cost on these
small manufacturers and assemblers will be shown in section
8.4.4.
Small manufacturers and assemblers are generally one-
plant operations, though some manufacturers and assemblers may
have warehouse space in locations other than their plant. There-
fore, for the 91 small plants there are approximately 91 firms.
Direct delivery to client accounts is generally the rule as
this is a most profitable distribution pattern for the plants.
As was seen in section 3.5, battery manufacturing can
be distinguished by the formation process - wet or dry forma-
tion. No information is available on the number of plants
forming wet versus dry or a combination of wet/dry. The
*Excluding small plants of the larger multiplant companies,
8-5
-------
Figure 8-1
REGIONAL DISTRIBUTIC)N_OF_J.;EAD-R£IP^Bft'rTERY PLANTS
EPA REGIONS
rNj^wJcToi
BASE WAP COPYRIGHT
J.L. SMITH CO.,
Region II - includes Puerto Rico and Virgin Island
Region IX - includes Hawaii
Region X - includes Alaska
-------
large plants proba51y have dry formation capability if they
are selling to retail markets, since dry forming increases the
shelf life of a battery. Small plants generally specialize
in wet formation; if any dry formation is performed, it is
usually a small portion of their total battery production.
Employment in the industry is approximately 19,000
people.6 Since a 500 BPD plant would generally employ 20-25
people and a 100 BPD plant about 5 or 6 people, small plant
employment accounts for about 1300 of the total, based on
an average of 15 people per small plant.
8.1.3 Markets
The market for lead-acid storage batteries is composed
of two segments. The first and largest segment consists of
replacement batteries for automobiles, trucks and buses, heavy
equipment, recreational vehicles, farm machinery, and other,
vehicles. The replacement market accounted for 78.8 percent of
industry sales in 1977. The second largest market, holding
21.2 percent of sales, is the original equipment market,
consisting of batteries sold to producers of new cars, new
trucks, and other new products. Table 8-3 summarizes ship-
ments to these markets for the past 10 years.
The industry as a whole has enjoyed an average growth
rate of 4.9 percent per year between 1968 and 1977. In 1974
and 1975 the economic recession caused a slowdown in sales and
production of new vehicles and therefore in battery sales.
Except for a decline in 1975, replacement battery shipments
8-7
-------
Table 8.3
BATTERY SHIPMENTS BY DOMESTIC PRODUCERS7
GO
I
Year
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
Replacement Batteries
Units,
.(thousands)
33793
35510
37863
39143
43220
43453
44408
42582
49203
54601
Share of
Market, %
75.2
76.5
80.7
77.2
77.9
76.1
81.5
82.5
78.6
78.7
Original Equipment
Units,
( thousands)
10718
10147
8239
10673
11270
12637
10058
8985
13365
14718
Share of
Market, %
23.8
21.9
17.6
21.0
20.3
22.1
18.5
17.5
21.4
21.3
Unit
(thousa
456
760
819
928
983
1017
a
a
a
a
1.0
1.6
1.7
1.8
1.8
1.8
a
a
a
a
44967
46417
46921
50708
55473
57107
54466b
51567b
62568b
69319b
aExport figures not available.
'-'Does not include exports.
-------
have increased each year of this 10-year span at an average
rate of 5.5 percent a year. Original equipment battery ship-
ments have been volatile but have increased at an average
rate of 3.6 percent per year.
According to Globe-Union, the replacement market will
continue to be strong. With more than 50 million vehicles
entering the automobile afterinarket by 1990, the number of
battery units should reach more than 285 million. Replacement
battery shipments should reach 62.5 to 63.5 million units in
1982, an increase of approximately 25 percent over the 1977
level. Table 8-4 shows a forecast for replacement battery
shipments for the years 1978 to 1982. Growth areas for the
industry lie in trucks and commercial vehicles, both for ori-
ginal equipment and replacement batteries. Another source with
potential for further market penetration lies in recreational
vehicles, such as motorcycles, snowmobiles, golf carts, and
motor boats. Globe-Union reports that this market accounted
for $50 million in sales in 1970, and estimates that by 1985
the recreational market may account for over $200 million.8
Table 8.4
REPLACEMENT BATTERY SHIPMENTS9
(In Millions)
Pejrcent Changj?
Year Number of Units From Previous Year
1978 57.3
1979 58,3 1.7%
1980 57.7 -1.1
1981 59.2 2.6
1982 63.0 6.4
8-9
-------
8.1.4 Distribution
Distribution of batteries by any plant usually takes
place in a limited geographical area. Because the weight of
lead-acid storage batteries is high relative to shipment value,
transportation cost is high and significant cost savings accrue
from geographical location adjacent to markets. It is generally
economically inefficient to ship beyond a 250 to 300 mile radius.
If a company wants national distribution of its product, plants
have to be located in regional markets. Proximity to markets
appears to be a key to the economic viability of many small
producers, whose unit manufacturing costs and F.O.B, plant
prices are significantly higher than those of larger companies.
The large producers are distributing primarily to the
large original equipment markets (OEM) such as the automobile
companies, and large retail accounts such as Sears, Roebuck, and
Co. and J.C. Penney. Warehouse distribution of their batteries to
smaller accounts is also made. Smaller firms sell primarily to
fleet accounts such as local cab companies, government and
business firms, local gas stations, discount stores, and the
like.
The marketing chain for batteries is primarily from
battery producer to warehouse to jobber to retailer, although
individual links in the chain are often bypassed. This is
particularly true of the smaller producer who is selling to
fleet accounts. Deliveries to these accounts are made in company-
\
owned trucks because it is more profitable to deliver directly.
8-10
-------
In this way the small firm can accrue the markup which would
have been applied by the intermediaries to the final buyer.
These markups vary by 20 to 65% from the warehouse price
depending on the client account.^
Competition between the large and small producer for some
client accounts exists through local warehouse distribution of
the larger company's battery to clients in the smaller produ-
cer's market. The smaller producer, however, offers additional
services such as faster delivery time, personalized service,
better credit arrangements, and pick-up of small quantities
of junk batteries from customers.
No alternative source can provide energy for a cost
comparable to that provided by the lead-acid storage battery
in its automobile application. This cost efficiency tends to
be true for other uses of SLI batteries such as golf carts and
snowmobiles. Potential substitutes, such as the nickel-cadmium,
nickel-zinc, nickel-iron, silver-zinc and silver-cadmium bat-
teries, cost from three to five times as much as lead-acid
batteries.
8.1.5 Imports
Imports and exports of storage batteries are, in general,
associated with the imports and exports of automobiles. The
high transport costs associated with storage batteries make
competitive pressure from foreign manufacturers a neglibile
factor in response to battery price movements.
8-11
-------
8.2 COST ANALYSIS OF ALTERNATIVE CONTROL SYSTEMS
The approach to determining the costs associated with the
alternative control systems involved three steps: 1) selecting
five representative model plants; 2) applying the selected
five control alternatives for lead and the sulfuric acid mist
control system as discussed in Chapter 6; and 3} determining the
total control costs based upon each strategy and typical exhaust
volumes. This three-step procedure is applied to both new and modified
plants. The results of this analysis are used in determining economic
impacts of the alternative systems in Section 8,4. (The listing of
eight control alternatives, as shown in Table 6-2, is repeated for
convenient reference as Table 8-6).
Of the approximately 200 battery manufacturing plants in
the United States, nearly 50 percent manufacture less than
500 units per day and 30 percent manufacture between 500 and
*
6500 units per day. Based on these statistics, the fol-
lowing model plant sizes were selected; small - 100, 250,
and 500 bpd; medium - 2000 bpd; and large - 6500 bpd.
Typical parameters for uncontrolled exhaust from the facili-
ties within these model plants are given in Tables 8-7 and
8-7A. These parameters were estimated from data obtained
from plant representatives, design calculations, and various
reports of source tests.
*
Based on employment data obtained from Reference 25 and
assuming output at 25 batteries per man-day.
8-12
-------
Table 8-6. SELECTED CONTROL ALTERNATIVES FOR
LEAD-ACID BATTERY MANUFACTURING INDUSTRY
Control
alternative
Facilities
Control system
II
III
IV
VI
VII
VIII
A, B, F
C, E
G
D
B, C, E
F
G
D
C, E
A, B, F
G
D
A, B, C
E
F
G
D
A, B, C, F
E
G
D
A, B, C
E
G
A, B, C, E
G
A, B, C
E
G
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1
Impingement and entraininent
scrubber
Impingement and entraininent
scrubber
Mist eliminator
Fabric filter, 2/1 A/CC
Fabric filter, 6/1 A/C
Impingement and entraininent
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Impingement and entrainment
scrubber
Fabric filter 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Impingement and entrainraent
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 6/1 A/C
Mist eliminator
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
* Facilities key: A - Grid casting furnace; B - Grid casting
machines; C - Paste mixer; D - Lead oxide manufacturing;
E - Three process operation and assembly; F - Lead reclaim
furnace? G - Formation.
All facilities are vented to common control systems as
shown.
c Small {S 500 bpd) plants are assumed to have no PbO manufac-
turing facilities.
fl-13
-------
Table 8-7". TYPICAL UNCONTROLLED EXHAUST PARAMETERS FOR BATTERY MANUFACTURING
FACILITIES3 (METRIC UNITS)
Facility
code
letter
A
B
C
D
E
F
1 >
Facility
Grid cagting
furnace"
Grid casting
machine^
Paste mixer
Lead oxide
manufacturing
Three-proces s
operation
Lead reclaim
furnace
Formation
Temperature,
"C
115
38
38
115
27
115
27
Moisture,
%
2-3
2-3
2-4
2-3
1-2
2-3
N.A.
Total particulate
loading,
tng/m^
<23
<23
137
21d
46
>229
4000e
Volume by plant size, m /min
100 bpd
27.5
27.5
62.0
c
403
f
75.3
250 bpd
27,5
27.5
62.0
c
403
f
177
500 bpd
33.7
33.7
67.9
c
472
198
347
2000 bpd
57.0
57.0
89.5
87.2
733
198
1366
6500 bpd
127
127
154
216
1517
198
4020
Based on exhaust data obtained from industry responses to EPA1a inquiries (Section 114 Letters),
design calculations and source test reports.
b
The grid casting facility consists of a furnace and a machine. Sometimes these elements are separate, as where one
furnace feeds many casting machines.
c
For purposes of this study, it is assumed that plants making only 500 bpd or less have no PbO manufacturing facilities.
d
Measured at outlet of baghouse, which is part of the process.
Test data from outlet of fan separator tested at Plant G indicated <10 ppra H2SO4 (<38.9 mg/m }; assuming control device
was 99 percent efficient, uncontrolled emission approximates 4000 mg/m3,
It is assumed for the purposes of this study that plants making <500 bpd have no lead reclaim furnace.
-------
Table 8-7A. TYPICAL UNCONTROLLED EXHAUST PARAMETERS FOR BATTERY
MANUFACTURING FACILITIES3 (ENGLISH UNITS)
Facility
code
letter
h
B
c
D
E
F
G
Facility
Grid casting
furnace*3
Grid casting
machine
Paste mixer
Lead oxide
manufacturing
Three-process
operation
Lead reclaim
furnace
Formation
Temperature,
Op
240
100
100
240
80
240
80
Moisture,
%
2-3
2-3
2-4
2-3
1-2
2-3
M.A.
Total participate
loading,
gr/dscf
<0.01
<0.01
0.06
0.009d
0.02
>0.10
1.6e
Volume by plant size.
100 bpd
970
970
2190
c
14220
f
2660
250 bpd
1050
1050
2270
c
15140
f
6260
500 bpd
1190
1190
«
2400
c
16680
7,000
12260
acfm
2000 bpd
2015
2015
3160
3080
25900
7,000
48300
6500 bpd
4470
4470
5460
7630
53600
7,000
142000
CO
I
Based on exhaust data obtained from industry responses to EPA's inquiries (Section 114 Letters),
design calculations and source test reports.
The grid casting facility consists of a furnace and a machine. Sometimes these elements are separate, as where one
furnace feeds many casting machines.
c For purposes of this study, it is assumed that plants making only 500 bpd or less have no PbO manufacturing facilities.
Measured at outlet of baghouse, which is part of the process.
e Test data from outlet of fan separator tested at Plant G indicated <10 ppm H2SO4 (<0.017 gr/dscf)j assuming control device
was 99 percent efficient, uncontrolled emission approximates 1.6 gr/dscf.
For purposes of this study, it is assumed that plants making less than 500 batteries per day have no lead reclaim furnace.
-------
Uncontrolled lead emissions based on data obtained from
tests performed in this study are shown in Table 8-8.
Typical uncontrolled emissions of lead from the grid-casting,
three-process operation, and lead oxide manufacturing
facilities are less than 0.5 kg/metric ton (1 Ib/ton) of
process weight. At a production rate of 200 batteries per
hour (approximately 3.6 Mg/hr 18,000 Ib/hrj process weight
rate) uncontrolled lead emissions from the three-process
operation would approximate 1.3 kg/hr (2.9 Ib/hr) . If it is
assumed that lead represents only 50 percent of the total
**
particulate emissions, this facility would still comply
with a typical process weight rate regulation (for particu-
late matter) as set forth in a State Implementation Plan
(SIP) because of its high process weight rate. Similarly,
the grid casting and lead oxide manufacturing facilities
would comply with this regulation.
**
Tests made during this study measured only lead. Other
contaminants such as bits of material from separators,
cork from the mold release agent, and the like must be
considered. It is estimated that the lead constitutes ]
at least SO percent of the total particulate matter.
8-16
-------
Table 8-0. UNCONTROLLED LEAD EMISSIONS FROM VARIOUS
LEAD-ACID BATTERY MANUFACTURING FACILITIES21
Facility
Emissions
Grid casting
Paste mixing
Three-process
operation
PbO manufacturing
Reclamation
0.4 kg/1000 (0.9 lb/1000) batteriesb
5.1 kg/1000 (11.2 lb/1000) batteries1
6.6 kg/1000 (14.7 lb/1000) batteries*
0.01 kg/Mg (0.02 Ib/ton) of lead
throughput
3.0 kg/Mg (5.9 Ib/ton) of lead charged
Based on data obtained from source tests performed in
this study.
For estimating purposes, each battery weighs 18 kg (40
Ib) and contains 12 kg (26 Ib) of lead, of which
approximately half is in the paste and half is in the
cast -parts.
The paste mixing and lead reclamation facilities apparently
would not comply with such a regulation, and therefore
controls would be required for these facilities even without
*
the promulgation of a New Source Performance Standard.
The possible effects of future SIP regulations for lead
are not considered in this chapter.
3-17
-------
Very few SIP's regulate sulfuric acid mist emissions
from the formation facility. New Jersey has set a limit of
10 mg/scf. A spokesman for the New Jersey Air Pollution
Control Agency states that the plant in his jurisdiction
complies with both this regulation and New Jersey's partic-
ulate matter regulation without use of a control device.
8.2.1 New Facilities
8.2.1.1 Cjap ital Cos t of Contro 1 Sy sterns - Control equipment
costs are shown in Tables 8-9 and 8-9A. All costs in this
section are based on 4th~quarter 1977 dollars. This equip-
ment represents the most efficient from a pollutant control
viewpoint and is currently used only on the best-controlled
facilities. Costs were obtained directly from vendors and
updated to 4th-quarter 1977 using the Marshall and Swift
index. 12>13
Two major categories of costs have been developed: in-
stalled capital costs and total annualized costs. The
installed capital cost for each control device system in-
cludes the purchased cost of the major and auxiliary equip-
ment, cost of site preparation and equipment installation,
and design engineering cost. Because of the short installa-
tion times required for construction of these control
systems, no construction interest charges are included. No
attempt is made to include costs of research and develop-
8-18
-------
Table 8-9 AIR POLLUTION CONTROL EQUIPMENT COSTS FOR LEAD-ACID BATTERY
MANUFACTURING FACILITIES (METRIC UNITS)
Equipment type
Impingement and
entrainment scrubber
Fabric filter, (pulse-jet
with 6/1 A/C ratio)
Fabric filter, (shaker-type
with 2/1 A/C ratio)
Fabric filter, (shaker-type
with 3/1 A/C ratio)
Mist eliminator
Sized,
m^/niin
28
425
142
1982
40
125
40
125
57
87
142
1982
Exhaust gas parameters
Temperature,
°c
27-115
27-115
27
27
115
115
115
115
27
27
27
27
Moisture ,
%
1-4
1-4
1-4
1-4
2-3
2-3
2-3
2-3
N.A.
N.A.
N.A.
N.A.
Particulate
loadings , mg/ra
46-137
46-137
46-137
46-137
114-229
114-229
114-229
114-229
3663
3663
3663
3663
Cost,3
F.O.B. site
$ 7,200
20,000
10,500
100,600
6,900
12,100
5,600
10,400
4,370b
5,000
5,600
53,300
CO
I
4th-quarter. 1977 dollars; includes cost of fans, motors, drives, pumps, pump motors, sludge
injector, walkways, and ladders as is appropriate. All costs obtained from Reference 29 except
as otherwise noted and updated to 4th-quarter 1977.
Reference 15. Costs were updated to 4th-quarter 1977.
-------
Table 8-9A. AIR POLLUTION CONTROL EQUIPMENT COSTS FOR LEAD-ACID BATTERY
MANUFACTURING FACILITIES (ENGLISH UNITS)
Equipment Type
Impingement and
entrainment scrubber
Fabric filter, (pulse-jet
with 6/1 A/C ratio)
Fabric filter, (shaker-type
with 2/1 A/C ratio)
Fabric filter, (shaker-type
with 3/1 A/C ratio)
Mist eliminator
Size, scfm
1,000
15,000
5,000
70,000
1,400
4,400
1,400
4,400
2,000
3,000
5,000
70,000
Exhaust gas parameters
Temperature ,
°F
80-240
80-240
80
80
240
240
240
240
80
80
80
80
Moisture,
%
1-4
1-4
1-4
1-4
2-3
2-3
2-3
2-3
N.A.
N.A.
N.A.
N.A.
Particulate
loading , gr/dscf
0.02-0.06
0.02-0.06
. 0.02-0.06
0.02-0.06
0.05-0.10
0.05-0.10
0.05-0.10
0.05-0.10
1.6
1.6
1.6
1.6
Cost,3
F.O.B. site
$ 7,200
20,000
10,500
100,600
6,900
12,100
5,600
10,400
4,370fc
5,000
5,600
53,300
CD
ro
O
4th-quarter. 1977 dollars; includes cost of fans, motors, drives, pumps, pump motors, sludge
injector, walkways, and ladders as is appropriate. All costs obtained from Reference 29 except
as otherwise noted and updated to 4th-quarter 1977.
Reference 15. Costs were updated to 4th-quarter 1977.
-------
ment, possible loss of production during equipment installa-
tion, or losses during start-up. ' All capital costs reflect
4th-quarter 1977 prices for equipment, installation mater-
ials, and installation labor. Tables 8-10 and 8-11 present
the various capital cost factors for installation of fabric
filters and wet collectors, respectively. These factors are
based on published information ' and engineering judgment.
Application of these factors to the equipment costs produces
the cost curves shown in Figures 8-2 and 8-3. These Figures
also show control system costs as reported by Plants Bf C,
D, E, G, and H updated to 4th-quarter 1977 by use of the
Marshall and Swift (M & S) equipment cost index.
8.2.1.2 Annualized Cost of Control Systems - The total
annualized cost consists of three categories: direct
operating cost, capital charges, and (where applicable)
credit for dust recovery. The first category accounts for
operating and maintenance costs, which include these items:
0 Utilities, including electric power and process
water
0 Operating labor
0 Maintenance and supplies
° Solid waste disposal
Since the material collected in the pollutant control
system is toxic, it is sent to a smelter for lead recovery.
The value of the recovered lead tends to offset the refining
8-21
-------
Table 8-10. COMPONENT CAPITAL COST FACTORS FOR A
FABRIC FILTER AS A FUNCTION OF EQUIPMENT COST, Q
Component
Equipment
Ductwork
Instrumentation
Electrical
Foundations
Structural
Sitework
Painting
Total direct costs
Direct costs
Material
l.OOQ
0.04Q
0.04Q
0.11Q
0.03Q
0.03Q
0.02Q
0.004Q
1.27Q
Labor
0.25Q
0.21Q
0.006Q
0.16Q
0.05Q
0.05Q
0.02Q
0.02Q
0.77Q
Component
Sng ineer ing
Contractor ' s fee
Shakedown
Spares
Freight
Taxes
Total indirect costs
Contingencies - 20%
Total capital costs
Indirect costs
Measure of costs
10% material and labor
15% material and labor
5% material and labor
1% material
3% material
3% material
of direct and indirect costs
Factor
0.204Q
0.306Q
0.102Q
0.013Q
0.038Q
0.038Q
0.696Q
0.547Q
3.28Q
8-22
-------
Table 8-11. COMPONENT CAPITAL COST FACTORS FOR A WET
COLLECTOR (SCRUBBER OR-MIST ELIMINATOR) AS A FUNCTION OF
EQUIPMENT COST, Q
Component
Equipment
Ductwork
Instrumentation
Electrical
Foundations
Structural
Sitework
Painting
Piping
Total direct costs
Direct costs
Material
l.OOQ
0.03Q
0.04Q
0.11Q
0.03Q
0.03Q
0.02Q
0.004Q
0.15Q
1.41Q
Labor
0.25Q
0.13Q
0.006Q
0.16Q
0.05Q
0.05Q
0.02Q
0.02Q
0.16Q
0.85Q
Component
Engineering
Contractor ' s fee
Shakedown
Spares
Freight
Taxes
Total indirect costs
Contingencies - 20%
Total capital costs
Indirect costs
Measure of costs
10% material and labor
15% material and labor
5% material and labor
1% material
3% material
3% material
•
- •
of direct and indirect costs.
i
Factor
0.226Q
0.339Q
0.113Q
0.014Q
0.042Q
0.042Q
0.776Q
0.607'Q
3.64Q
-------
500
300
DC
-------
500
2 300
8
200
100
50
8
£
ae
NOTES:
1. A' REPRESENTS OAIA POINT FOR
TYPE N ROTOCLONE
2.
3.
M- REPRESNETS DATA POINT FOR
MIST ELIMINATOR OR FAN
SEPARATOR
LETTER INSIDE SYMBOL IDENTIFIES
REPORTING PLANT.
FORHATION FACILITY
LOW ENERGY SCRUBBER
4. PLANT REPORTED COSTS WERE
UPDATED TO 4th-QUARTER 1977
BASED ON M 8 S INDEX.
5. TO CONVERT EXHAUST GAS
VOLUME TO METRIC UNITS:
CF X 0.0283 - m3
-IOH ENERGY SCRUBBER
10
EXHAUST GAS, 1000 acfm
30
50
100
Figure 8-3. Reported installed costs of wet scrubber
systems compared with estimated cost curves used in
this study (4th-quarter 1977 dollars).
8-25
-------
costs. Generally, no solid waste disposal costs due to air
pollution control are incurred in the lead-acid battery
industry. The industry therefore receives no dust recovery
*•*. 17>^
credit.
Capital charges account for depreciation, interest,
administrative overhead, property taxes, and insurance.
Depreciation and interest are computed by use of a capital
recovery factor (CRP), the value of which depends on the
operating life of the device and on the interest rate. (An
operating life of 15 years and an annual interest rate of 10
percent are assumed). Insurance cost is fixed at an addi-
tional 0.3 percent of the installed capital cost per year.
Because most states have liberalized their tax laws regard-
ing air pollution control equipment, the cost of taxes is
considered to be negligible. The values used for overhead
are shown in Table 8-12 and the various items and unit
values used in computing total annualized costs are listed
in Table 8-13.
Annualized costs of operation of control devices on all
facilities except formation and lead oxide manufacturing are
a function of the number of operating shifts per day. For
purposes of this study, the following are designated: three
shifts for a large plant, two shifts for a medium plant, and
one shift for the small plants. The formation facility nor-
8-26
-------
Table 8-12. ITEMS USED IN COMPUTING TOTAL ANNUALIZED COSTS
Item
Unit value
Operating factor
Operating labor
Utilities
Electric power
Process water
Solid waste disposal
Dust recovery credit
Capital recovery factor1
2000 hours/year/operating
shift
$5/man~hour
$0.03/kWh
$0.0625/m3 ($0.25/thous. gal)
0
0
13.2% of installed capital
cost
For all air pollution control equipment; 15 year
life, 10 percent interest assumed.
8-27
-------
Table 8-13. CALCULATION OF ANNUALIZED COSTS
OF AIR POLLUTION CONTROL SYSTEMS
Cost component
Method of calculation
oo
I
ro
CO
pirect__op_erating costs
Utilities
Water
Electricity
Operating labor
Direct
Supervision
Maintenance and supplies
Labor and material
Supplies
Cagital charges^
Overhead
Plant
Payroll
Fixed costs
Capital Recovery
Insurance
Amount used per year x $0.0625/m ($0.25/1000 gal)
Amount used per year x $0.03/kwh
Number of manhours per year x $5.00
15% of direct labor
6% of total capital costs
15% of labor and material
50% of operating labor plus 50% of maintenance
and supplies
20% of operating labor
13.2% of total capital costs
0.3% of total capital costs
-------
mally operates 16 to 24 hours per day, regardless of plant
size. For estimating purposes, it is assumed that this
facility operates three shifts per day. Table 8-12 illus-
trates how annualized costs are computed for air pollution
control systems used in the lead-acid battery manufacturing
industry. Since all the dust or sludge collected in the
control systems is sold to a lead smelter for a low price,
the solid waste disposal cost and dust recovery credit are a
tradeoff. The utilities and labor factors used in cal-
culating the annualized costs are shown in Tables 8-14 and
8-14A. Smelters generally take waste only from customers
and would refuse lead waste from noncustomers even if it
IQ
were delxvered to the smelter at no cost.
8.2.1.3 Cost of Alternative. Control Measures - Each of the
ten model plants (five new, five retrofit) consists of from
five to seven separate facilities (see Tables 3-7 and 8-7A).
These facilities can each be controlled separately. In
practice, these facilities are often controlled by common
systems. Of the five selected alternative control systems
for control of lead emissions from the larger plants, system
I corresponds to best control technology for emission reduc-
tion considered? the other systems are presented for analy-
sis of the cost aspects of various other levels of control.
Control alternatives VI and VII represent the best control
8-2Q
-------
I
CO
I
UJ
o
Table 8-14. UTILITIES AND LABOR REQUIRED FOR OPERATION OF VARIOUS
CONTROL DEVICES FOP. LEAD-ACID BATTERY MANUFACTURING FACILITIES (Metric Units)
Control
Fabric filter, 6/1 A/C
Fabric filter, 2/1 A/C
Mist eliminator
impingement and entrain-
ment scrubber
Pressure drop
across device,
Pa
1245
ob
249
1245
Electric power
requirements , ,
kWh/hr/iOOO m
20
ob
4. 2
20
Water
usage
raVlOOO m3
0
0
67
134
Operating
factor,
hr/yr
2000-6000a
Qb
6000
200Q-6000a
Direct
labor,
hr/yr
200-600a
Ob
600
200-600a
Depends on number of shifts/day device is operating; it is assumed that a small plant operates
one shift; a medium plant, two shifts; a large plant, three shifts.
This device is only used on the PbO manufacturing facility, which requires a fabric filter as
part of the process. For estimating purposes, it is assumed that there is no significant
difference between the utilities and labor required for the two systems.
-------
CO
Table 3-14A. , UTILITIES AND LABOR REQUIRED FOR OPERATION OF VARIOUS
CONTROL DEVICES FOR LEAD-ACID BATTERY MANUFACTURING FACILITIES (English Units)
Control
device
Fabric filter, 6/1 A/C
Fabric filter, 2/1 A/C
Mist eliminator
Impingement and entrain-
ment scrubber
Pressure drop
across device,
in. W.G,
5
Ob
1
5
Electric power
requirements ,
kWh/hr/1000
scfm
0.59
Ob
0,118
0.59
Water
usage
gal/1000
scfm
0
0
0.5
1.0
Operating
factor,
hr/yr
2000-60003
Ob
6000
20QO-6000a
Direct
labor,
hr/yr
200-600a
Ob
600
200-6GQ3
Depends on number of shifts/day device is operating; it is assumed that a small plant
operates one shift; a medium plant, two shifts; a large plant, three shifts.
This device is only used on the PbO manufacturing facility, which requires a fabric
filter as part of the process. For estimating purposes, it is assumed that there is
no significant difference between the utilities and labor required for the two systems.
-------
technology for smaller plants. They differ only in con-
figuration. The three alternatives, (VI, VII, and VIII) are
considered for the cost aspects.
The control systems for which costs have been estimated
are fabric filters, impingement and entrairiment scrubbers,
and mist eliminators, all of which are technically capable
of achieving the various emission reductions. Each system
includes all auxiliary equipment such as fans, motors,
drives, pumps, sludge ejectors, walkways, and ladders, as is
appropriate. It is necessary to provide insulation and
auxiliary heating for fabric filters to which mixer gases
are exhausted. However, this requirement depends on the
geographic location of the baghouse, the exhaust gas1 dew
point, and the concentration of acid mist and water vapor.
Those control alternatives in which the mixer gases are
vented to a baghouse also vent the three process operation
to the same device. This dilutes the mixer exhaust from a
6500 BPD plant by a 6 to 1 factor. In warm climates con-
densation may be controlled by installing the baghouse
inside the building. The annualized cost of this precaution
would be $700, $1100, and $2400 for a 500 BPD, 2000 BPD, and
6500 BPD plants respectively, based on an annual space cost
of $3.50 per square foot. For purposes of this report, the
cost of insulation and auxiliary heat sufficient to maintain
8-32
-------
a 55-65°C (130-150°F) exhaust gas temperature for condensa-
tion control was added. No allowance is made for handling
and conveying systems for the collected sludge and dust.
This material is normally manually dumped directly from the
control device into reusable 0.2 cubic meter (55-gallon)
drums or plastic bags and is shipped to a smelter. The
estimated total particulate catch of an entire 6500 bpd
plant is estimated at 158 kg (350 Ib) per day. Shipment in
plastic bags would require 10 bags per day, which can be
purchased for approximately $4.00. This cost is insignifi-
cant relative to the estimated total annualized costs of
more than $100,000.
For purposes of estimating the cost of the best demon-
strated technology with regard to lead oxide manufacturing
controls, it is assumed that the average facility incor-
porates a baghouse having an air-to-cloth ratio of 3 to 1
(3/1 Aye). This is part of the process equipment. To reach
the collection efficiency of the control system tested at
Plant G, it may be necessary to use fabric filters with an
A/C of 2/1. Therefore the incremental cost of a 2/1 A/C
baghouse is added to the overall control'costs shown herein.
None of the selected lead emissions control systems dis-
charges water. Impingement and entrainment scrubbers
generally use water at a rate of only 134 m /1000 m {1
8-33
-------
gpm/1000 acfrn) , only 20 percent of which is due to recir-
culation tank blowdown. The balance is lost through evapor-
ation. This use results in a maximum increase of only 1 to
2 percent in total hydraulic flow for the plant (see Table
7-11). This increase would probably not require expansion
of the water treatment system nor would it significantly
increase the operating costs.
The mist eliminator used to control acid mist requires
67 m water per 1000 m (1/2 gpm per 1000 scfm). A typical
battery plant requires 42 to 290 liters (11 to 74 gal) water
per battery depending on whether batteries are wet- or dry-
on
charged, cne dry-charge battery requiring the higher
amount. A typical plant requirement is given as an average
21
of 250 liters/battery (66.5 gal/battery). Thus the daily
water flow to the plant's wastewater system is as follows:
Plant Manufacturing Water added for
size, wastewater, H7SO, mist control,
3 \
bpd m (gal)/day mj (gal)/day*
100 25 (6,600) 5 (1,200)
250 62 (16,500) 11 (2,900)
500 124 (33,000) 22 (5,800)
2000 503 (133,000) 87 (23,000)
6500 1627 (430,000) 260 (68,000)
The cost to build and operate the additional water treatment
capacity must be added to the cost of the acid mist control.
Based on the data reported in Reference 22 it is estimated
* Based on 16 hrs. per day.
ft ~3
-------
that the additional capital costs and annualized costs for
treatment of the mist eliminator water are as follows:
Plant size, bpd
100, 250*
500
2000
6500
Capital costs
$ 300
$ 1,000
$10,000
$15,000
Annualized costs
$ 300
$ 1,000
$ 6,000
$10,000
The estimated total costs of each control system for each
control alternative are shown in Tables 8-15 through 8-22.
Not''all these costs are attributable to the promulgation of
a New Source Performance Standard, since two facilities
(lead reclamation and paste mixing) require controls just to
meet typical SIP regulations for particulate matter. The
applicable costs of these SIP controls must be deducted from
the overall costs shown in Tables 8-15 through 8-22 SIP
control costs are shown in Table 8-23. For estimating the
SIP control costs, it is assumed that each facility is
vented to a separate impingement and entrainment scrubber
having a 90 percent total particulate collection efficiency.
Tables 8-24 through 8-28 show the net capital cost of
lead control resulting from a New Source Performance Stan-
dard for lead, ^able 8-29 lists the overall net capital
Capital costs and annualized costs are assumed to level
off at the 250 BPD plant capacity level.
8-35
-------
Table 8-15. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE I FOR NEW PLANTS
Plant
size,
bpd
500
2000
6500
Affected
facilities
C»E
A,B,F
Gu
Db
Cf E
A,B,F
G
D
C,E
A,B,F
G
D
Control device to which
facilities are vented
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Exhaust rate
3 , ,
m /mm
541
266
348
825
311
1367
88
1670
453
4020
215
acfm
x 1000
19.1
9.4
12.3
29.1
11.0
48.3
3.1
59.0
16.0
142.0
7.6
Installed
cost,
$1000
150,
66d
44
0
260
225-,
??d
145
_i
451
440,
105d
370
J^c
928
CO
I
OJ
01
b
d
Facility codes are as follows: A, grid casting furnace? B, grid casting
machine; C, paste mixing; D, PbO manufacturing? E, Three-process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd plant does not
manufacture PbO.
Incremental cost between 2/1 A/C and 3/1 A/C baghouse.
includes additional 10 percent for modification of basic system of preven-
tion of spark carryover.
-------
Table 8-16. COST OF EMISSION CONTROL SYSTEMS
FCR CONTROL ALTERNATIVE II FOR NEW PLANTS
Plant
size,
bpd
500
2000
6500
Affected
"facilities
B,C,E
F
A
Gb
D
B,C,E
F
A
G
D
B,C,E
F
A
G
D
Control device to which
facilities are vented
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Exhaust rate
m /min
575
198
34
348
880
198
57
1367
88
1798
198
127
4020
215
acfm
x 1000
20.3
. V
1.2
12.3
31.1
7.0
2.0
48.3
3.1
63.5
7.0
4.5
142
7.6
Installed
cost,
$1000
160
55
27
44
0
286
230
55
34
145,,
4°
468
465
55
46
370
13°
949
CO
I
a Facility codes are as follows: A, grid casting furnace; B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-Process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd plant does not
manufacture PbO.
C Incremental cost between 2/1 A/C and 3/1 A/C baghouse.
-------
00
co
Table 8-17. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE III FOR NEW PLANTS
Plant
size,
bpd
500
2000
6500
Affected
facilities3
C,E
A,B,F
Gb
D
C,E
A,B,F
G
D
C,E
A,B,F
G
D
Control device to which
facilities are vented
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Exhaust rate
m /min
541
266
348
825
311
1367
88
1670
453
4020
215
acf m
x 1000
19.1
9,4
12.3
29.1
11.0
48.3
3.1
59
16
142
7.6
Installed
cost,
$1000
150
61
44
0
255
225
66
145
4C
440
440
75
370
13C
898
Facility codes are as follows: .A, grid casting furnace; B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-Process operation?
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd plant does not
manufacture PbO.
c Incremental cost between 2/1 A/C and 3/1 A/C baghouse.
-------
CO
Table 3-18. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE IV FOR NEW PLANTS
Plant
size,
bpd
500
2000
6500
Affected
facilities
A,B,C
E
F
Q
j-jk
A,B,C
E
F
G
A,B,C
E
F
G
D
Control device to which
facilities are vented
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Mist eliminator
Fabric filter, 2/1 A/C
Exhaust rate
m /min
136
472
198
349
204
733
198
1367
88
408
1517
198
4020
215
acfm
x 1000
4.8
16.7
7.0
12.3
7.2
25.9
7.0
48.3
3.1
14.4
53.6
7.0
142
7.6
Installed
cost,
$1000
48
98
55
44
0
245
50
140
55
145
4
394
72
260
55
370
13C
770
a Facility codes are as follows: A, grid casting furnace; B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-Process operation;
F, lead reclaim furnace; G, formation.
b For purposes of this study it is assumed that, a 500-bpd plant does not
manufacture PbO.
c Incremental cost between 2/1 A/C and 3/1 A/C baghouse.
-------
Table 8-19. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE V FOR NEW PLANTS
Plant
size,
bpd
500
2000
6500
Affected
facilities3
A,B,C,F
E
Gb
D
A,B,CfF
E
G
D
A,B,C,F
E
G
D
Control device to which
facilities are vented
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 2/1 A/C
Exhaust rate
m /min
334
472
349
402
733
1367
88
606
1517
4020
215
acfm
x 1000
11.8
16.7
12.3
14.2
25.9
48.3
3.1
21.4
53.6
142
7.6
Installed
cost,
$1000
67
98
44
0
204
70
140
145
4°
359
84
260
370
13C
727
00
-Ca
o
Facility codes are as follows: A, grid casting furnace? B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-Process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd plant does not
manufacture PbO.
Incremental cost between 2/1 A/C and 3/1 A/C baghouse.
-------
Table 8-20. COST OP EMISSION CONTROL SYSTEMS
FOR COIITROL ALTERNATIVE VI FOR NEW PLANTS
CD
Plant
size,
bpd
100
250
Affected
facilities3
A,B,C
E
G
D
Fd
A,B,C
E
Gb
D
Fd
Control device to which
facilities are vented
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Mist eliminator
Exhaust rate
m /min
117
402
75
124
428
177
acfm
4130
14,200
2660
4370
15,100
6260
Installed
cost
S 39,100C
85,000
11,500
0
0
$ 135,000
$ 40,700°
90,000
24,500
0
0
$ 155,000
Facility codes are as follows: A, grid casting furnace; B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd or less plant does not
manufacture PbO,
Includes additional 10 percent for modification of basic system of preven-
tion of spark carryover.
For the purposes of this study, it is assumed that a plant making less than
500 bpd does not have a lead reclaim furnace.
-------
Table 8-21. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE VII FOR NEW PLANTS
33
I
Plant
size,
bpd
100
250
Affected
facilities
A,B,C,E
&>
Fd
A,B,C,E
Control device to which
facilities are vented
Fabric filter, 6/1 A/C
Mist eliminator
Fabric filter, 6/1 A/C
Mist eliminator
Exhaust rate
m /min
518
75
552
177
acfm
18,300
2,660
19,500
6,260
Installed
cost
$ 159,000°
11,500
0
0
$ 171,000
$ 171,000°
24,500
0
0
$ 196,000
Facility codes are as follows: A, grid casting furnace; B, grid casting
machine; C, paste mixing; D, PbO manufacturing; E, Three-process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd or less plant does not
manufacture PbO.
Includes additional 10 percent for modification of basic system of preven-
tion of spark carryover.
For the purposes of this study, it is assumed that a plant making less than
500 bpd does not have a lead reclaim furnace.
-------
00
I
4S>
u>
Table 8-22. COST OF EMISSION CONTROL SYSTEMS
FOR CONTROL ALTERNATIVE VIII FOR NEW PLANTS
Plant
size,
bpd
100
250
Affected
facilities
A,B,C
E
G
Fc
A,B,C
E
Gb
D
FC
Control device to which
facilities are vented
Impingement and entrain-
ment scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Impingement and entrain-
ment scrubber
Fabric filter, 6/1 A/C
Mist eliminator
Exhaust rate
m /min
117
402
75
124
428
177
acfm
4130
14,200
2660
4370
15,100
6260
Installed
cost
$ 44,500
85,000
11,500
0
$ 141,000
$ 45,500
90,000
24,500
0
$ 160,000
Facility codes are as follows: A, grid casting furnace; B, grid casting
machine,- C, paste mixing; D, PbO manufacturing; E, Three-process operation;
F, lead reclaim furnace; G, formation.
For purposes of this study it is assumed that a 500-bpd or less plant does not
manufacture PbO.
c
For the purposes of this study, it is assumed that a plant making less than
500 bpd does not have a lead reclaim furnace.
-------
Table 8-23. COSTS OF CONTROL SYSTEMS REQUIRED TO MEET
TYPICAL SIP REGULATIONS*1
Plant
size,
bpd
100
250
500
2000
6500
Facility
Paste mixing
Paste mixing
Paste mixing
Lead reclamation
Paste mixing
Lead reclamation
Paste mixing
Lead reclamation
Exhaust rate
ra /min
51
51
67
198
91
198
156
198
ac£m
x 1000
2.2
2.3
2.4
7.0
. 3.2
7.0
5.5
7.0
Installed .
cost, SZOOO
35
35
36
55
91
40
55
95
50
55
105
Direct operating
cost, S1000b
3.8
3.9
3.9
S.6
9.5
5.7
5.6
11.3
8.9
•'5.6
14.5
Annual! zed
capital,
$1000b
6.7
6.8
6.9
10.0
16.9
8.6
10.0
18.6
11.3
10.0
21.3
Total Annual! zed
cost, 51000b
10.5 •
10.7
10.8
15.6
26,4
14.3
15.6
29.9
20.2
15.6
35.8
The control device consists of an impingement and entrainment scrubber.
4th-quarter 1977 dollars.
-------
Table 8-24 . CAPITAL COSTS OF LEAD EMISSIONS CONTROL FROM NEW LEAD-
ACID BATTERY MANUFACTURING FACILITIES - 100 BPD PLANT
Control
alternative
VI
VII
VIII
Lead emissions.
kg/day
SIP
0.759
0.759
0.759
NSPS
0.0122
0.0127
0.0615
Ib/day
SIP
1.67
1.67
1.67
NSPS
0.0268
0.0268
0.136
Effectiveness of lead
control » percent
SIP
38
38
39
NSPS
99.0
99.0
94.9
Installed cost, 4th-qtr.
1977 dollars x 1000
SIP
35
35
35
NSPS
124
159
129
Installed cost of
control allocable to
NSPS, 4th-qtr. 1977
dollars x 1000
89
124
94
oc
I
-------
Table 8-25. CAPITAL COSTS OF LEAD EMISSIONS CONTROL FROM NEW LH"AD-
ACID BATTERY MANUFACTURING FACILITIES - 250 BPD PLANT
Control
alternative
VI
VII
VIII
Lead emissions.
kg/day
SIP
1.90
1.90
1.90
NSPS
0.0304
0.0304
0.154
Ib/day
SIP
4.18
4.18
4.18
NSPS
0.067
0.067
0.339
Effectiveness of lead
control
1 SIP
38
38
38
percent
NSPS
99.0
99.0
94.9
Installed cost, 4th-
-------
Table 8-26^ . CAPITAL COSTS OF LEAD EMISSIONS CONTROL FROM NEW
LEAD-ACID BATTERY MANUFACTURING FACILITIES, 500-BPD PLANT
oo
i
• Control
alternative
I
II
III
IV
V
Lead emissions.
kg/day
SIP
3.82
3. 82
3.82
3.82
3.82
NSPS
0.063
0.066
0.097
0.326
0.326
Ib/day
SIP
8.42
8.42
8.42
8.42
8.42
NSPS
0.13B
0.193
0.214
0.718
0.718
Effectiveness of lead
control
SIP
39
39
39
39
39
percent
NSPS
99.0
98.6
98.4
94.8
94.8
Installed cost, 4th-qtr.
1977 dollars x 1000
SIP
91
91
91
91
91
NSPS
216
242
211
201
160
Installed cost of
control allocabla to
NSPS, 4th-qtr. 1977
dollars x 1000
125
151
120
110
69
-------
Table 8-27. CAPITAL COSTS OF LEAD EMISSIONS CONTROL FROM NEW LEAD-ACID
BATTERY MANUFACTURING FACILITIES,. 20no-BPD PLANT
co
-o
CO
Control
alternative
I
II
III
IV
V
.Lead emissions,
kg/day
SIP
16.2
16.2
16.2
16.2
16.2
NSPS
0.030
0.400
0,439
1.350
1.360
Ib/day
SIP
33.7
33.7
33.7
33.7
33.7
NSPS
0.665
0.885
0.940
2.880
2.880
Effectiveness of lead
control, percent
SIP
38
38
38
38
38
HSPS
98.8
98.4
98.3
94.8
94.8
Installed cost, 4th-qtr.
1377 dollars x 1000
SIP
95
95
95
95
95
NSPS
306
323
295
249
214
Installed cost of
control allocable to
NSPS, 4th-qtr. 1977
dollars x_1000
211
228
200
154
119
-------
Table 3-28,, CAPITAL COSTS OF LEAD EMISSIONS CONTROL FROM NEW LEAD-ACID BATTERY
MANUFACTURING FACILITIES, 6500-BPD PLANT
Control
alternative
1
II
III
IV
V
Lead emissions,
kg/day
SIP
50.1
50.1
50,1
50,1
50.1
NSPS
0,988
1.310
1.430
4.390
4.410
Ib/day
SIP
110.5
110.5
110.5
110.5
110,5
NSPS
2.18
2.89
3.15
9.67
9.73
Effectiveness of lead
control, percent
SIP
39
39
39
39
39
KSPS
98.8
98.4
98.3
94,6
94,6
Installed cost, 4th-qtr,
1977 dollars x 1000
SIP
105
105
105
105
105
NSPS
558
579
528
400
357
Installed cost of
control allocable to
NSPS, 4th-qtr. 1977
dollars x 1000
453
474
423
295
252
.£»
10
-------
Table 8-29. NET CAPITAL COSTS OF CONTROL ALTERNATIVES FOR LEAD-ACID
BATTERY MANUFACTURING PLANTSS'b
cn
O
Control
alternative
I
11
III
IV
V
VI
VII
VIII
installed cost of control systems allocable to NSPS , 4th-qtr. 197? dollars K 1000
100 bpd plant
101
136
106
250 bpd plant
120
161
125
500 bpd plant0
170
196
165
155
114
2000 bpd plant
366
383
355
309
274
6500 bpd plant6
838
859
80S
680
637
includes controls for both lead emissions and sulfuric acid mist emissions and includes
additional wastewater treatment capacity for the acid mist control system.
Cost of controls necessary to meet SIP requirements are not included; these costs are
estimated to be 591,000, 595,000, and §105,000 for SOQ-bpd, 2000-bpd, and 6500-bpd plants,
respectively, and $35,000 for the 100 and 250 bpd plants.
$1000 added for additional wastewater treatment capacity.
510,000 added for additional wastewater treatment capacity,
515,000 added for additional wastewater treatment capacity.
-------
cost of each control alternative for both lead and acid mist
emissions. Annualized control costs for new plants are
shown in Tables 8-30 through 8-34. These costs are exclu-
sive of those costs incurred to meet SIP regulations. The
annualized costs of sulfuric acid mist control are shown in
Table 8-35,
8.2,2 Modified/Reconstrueted Facilities
8.2.2.1 Capital Cost of Control Systems - The cost for
installing a control system in an existing plant that has
been modified, reconstructed, or expanded (given the same
exhaust gas parameters) is greater as a result of special
design considerations, more complex piping requirements,
etc. Estimating this additional installation cost or retro-
fit penalty is difficult because of many factors peculiar to
the individual plant. In preparation of this section, such
factors as lack of space, additional ducting, and additional
engineering were considered.
Configuration of equipment in the existing plant governs
the location of the control system. Depending on process or
stack location, long ducting runs from ground level to the
control device and to the stack may be required. A sizable
increase in costs may be incurred if the control equipment
must be placed on the roof, which may require steel struc-
tural support. Other cost components that may be increased
8-51
-------
Table 8-30. ANNUALIZED COSTS OF LEAD CONTROLS ALLOCABLE TO A NEW
SOURCE PERFORMANCE STANDARD FOR A NEW 100 BPD PLANT
CO
Control
alternative
VI
VII
VIII
Effectiveness of lead
removal compared with
SIP regulations,
units Pb removed/yra
kg
186
186
174
Ib
410
410
383
Direct
costs,
$1000/yr°
12.5
26.1
9.0
Annual! zed
capital,
$1000/yr°
16.1
IS. 2
17.1
Total annual! zed
costs,,
$1000/yr
28.6
44.3
26.1
Dollars
per unit of
lead removed,
kg
154
238
150
Ib
70
108
68
(SIP emissions - NSPS emissions) x 250 days/yr.
Excludes costs associated with mixer which is controlled under SIP regulations.
Does not include formation control costs and water treatment costs.
-------
Table 8-31. ANNUALIZED COSTS OF LEAD CONTROLS ALLOCABLE TO A NEW
SOURCE PERFORMANCE STANDARD FOR A NEW 250 BPD PLANT
Jl
Control
alternative
VI
VII
VIII
Effectiveness of lead
removal compared with
SIP regulations,
units Pb removed/yra
kg
467
467
438
lb
1030
1030
965
Direct
costs,
S1000/yrb
13.2
27.9
9.4
Annualized
capital,
$1000/yrb
17.2
19.1
18.2
Total annualized
costs,
$1000/yrb
30.4
47.0
27.6
Dollars
per unit of
lead removed.
kg
65
101
63
lb
30
45
29
(SIP emissions - NSPS emissions) x 250 days/yr.
Excludes costs associated with mixer which is controlled under SIP regulations.
Does not include formation control costs and water treatment costs.
-------
DD
Table 8-32. ANNUALIZED COSTS OF LEAD CONTROLS ALLOCABLE TO A NEW SOURCE
PERFORMANCE STANDARD FOR A NEW 500 BPD PLANT
(SIP emissions - NSPS emissions) x 250 days/yr.
• *' _..:::::::::::::::::=m~ll
Control
alternative
••
I
II
III
IV
V
Effectiveness of lead
removal compared with
SIP regulations, &
units Pb removed/yr
kg lb
936
934
930
875
875
2070
2060
2050
1930
1930
Direct
costs, b
$1000/yr
27.6
32.2
27.7
10.5
6.5
Annualized
capitalh
$1000/yr
19.9
24.7
19.9
19.7
12.9
Total annualized
costs,.
$1000/yr°
47 .5
56.9
47.6
30.2
19-4
Dollars
p&T unit of
lead removed
kg
51
61
51
35
22
lb
23
28
23
16
10
costs and water treatment costs
-------
Table 8-3.1. ANNUALIZED COSTS OF LEAD CONTROLS ALLOCABLE TO A NEW SOURCE
PERFORMANCE STANDARD FOR A NEW 2000-BPD PLANT
CO
i
Ol
CJI
(SIP emissions - NSPS emissions) x 250 days/yr.
Excludes costs associated with mixer and reclamation facilities, both of which are
controlled under SIP regulations. Does not include formation control costs and
water treatment costs.
Control
alternative
I
II
III
. IV
V
Effectiveness of lead
removal compared with
SIP regulations,
units Pb removed/yr
kg
3740
3720
3710
3490
3490
Ib
8240
B190
8180
7690
7690
Direct
costs,.
$1000/yr
71.7
71.7
71.7
17.5
13.5
Annualized
capital.
$10QO/yrD
36.2
42.2
35.2
30.6
23.4
Total annual i zed
costs,.
$1000/yr
108
122
107
48.1
36.9
Dollars
per unit of
lead removed
kg
29
33
29
14
11
ID
13
15
13
6.3
4.8
-------
\
I
Table 8-34. ANNUALIZED COSTS OF LEAD"CONTROLS ALLOCABLE TO A NEW SOURCE
PERFORMANCE STANDARD FOR A NEW 6500-BPD PLANT
CO
in
Control
alternative
I
II
III
IV
V
Effectiveness of lead
removal compared with
SIP regulations,
units Pb removed/yr
Kg
12,292
12,202
12,156
11,430
11,430
Ib
27100
26900
26800
25200
25200
Direct
costs,.
$100Q/yr0
200
21?
198
33,5
28,5
Annual i zed
capital,
S1000/yr°
83.5
86.0
78.5
57.5
49.5
Total annualized
costs,,
SlOOO/yr
284
303
277
91
78
• Dollars
per unit of
lead removed
kg
23
25
23
8.0
6.8
Ib
11
11
10
3.6
" 3.1
(SIP emissions - NSPS emissions) x 250 days/yr.
Excludes costs associated with mixer and reclamation facilities, both of which are controlled
under SIP regulations. Does not include formation control costs and water treatment costs.
-------
Table 8-35.
ANNUALIZED COSTS OF SULFURIC ACID MIST CONTROLS
FOR NEW FACILITIES3'b
Plant
size,
bpd
100
250
500
2000
6500
Direct operating
costs of control
system, $1000/yr
3.8
6.1
8.5
17
30
Annuali zed capital
charges of control
system, $1000/yr
4.0
6.9
10.5
27
55
Annualized cost of
additional wastewater
treatment, $1000/yr
0.2
0.3
1.0
6.0
10.0
Total annualized
costs, $1000/yr
8.0
13.3
20.0
50.0
95.0
CO
en
Based on installation of a mist eliminator.
No SIP regulations are applicable; 100 percent of costs allocable to NSPS regulations.
-------
because of space restrictions and plant configuration are
contractor's fees and engineering fees. These fees, esti-
mated at 15 percent and 10 percent respectively under normal
conditions, can be expected to increase to 20 percent and 15
percent respectively for a retrofit. These fees vary from
place to place and job to job depending on the difficulty of
the job, the risks involved, and current economic conditions.
The fees cited are PEDCo's estimates,
The requirement for additional ducting can vary con-
siderably, depending on plant configuration. For purposes
of this study, it is estimated that approximately 50 percent
more ducting may be required to install a control system in
an existing plant.
If the space is tight within the plant, it may be
necessary to install the control equipment on the roof. It
is estimated that a roof-top installation could double the
structural costs. The additional labor costs were deter-
mined by assuming that 10 percent of the labor will be
required to tie the system into the process. This work
would most likely have to be done at premium-time wage rates
in accordance with governmental regulations and/or union
agreements. These rates are assumed to be double the
straight-time pay.
8-58
-------
Applying these additional cost factors to those in
Tables 8-10 and 8-11 shows that the cost of retrofit installa-
tions runs approximately 20 percent higher than the cost of
new installations. Breakdowns of retrofit cost factors are
Shown in Tables 3-36 and a~3~/ for fabric filters and wet
collectors.
8.2.2.2 Annualized Cost_of ControlSystems - The annualized
costs of control systems for modified/reconstructed facilities
are calculated similarly to those for new facilities. The
cost components that are proportional to capital costs, {see
Table 8-12) are approximately 20 percent higher than those
for new facilities.
8.2.2.3 Cost of Alternative Contrp_3^Measur_es_ - The costs of
the eight control alternatives listed in Table 8-6 were
calculated on the same basis as those costs applicable to
new facilities, (see Section 8.2.1.3). Tables 8-38 through
8-42 show the net capital and annualized costs for the eight
control alternatives applicable to existing facilities that
have been reconstructed or modified; Table 8-43 shows the
costs of sulfuric acid mist control. The additional waste-
water costs resulting from use of a fan separator have been
added. For estimating purposes, it was assumed that these
costs are double those incurred for a new plant* It is
important to note that these costs are estimates. Retrofit
situations vary over a broad range, since, for example, some
-fi-RQ
-------
Table 8-36. COMPONENT CAPITAL COST FACTORS FOR A
RETROFIT INSTALLATION OP A FABRIC FILTER AS A
FUNCTION OF EQUIPMENT COST, Q
Component
Equipment
Ductwork
Instrumentation
Electrical
Foundations
Structural
Sitework
Painting
Premium time labor
Total direct costs
Direct costs
Material
l.OOQ
0.06Q
0.04Q
0.11Q
0.03Q
0.04Q
0.02Q
0.004Q
1.30Q
Labor
0.25Q
0.30Q
0.006Q
0.16Q
0.05Q
0.08Q
0.02Q
0.02Q
0.09Q
0.98Q
Component
Engineering
Contractor's fee
Shakedown
Spares
Freight
Taxes
Total indirect costs
Indirect costs
Measure of costs
15% material and labor
20% material and labor
5% material and labor
1% material
3% material
3% material
Factor
0.342Q
0.456Q
0.114Q
0.013Q
0.039Q
0.039Q
1.003Q
Contingencies - 20% of direct and indirect costs 0.656Q
Total capital costs
3.94Q
8-60
-------
Table 8-37. COMPONENT CAPITAL COST FACTORS FOR A RETROFIT
INSTALLATION OF A WET COLLECTOR (SCRUBBER OR MIST ELIMINATOR)
AS A FUNCTION OF EQUIPMENT COST, Q
Component
Equipment
Ductwork
Instrumentation
Electrical
Foundations
Structural
Sitework
Painting
Piping
Premium Time Labor
Total direct costs
Direct costs
Material
l.OOQ
0.04Q.
0.04Q
0.11Q
0.03Q
0.04Q
0.02Q
0.004Q
0.15Q
-
1.43Q
Labor
0.25Q
0.20Q
0.006Q
0.16Q
0.05Q
0.08Q
0.02Q
0.02Q
0.1 6Q
0.09Q
1.03Q
Component
Engineering
Contractor ' s fee
Shakedown
Spares
Freight
Taxes
Total indirect co;
Indirect costs
Measure of
15% material and
20% material and
5% material and
1% material
3% material
3% material
5tS
costs
labor
labor
labor
Factor
0.369Q
0.492Q
0.123Q
0.014Q
0 . 04 2Q
0.042Q
1.082Q
Contingencies - 20% of direct and indirect cost 0.708Q
Total capital costs
4.25Q
R-fil
-------
Table 8-38.. COSTS OF LEAD EMISSIONS CONTROL ALTERNATIVES FOR
AN EXISTING 10Q-BPD PLANT
CO
i
en
ro
Control
alternative
VI
VII
VIII
Effectiveness of lead
removal compared with
SIP regulations, .
units Pb removed/yr
kg
186
186
174
Ib
410
410
383
Installed
cost,
S1000C
107
149
113
Direct
operating
cost, SlOOO/yr
13.7
27.8
in. 3
Annual! zed
capital
charges, SlOOO/yr
19.1
22.4
20.3
Total
annual! zed
cost,
$10QO/yr
32.8
50.2
30.6
Dollar per unit of
lead removed
kg
176
270
176
Ib
80
123
80
See Table 8-5 for a description Of each Control Alternative.
b (SIP emissions - NSPS emissions) x 250 days/yr.
Does not include costs associated with mixing and reclaim facilities, both of which are controlled under SIP
regulations.
-------
Table :8-39, COSTS OF LEAD EMISSIONS CONTROL ALTERNATIVES
FOR AN EXISTING 250-BPD PLANT
CD
I
CT>
CO
Control
alternative
VI
VII
VIII
Effectiveness of lead
removal compared with
SIP regulations, b
units Pb removed/yr
kg
46?
46?
438
Ib
1030
1030
965
Installed
cost,
S1000C
114
163
120
Direct
operating
coat, 51000/yrc
14.5
29. 8
10.8
Annualized
capital
charges, SlOOO/yr
20.4
23.7
21.6
Total
annual i zed
cost,
SlOOO/yr
34.9
53.5
32.4
Dollar per unit of
lead removed
kg
74
115
74
Ib
34
52
34
a See Table 8-5 for a description of each Control Alternative.
k (SIP emissions - NSPS emissions) x 250 days/yr.
c Does not include costs associated with nixing arid reclaim facilities, both of which are controlled under SIP
regulations.
-------
I
Table 8-40. COSTS OF LEAD EMISSIONS CONTROL ALTERNATIVES
FOR AN EXISTING 500-BPD PLANT
Control
alternative
I
II
III
IV
V
Effectiveness of lead
removal compared with
SIP regulations, ,
units Pb removed/yr
Kg
936
934
930
875
875
Ib
2070
2060
2050
1930
1930
Installed
cost
$1000C
ISO
181
144
132
83
Direct
operating
cost, SlOOO/yr
29.4
34,3
29.4
12.0
7.5
Annualized
capital
charges, $10QO/yr
24.2
29.8
24.0
23.4
15.2
Total annualized
cost
$1000/yrt"
53.6
64.1
53,4
35.4
22,7
Dollar per unit of
lead removed
kg
57
69
57
40
26
Ib
26
31
26
ia
12
See Table 8-5 for a description or each Control Alternative.
(SIP emissions - NSPS emissions) x 250 days/yr.
Does not include costs associated with mixing and reclaim facilities, both of which are
controlled under SIP regulations.
-------
Table 8-41. COSTS OF LEAD EMISSIONS CONTROL ALTERNATIVES FOR
AN EXISTING 2000-BPD PLANT
="
Control a
alternative
I
II
III
IV
V
Effectiveness of lead
removal compared with
SIP regulations, .
units Pb reroove<3/yr
kg
3740
3710
3710
3490
3490
Ib
8240
8190
8180
7690
7690
Installed
cost
$100 Oc
253
274
240
185
143
Direct
operating
cost, S1000/yrc
74,7
82.9
74.5
19,7
15,2
Annualized
capital
charges, SlOOO/yr
43,4
50.0
42.0
36,1
27,4
Total annualized
cost
SlOOO/yr
118
133
117
55.8
42.6
Dollar per unit of
lead removed
kg
32
36
32
16
12
Ib
14
16
14
7.3
5.5
CD
I
CJ>
a See Table 8-5 for a description of each Control Alternative,
b (SIP emissions - NSPS emissions) x 250 days/yr.
c Does not include costs associated with mixing and reclaim facilities, both of
which are controlled under SIP regulations.
-------
I
Table 8-42. COSTS OF LEAD EMISSIONS CONTROL ALTERNATIVES FOR
AN EXISTING 6500-BPD PLANT
Control
alternative
1
II
III
IV
V
Effectiveness of lead
removal compared with
SIP regulations, b
units Pb removed /yr
kg
12,292
12,202
12,156
11,430
11,430
Ib
27100
26900
26800
25200
25200
Installed
cost
S1000C
544
569
508
JS4
302
Direct
operating
cost, $1000/yrc
206
224
204
37.6
2
42.0
Annual! zed
capital
charges, S1000/yrc
98.9
102
92.9
67.5
58.1
["""
Total annualized
cost
$1000/yr
305
326
297
105
100
Dollar per unit of
lead removed
I kg 1
25
27
24
9.1
8,7
Ib
11
12
11
4.2
4. 0
See Table 8-5 for a description of each Control Alternative.
(SIP emissions - NSPS emissions) x 250 <3ays/yr,
Does not include costs associated with mixing and reclaim facilities,
both of which are controlled under SIP regulations.
-------
Table 8-43. SULFURIC ACID MIST CONTROL COSTS FOR EXISTING RECONSTRUCTED/
MODIFIED BATTERY FORMATION FACILITIES3
CO
I
CTl
Plant
size,
BPD
100
250
500
2000
6500
Installed costs, $1000
Mist eliminator
13.8
29.4
52.8
174
444
additional wastewater
treatment capacity
0.6
0.6
2.0
20.0
• 30.0
Direct operating
costs uf mist
eliminator
SlOOO/yr
4.n
6.4
9,1
13.0
35.2
Annualized capital
charges of mist
eliminator
$1000
4.4
7.7
12.0
43.9
67.6
Annualized coats
of additional
Water treatment
$1000
0.6
0.6
2.0
12.0
20.0
Total
annualized
costs,
$1000
9.0
14.7
23.1
74.9
123
4th-qu»rter 1977 dollars
-------
are reconstructions and others are expansions. Thus it is
unlikely that the new plant exhaust parameters would fit all
the retrofit applications. For estimating purposes, it must
be assumed that exhaust parameters remain constant. Addi-
tionally, plants that reconstruct or modify their facilities
are not likely to undertake changing all their facilities at
the same time. Consequently, the overall capital and
annualized costs shown in Tables 8-38 through 8-43 are not
likely to be incurred at the same time. All the costs must
be incurred at some point in time, as each of the facilities
becomes an affected facility.
8.2,3 Cost-effectivenessof Alternative Control Measures
It is informative to compare the annualized costs of
the various alternative lead control measures to the quanti-
ties of lead removed by them. This comparison, or cost-
effectiveness analysis, is done in this section for the
five sizes of the new model battery plants. (Since an NSPS
impacts most heavily on new, rather than existing plants,
the cost-effectiveness analysis will be limited to them.}
There are several ways this comparison can be made.
First, the various incremental annualized costs (that is,
those costs solely due to NSPS control) may be divided by
the incremental quantities of lead removed. Tables 8-30
through 8-34 list these cost-effectiveness quotients. It is
8-68
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clear from the tables that the quotients vary both with the
plant capacity and the control alternative. The quotients
vary from nearly $7.00 to $25.00 per Kg in the 6500 battery
per day (bpd) plant, but are much higher in the smallest
plant (100 bpd) where they range from $150.00 to $238.00 per
Kg. This clearly indicates that control costs benefit from
a positive economy of scale.
The quotients for control alternatives I through VIII
are plotted in Figure 8-4 against the model battery plant
capacity. Note, first of all, that the cost-effectiveness
quotients decrease significantly as the plant size increases.
This demonstrates the economy of scale characteristic men-
tioned above. Moreover, as the size increases to the
largest capacity, 6500 bpd, the quotients continue to
decrease, although more gradually. If extrapolated beyond
6500 bpd, the curves would tend to approach certain limiting
values. Beyond these values, cost-effectiveness would be
effectively independent of plant size.
Also notice that the cost-effectiveness curves are not
ordered according to their respective control efficiencies.
For instance, the curve for Alternative I, the most strin-
gent with 99 percent lead emissions control, lies below the
curve for Alternative II, which represents a lower control
efficiency (98 percent) for the larger plants. Likewise the
curve for Alternative VI lies below an equally efficient
8-69
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1000
500
S 200
o 100
•to*
C_5
1/5
O
o
50
20
10
ALTERNATIVE I;
ALTERNATIVE II:
k ALTERNATIVE III:
ALTERNATIVE IV:
ALTERNATIVE V:
ALTERNATIVE VI:
-ALTERNATIVE VII:
ALTERNATIVE VIII:
99 PERCENT
98 PERCENT
98 PERCENT
95 PERCENT
95 PERCENT
99 PERCENT
99 PERCENT
95 PERCENT
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
LEAD EMISSION
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
CONTROL
100 250 500
PLANT SIZE, bpd
1000 2000
6500
Figure 8-4
Cost-effectiveness of Model Plant Control
Alternatives.
8-70
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Alternative VII and barely above Alternative VIII which
represents a much lower efficiency (95 percent). In other
words, one would expect Alternatives I, VI, and VII to be
less cost-effective {i.e., more costly) than all the others,
simply because they require the greatest degree of control.
This, however, is not the case in Alternatives I and VI. This
situation can be understood if it is remembered that each
alternative represents a different group of control systems
and for each of these systems there is a different relation-
ship between cost and gas flowrate. For example, the Alter-
native I costs for the 2000 and 6500 bpd plants include
three fabric filters, while the corresponding Alternative II
costs include two fabric filters and two impingement and
entrainment scrubbers a total of four lead control systems.
Alternative VI is less costly than Alternative VII because
the moist mixer gases and the three-process operation ex-
hausts are vented to separate fabric filters. Thus Alterna-
tive VI does not require heating as large a fabric filter as
does Alternative VII.
Finally, as Figure 8-4 shows. Alternative VIII (at 95
percent) is the most cost-effective for the smallest plants,
while Alternative V (95 percent) is the most cost-effective
for the 2000 and 6500 bpd plant sizes.
8-71
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8.3 OTHER COST CONSIDERATIONS
8.3.1 Costs Imposed by Water PollutionRegulations
Effluent limitations, new source standards, and pretreatment
standards regulating water emissions from lead-acid battery plants
are expected to be proposed in 1980. Upon promulgation of these
regulations, existing plants discharging to surface waters will be
subject to effluent limitations which will reflect best practicable
technology (BPT) currently available. After 1983, these effluent
limitations will reflect best available technology (BAT) economically
achievable. New battery plants discharging to surface waters will be
subject to new source standards which will reflect BAT.
Existing plants discharging to municipal treatment systems will
be subject to Federal pretreatment standards which will reflect BPT.
New plants discharging to municipal treatment systems will be required
to meet Federal pretreatment standards which will be more stringent
than those for existing plants.
One study reports that of the 200 lead-acid battery plants in
the United States in 1972, approximately 150 were neutralizing their
wastewater effluents. Of these 150 plants, about 46 use lime treat-
23
ment and 14 use caustic treatment. The number of plants applying
such treatments will increase rapidly as Federal effluent limitations
become effective. The costs associated with water pollution control
8-72
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are presented in Table 8-44. Wastewater generated by impingement and
entrainment scrubbers used to control atmospheric lead emissions
would make up only a small percentage of the wastewater generated at
a lead-acid battery plant. The additional wastewater would not
significantly affect the costs of water treatment. Use of a mist
eliminator to control acid mist requires increased water treatment
capacity. This extra cost is included with the mist eliminator
control costs in Table 8-43.
8.3.2 CostsImposed by Solid Waste^Disppsal Regulations
As mentioned earlier, 60 plants were producing wastewater treat-
ment sludges in 1972. These sludges require some type of landfill
disposal. Estimated annualized costs for providing solid waste
disposal for lime and caustic treatment facilities are presented in
Table 8-45 and Table 8-46, respectively. These costs are based on
24
costs applicable to an 1800-BPD plant and scaled to 100, 250, 500,
2000, and 6500 bpd plants by use of the t law.
8.3.3 Costs Associated with OSHA Compliance
The costs of compliance with regulations of the Occupational
Safety and Health Administration have been estimated for five factors,
as shown in Table 8-47, which also lists the assumptions upon which
the compliance cost estimate is based. The 25 batteries/man-day
figure is an average based on information obtained from several plant
representatives.
8-73
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Table 8-44. ANNUALIZED COSTS ASSOCIATED WITH WATER POLLUTION CONTROL
{4th-Quarter 1977 Dollars)3
Degree of control
Pre-NPDESd
Best Practicable Technology,
(BPT)e,f
Best Available Technology,
(BAT)6''
Annualized costs by plant size, $1000
100 bpdb
2.2
18.6
24.0
250 bpdb
4.5
30.6
40.5
500 bpdc
19.9
81.5
116
2000 bpdc
60.5
169
262
6500 bpdc
162
314
510
CO
Costs obtained from references were updated per the Chemical Engineering (CE) index
for Plant Costs.
Based on 0.075 m3 {20.0 gal) water per battery. This represents the mix of wet
and dry units typical for small (less than 500 BPD) plants reported to U.S. EPA.
c Based on 0.25 m3 (66.5 gal) water per battery. 5
Reference 26.
Q
Reference 27.
Since effluent limitations and new source standards for battery manufacturing.
have not been proposed, the costs set forth for BPT and BAT are estimates, rather
than firm costs.
-------
Table 8-45. ANNUALIZED COSTS ASSOCIATED WITH SOLID WASTE DISPOSAL
FOR PLANTS USING LIME NEUTRALIZATION
(4th Quarter-1977 Dollars}3
Type of disposal
On-site land storage
On-site land storage with
leachate collection and
treatment system
Chemical fixation and landfill
Annualized costs by plant size, $1000
100 bpd
4.4
6.5
15.0
250 bpd
8.7
13.6
30.5
500 bpd
14.7
23.5
51.4
2000 bpd
41.2
67.6
150
6500 bpd
106
176
332
co
i
Costs for 1800 bpd were obtained from Reference 28 and scaled to various plant
= ^AC= ,,«n no the tO-6 law and updated to 4th quarter-1977 costs per the Chemical
sizes using the t°-6 law and updated
Engineering (CE) Index for Plant Costs
-------
CO
i
~j
en
Table 8-46. ANNUALIZED COSTS ASSOCIATED WITH SOLID WASTE DISPOSAL
FOR PLANTS USING CAUSTIC SODA NEUTRALIZATION
(4th Quarter-1977 Dollars)3
Type of disposal
On-site landfill
Off-site landfill (contractor)
Off-site landfill
Secured landfill
Annualized costs by plant size, $1000
100-500 bpd
<0.5
<0.5
<0.5
<0.5
2000 bpd
2.2
0.9
0.9
1.6
6500 bpd
5.3
2.0
2.0
4.0
a Costs for 1800 bpd were obtained from Reference29 and scaled to various plant
sizes using the t°*6 law and updated to 4th quarter-1977 costs per the Chemical
Engineering (CE3 index for Plant Costs.
-------
Table 8-47. COST FACTORS AND ASSUMPTIONS FOR
OSHA COMPLIANCE (METKIC UNITS)
OSHA Factor
Assumptions upon which
estimate is made
Employee care
Heat for makeup air
Exhaust hoods and ducts
Electricity
Fans & motors
25 batteries/man-day
$35/employee/mo.
4600 degree-days/year
$3.00/GJ
Air volumes as follows:
8
8
8
16
24
hr/day
hr/day
hr/day
hr/day
hr/day
100-bpd plant 600
250-bpd plant 730
500-bpd plant 1160
2500-bpd plant 2580
6500-bpd plant 6360
457 meters/min velocity
122 m ductwork/plant
annualized costs = 20% of capital
costs
$0.03/kWh
Pressure loss: 1.6 Pa/m duct
Each plant has four separate systems
with overall AP of 100 Pa.
(including fittings & dampers, etc.)
Four equal sized units per plant
Annualized costs = 30% of capital costs
8-77
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Table 8-47A. COST FACTORS AND ASSUMPTIONS FOR
OSHA COMPLIANCE (ENGLISH UNITS)
OSHA factor
Assumptions upon which
estimate is made
Employee care
Heat for makeup air
Exhaust hoods and ducts
Electricity
Fans and motors
25 batteries/man-day
$ 3 5/employee/mo.
4600 degree-days/year
$3.00/MM Btu
Air volumes as
100-bpd plant
250-bpd plant
500-bpd plant
2000-bpd plant
6500-bpd plant
follows:
21,000 cfm,
25,600 cfm,
40,800 cfm,
91,000 cfm,
224,000 cfm,
8 hr/day
8 hr/day
8 hr/day
16 hr/day
24 hr/day
1500 fpm velocity
400 ft ductwork/plant
annualized costs = 20% of capital
costs
$0.03/kWh
Pressure loss: 0.2 in. W.G./100 If duct
Each plant has four separate systems
with overall AP of 0.4 in. W.G.
(including fittings and dampers, etc.)
Four equal sized units per plant
Annualized costs = 30% of capital costs
8-78
-------
Simply put, it represents plant capacity divided by plant
employees. It is estimated that $35 per employee per month
30
is required for blood tests, laundry, and shower facilities.
All the plant air that is exhausted must be made up. In
cold climates, this requires the addition of heat. The
heating costs are based on 4600 degree days per year (average
for St. Louis, Missouri), a fuel cost of $3.00 per MM Btu,
and a heat exchange efficiency of 60 percent. If the plant
uses propane, the costs will be somewhat higher. The volume
of air to be heated corresponds to the exhaust rates shown
in Table 8-15. The capital costs of ductwork, hoods, fans,
and motors are based on engineering judgment and published
data. Likewise, the ventilation system pressure drop,
velocity, and length and number of runs are based on engi-
neering judgment. Calculated annualized costs for the
control alternatives are approximately 30 percent of the
capital costs, (See Tables 8-29 through 8-35) . That percent-
age value is used for the costs associated with the fans and
motors. Since the ductwork and hoods require less mainten-
ance and no operating labor, the associated annualized costs
are estimated at 20 percent of the capital costs.
Overall OSHA compliance costs are shown in Table 8-48.
These costs do not include the impact of any new regulations
8-79
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or amendments that OSHA may be considering. Should OSHA
adopt more stringent standards, the compliance costs could
easily double.
The battery industry has no operations that require the
expenditure of funds for noise control.
Table 8-48. ESTIMATED OSHA COMPLIANCE COSTS FOR
LEAD-ACID BATTERY MANUFACTURING PLANTS
OSHA factor
Employee care
Heat for makeup air
Exhaust hoods and ducts
Electricity
Fans and motors
Totals
Annualized costs, $1000
100
bpd
1.7
4.1
1.6
0.1
4.6
12.1
250
bpd
4.2
5.2
2.0
0.1
4.8
16.3
500
bpd
8,4
8.2
2.4
0.2
5.6
24.8
2000
bpd
33.6
39.4
3.6
1.1
8.8
86.5
6500
bpd
109.0
132,0
5,5
4.1
18.7
269.3
8.3.4 Costs_ Associatedjwith Compliance Testing
Each source subject to a New Source Performance
Standard must undergo a compliance testing program. In
the case of lead-acid battery manufacturing plants, the
following facilities and pollutants may be affected:
8-80
-------
•^ Facility Pollutant
Grid Casting Lead
Paste Mixer Lead
Lead Oxide Manufacturing Lead
Three-Process Operation Lead
Lead Reclamation Lead
Formation Sulfuric Acid Mist
Concentrations of lead and sulfuric acid mist in well-
controlled gas streams from these facilities are very
small and extended sampling time is required to gather a
measurable sample. For example, it was necessary to sample
for 16 straight hours to gather a measurable sulfuric acid
mist sample for a test performed under this study. It is
estimated that a standard three-run compliance test program
will cost approximately $6,000-$?,500 for lead and $10,000-
$11,500 for sulfuric acid mist.* These costs include the
expenses of a presurvey travel, lodging and report prepara-
tion for the test crews. The total impact of these costs
are shown in Table 8-49. Except for the fact that smaller
plants, for purposes of this study, have fewer Affected
Facilities, the test costs are insensitive to plant size.
As can be seen, the compliance test program is a large
proportion of, and in addition to, the capital costs of the
Control Alternatives.
* The higher cost applied to a single stack test program.
The smaller figure applies to any stacks sampled beyond
the first stack in a multi-stack test program.
8-81
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Table 8-49. COMPLIANCE TESTING COSTS APPLICABLE TO NEW
SOURCE PERFORMANCE STANDARDS FOR LEAD-ACID
BATTERY MANUFACTURING FACILITIES
Control
Alternative
I
II
III
IV
V
VI
VII
VIII
Plant Size
Range , BPD
> 500
> 500
> 500
> 500
> 500
< 500
< 500
< 500
No. of Stacks
Pb
3
4
3
4
3
2
1
2
H2S04
1
1
1
1
1
1
1
1
Total Cost,
$1,000
29.5
35.5
29.5
35.5
29.5
23.5
17.5
23.5
8.3.5 Composite Costs of Environmental Regulatory
Requirements^
This subsection summarizes the cost impacts of the
various environmental regulations discussed earlier and
compares these costs with those related to air pollution
control. These latter costs consist of costs for SIP com-
pliance and costs related to compliance with an NSPS. Table
8-50 lists the various annualized costs of compliance with
environmental regulatory requirements for typical new plants.
The costs of compliance source tests, shown in Table 8-49,.
are not annualized.
8-82
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Table 8-5n_. . ANNUALIZED COSTS OF COMPLIANCE WITH ENVIRONMENTAL
REGULATORY REQUIREMENTS FOR TYPICAL NEW LEAD-ACID BATTERY MANUFACTURING PLANTS
Environmental
regulatory requirements
Water pollution control3
Solid waste disposal
OSHA
Air pollution control
SIPCH
NSPS
Totals
Annualized costs by plant size,
$1000 4th guarter-1977 dollars
100 bpd
24.0
6.5
12.1
12.9
36.6
92
250 bpd
40.5
13.6
16.3
12.9
43.7
127
500 bpd
116
23.5
24.8
36.0
67.5
268
2000 bpd
262
67.6
86.5
41.0
158
615
6500 bpd
510
176
269
47.5
379
1,300
00
I
30
Based on BAT controls.
Assumes lime neutralization of waste and on-site land storage with leachate
collection and treatment system.
[SIP-related capital costs 4- NSPS-related capital costs] x [NSPS-related
annualized costs].
Control alternatives I and VI.
-------
8.3.6 Regulatory Agency Manpower Requirements
States are required to adopt regulations for non-
criteria pollutants addressed in the Federal standards and
to obtain EPA approval of a plan to implement enforcement of
these regulations. State and local agencies will be re-.
sponsible for issuance of construction permits and for
compliance verification of new sources. These agencies will
be responsible for permits, compliance schedules, enforce-
ment, and compliance verification on existing sources. In
addition, agencies will provide periodically updated reports
on compliance status and legal matters relative to new and
existing sources.
In summary, regulation of sulfuric acid mist emissions
under an NSPS adds another pollutant to the list of those to
be regulated by state agencies. As a practical matter, it
is estimated that particulate matter and sulfur oxides
probably require 80 percent of an agency's resources current-
ly. It is further estimated that the remaining 20 percent
of their workload will be increased by less than 1/20,
giving an estimated net increase of 1 percent in the cost of
agency operations. Typical annual budgets for state air
programs range from $250,000 to $2 million. Therefore a
proposed NSPS for the formation facility in lead battery
plants may require an additional cost of $2500 to $20,000
for local agencies.
8-84
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8.4 ECONOMIC IMPACTOFCONTROL ALTERNATIVES
This section presents an assessment of economic
\
of alternative NSPS lead control systems and sulfuric acid
mist control. Integral to this assessment are the NSPS
compliance cost data developed in the technical analysis
(described in Section 8.2) and the industry economic conditions
discussed in Section 8.1 and in this section. The assessment
focuses only on incremental cost effects of the regulations
which include both sulfuric acid mist control and NSPS lead
particulate control. Th scope of the impact analysis if
limited to establishments engaged in manufacturing lead-acid
storage batteries.
The economic assessment includes an evaluation of the
impact of the proposed regularoty alternatives on industry
growth and prices. It considers potential impacts on the
operations of existing plants, categorized by size, product
mix, processes performed, age, and financial status.
As will be shown in the following pages, the incremental
cost impact of NSPS regulations on the lead-acid battery
industry as a whole will not cause significant economic
disruption. The more significant impacts are summarized
as follows:
8-85
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* Increased long-run prices on the order of 1 to 1.5
percent of the average value of battery shipments
are predicted.
* Industry volume is projected to grow throughout the
period of NSPS introduction at an average annual
growth rate of 3.5 percent or more per year. This
growth rate will not be significantly affected by
a pass-through of NSPS costs.
* Impacts on the lead-acid storage battery manufac-
turing industry are limited because of the general
lack of economically feasible alternative sources
(such as imports) or substitutes (alternative energy
sources) for the major battery use applications,
* No significant regional, community, or balance of
trade impacts are expected as a result of the NSPS
regulation.
* The impact of NSPS lead and sulfuric acid mist con-
trol on small plants (producing in the range of 100
batteries per day) will be substantial. Return on
investment will fall from 11 to 19 percentage points
and obtaining financing of control equipment will
be difficult. This impact is further aggravated
when compliance testing costs are also considered.
Although it is believed that the NSPS regulation in
itself will not have a significant effect on the projected
baseline conditions of the industry, the complete "package"
of governmental regulations, as discussed in Section 8.3,
probably will have significant impact. The cumulative cost
impact is estimated to be over 5 percent of the value of
shipments. The total cost increase may be higher, since a
number of these regulatory programs are not yet finalized.
8.4.1 Regulatory Alternatives
In response to the regulations analyzed here, the plant
managervwill generally have more than one control alternative
8-86
-------
available to meet them. Of these, some alternatives will
involve higher capital expenditure costs and thus higher
total unit costs than others.
Only impacts under Alternative I are reviewed in the
analysis of large plants. This alternative was selected
because control Alternative I has been determined in section
8.2 to be the best control technology for emission reduction.
For small plants control Alternatives VI and VII rep-
resent the best control technology for emission reduction.
Alternative VI was selected for analysis because it has
lower capital and annualized costs than alternative VII.
The basic economic analysis assumes that NSPS regula-
tions will impact in the following manner:
1. New sources will be subject to the regulations on
all facilities. Facilities will be considered reconstructed
and will be covered if "(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 facil-
ity and (2) it is technologically and economically feasible
to meet the applicable standards set forth...". With certain
exceptions, "any physical or operational change to an existing
facility which results in an increase in the emission rate to
the atmosphere of any pollutant to which a standard applies
shall be considered a modification..." and the facility will
come under NSPS.
2. Based on 1 above, it is assumed that expansion of
8-87
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any facility at an existing source will be subject to the
regulations, no matter how small the resulting increase in
capacity. This will result from the reconstruction and
modification provisions of the NSPS.
3. Technological improvements at existing sources,
whether or not they involve expansion of output capacity,
are subject to the NSPS reconstruction and/or modification
provisions, under conditions similar to those stated in
2 above.
4. Because of the NSPS definition of "facilities", it
is reasonable to assume that all replacement of major capital
items at existing plants will fall under NSPS, including cases
that involve neither expansion of capacity nor technical up-
grading. This is true because replacement would generally be
covered under reconstruction. Thus, all facilities at existing
plants that continue operations on a long-term basis will even-
tually fall under NSPS, except insofar as some equipment might
effectively be reconstructed through piecemeal expenditures on
maintenance and repair.
These assumptions governing interpretation of the regu-
lations have been formulated with the objective of portraying
cases having the greatest potential impacts,
The analysis of modified/reconstructed plants assumes
a "worst case" analysis, i.e., the replacement/reconstruction
of all affected facilities immediately after the promulgation
of the regulations. "Worst case" analysis is standard practice
8-88
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in NSPS economic impact assessments. x
8.4.1.1 Limitations of the Analysis
The socio-economic impact analysis in Section 8.4 is
subject to the following general limitations:
1. The analysis is based on publicly available informa-
tion, interviews with selected industry representatives and
information obtained in earlier EPA studies. No formal economic
survey of lead-acid battery plants was possible, therefore many
of the observations about industry conditions and trends are
based on qualitative information.
2. Although the analysis is designed to measure incre-
mental cost impacts, no attempt was made to survey existing
plants concerning specific SIP, water pollution control or
current OSHA requirements, or the current status of compliance
with these requirements. All SIP and current OSHA required
equipment is assumed to be in place.
8.4.2 MarketImpact of NSPS
8.4.2.1 Baseline Industry Expansion
As described earlier, shipments of lead-acid storage
battery units increased at an average annual rate of about
5 percent between 1968 and 1977. Although the industry should
experience steady growth, the future rate of growth is subject
to much speculation. Over-all growth estimates obtained from
plants responding to EPA inquiry (Section 114 Letters) range
from 40 to 120 percent through 1985. This is a projected
average annual rate of 3.5 to 8.2 percent. BCI agrees with
8-89
-------
the lower estimate. Responses to EPA's Section 114 Letters
indicate that nearly all growth would be realized through
expansion of existing larger plants (more than 2000 BPD capa-
city) .
The lead-acid battery industry is intimately tied to
the automobile industry, through both the original equipment
and replacement battery markets. As such, the industry is
strongly dependent on auto production for its economic via-
bility. Expanding auto sales not only stimulate current
production of lead-acid batteries, but also production 3 to
4 years in the future when previously purchased automobiles
are in need of a replacement battery. Current demand for
batteries is dependent on current and previously purchased
automobiles, i.e., current automobile sales, sales 3 to 4
years ago, and sales 6 to 8 years ago.
Most of the output expansion in the lead-acid storage
battery industry occurs through modifications and additions
to existing plants. The major mode of output expansion in
the lead-acid storage battery industry since the mid-1950's
has been expansion of existing plants in the 1200-4000 BPD
range. In late 1974, plants less than 10 years of age com-
prised only 22 percent of all establishments and accounted
for less than 20 percent of lead-acid battery capacity.
Larger new plants (with capacities of 1600 BPD or higher)
accounted for only 15 percent of estimated industry capacity.
X
By contrast, plants between 10 and 24 years old producing 1200
8-90
-------
available to meet them. Of these, some alternatives will
involve higher capital expenditure costs and thus higher
total unit costs than others.
Only impacts under Alternative I are reviewed in the
analysis of large plants. This alternative was selected
because control Alternative I has been determined in section
8.2 to be the best control technology for emission reduction.
For small plants control Alternatives VI and VII rep-
resent the best control technology for emission reduction.
Alternative VI was selected for analysis because it has
lower capital and annualized costs than alternative VII.
The basic economic analysis assumes that NSPS regula-
tions will impact in the following manner:
1. New sources will be subject to the regulations on
all facilities. Facilities will be considered reconstructed
and will be covered if "(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 facil-
ity and (2) it is technologically and economically feasible
to meet the applicable standards set forth...". With certain
exceptions, "any physical or operational change to an existing
facility which results in an increase in the emission rate to
the atmosphere of any pollutant to which a standard applies
shall be considered a mod i f i ca t ion..." and the facility will
come under NSPS.
2. Based on 1 above, it is assumed that expansion of
8-87
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any facility at an existing source will be subject to the
regulations, no matter how small the resulting increase in
capacity. This will result from the reconstruction and
modification provisions of the NSPS.
3. Technological improvements at existing sources,
whether or not they involve expansion of output capacity,
are subject to the NSPS reconstruction and/or modification
provisions, under conditions similar to those stated in
2 above.
4. Because of the NSPS definition of "facilities", it
is reasonable to assume that all replacement of major capital
items at existing plants will fall under NSPS, including cases
that involve neither expansion of capacity nor technical up-
grading. This is true because replacement would generally be
covered under reconstruction. Thus, all facilities at existing
plants that continue operations on a long-term basis will even-
tually fall under NSPS, except insofar as some equipment might
effectively be reconstructed through piecemeal expenditures on
maintenance and repair.
These assumptions governing interpretation of the regu-
lations have been formulated with the objective of portraying
cases having the greatest potential impacts.
The analysis of modified/reconstructed plants assumes
a "worst case" analysis, i.e., the replacement/reconstruction
of all affected facilities immediately after the promulgation
of the regulations. "Worst case" analysis is standard practice
-------
to 4000 BPD accounted for about 37 percent of estimated
32
capacity .
8.4.2.2 Control Costs
The regulatory alternatives under consideration for the
lead-acid battery manufacturing industry include acid mist
controls on the dry formation process. If a standard is
promulgated for acid mist emissions under Section 111(b) of the
Clean Air Act, States would be required to develop standards
for acid mist emissions from existing formation processes. In
addition, existing plants would be required to meet the NSPS
for any facilities which are newly constructed, modified, or
reconstructed.
Table 8.51 presents the annual sulfuric acid mist con-
trol cost for large existing plants and the cost per battery
at capacity and at an 80% operating rate. Capacity is battery
production per day multiplied by the number of annual working
days (250 working days/year is used). The operating rate is
defined as actual production divided by capacity production.
Table 8.51
SULFURIC ACID CONTROL COSTS - EXISTING PLANT
WET/DRY OR DRY FORMING
(In Thousand of Dollars)
500 BPD 2000 BPD 6500 BPD
Annual Cost $23.1 $74.9 $123.0
Cost Per Battery
at Capacity $.184 $ .15 $ .077
Cost Per Battery
at 80% Capacity $ .23 $.187 $ .096
8-91
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Table 8.52 shows the annual sulfuric acid mist control
and lead NSPG control costs for plants at capacity and at
80% of capacity, if all plants were to replace their affec-
ted facilities or to fall under the reconstructed/modified
clause immediately after promulgation of the standard,
Table 8.52
INCREMENTAL ANNUAL SULFURIC ACID MIST AND LEAD NSPS CONTROL COSTS
RECONSTRUCTED/MODIFIED PLANT - CONTROL ALTERNATIVE I
(In Thousand of Dollars)
500 BPD 2000 BPD 6500 BPD
Annual Cost $76.7 $192,9 $428.0
Cost Per Battery
at Capacity $ .61 $ .385 $ .261
Cost Per Battery
at 80% Capacity $.767 $ .482 $ .329
Table 8.53 presents the annual control costs for new
plants.
Table 8.53
INCREMENTAL ANNUAL SULFURIC ACID MIST AND LEAD NSPS CONTROL COSTS
NEW PLANT - CONTROL ALTERNATIVE. I
(In Thousand of Dollars)
500 BPD 2000 BPD 6500 BPD
Annual Cost $70.6 $182.9 $407.0
Cost Per Battery
at Capacity $ .56 $ .365 $ .25
Cost Per Battery
at 80% Capacity $.706 $ .456 $ .31
8-92
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8.4.2.3 Demand Conditions s
No quantitative studies of the price elasticity of
demand for batteries have been identified during this analysis.
Price elasticity of demand is defined as the percent change in
sales divided by the corresponding percent price change, and
determines the quantitative effect on sales from a change in
the price charged for a battery.
Batteries are purchased for replacement of existing
batteries and for inclusion in original equipment. In the
replacement market the price elasticity of demand for a com-
modity is determined by the availability of good substitutes
for the product, the number of uses to which the product can
be put, and the price of the commodity relative to consumer
incomes. In the original equipment market, a battery is not
purchased per se, but is purchased as part of a larger product
(such as an automobile, golf cart or industrial equipment). The
elasticity of price demand in this case is determined by the
availability of good substitutes for the battery in its use
in the final product, the price elasticity of demand for the
final product and the ratio of the cost of the battery to the
total cost of the product of which it is a part. The smaller
the number of good substitutes, the smaller the number of uses
to which the product can be put, and the smaller the price of
the product relative to consumer's income, the lower is the
elasticity of demand for the product.
R-93
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By the same reasoning the smaller the ratio of the
battery's cost to the total cost of the final product of
which it is part and the lower the price elasticity of the
final product,- the more inelastic is the demand for the pro-
duct. Of these factors the availability of adequate substi-
tutes is the most important to price elasticity. In the
automobile industry, the major market for lead-acid batter-
ies, there is currently no adequate substitute for the bat-
tery, either in its original, new car application or in its
battery replacement application. While there are some poten-
tial substitutes, these have not as yet proved generally
feasible for use. In fact research is being conducted on the
development of lead-acid battery powered electric vehicles.
The cost of a battery relative to the total cost of the
final product of which it is part is small; e.g. at $40 per
battery, the battery price is only .8% of the price of a
$5,000 car. If the battery price should double, the price
of a car would only increase 0.8%. For these reasons the
price elasticity of demand for lead-acid batteries is likely
to be inelastic, i.e. a change in price brings about a less-
than-proportionate change in sales.
On the whole, when the original equipment and replace-
ment markets are considered together, the price elasticity
of demand for lead-acid batteries is likely to be inelastic.
The effect of this is that the industry as a whole can pass
through the control cost with little effect on sales volume.
5-94
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However, some smaller plants will not be able to capture all of
the cost because they will be competing in the same market as
larger plants whose control costs are lower on a per battery
basis. For example, while the 6500 BPD plant may be able to
recapture all of its control costs, the 2000 BPD plant will be
able to capture only a portion of its control costs (the same
amount as the larger producer is passing through) in some
markets, e.g., the large retail accounts. In those markets
where it is shipping to distributors and his competition is
similar or smaller size plants, the 2000 BPD plant will be able
to pass through the entire cost per battery. The 500 BPD plant
will be constrained in the same manner as the smaller plants
considered in Section 8.4.4.
.•**"
8.4.2.4 Price Effects
Long-Run Market Price Response to NSPS
The long-run increase in battery prices resulting from
NSPS will be determined by the total incremental unit costs
applicable to newly built, economically efficient, production
units entering the industry. Over the long-run, industry
output can be maintained only through the construction of
entirely new plants. The entry and retirement of lead-acid
battery plants historically has proceeded at a very slow pace;
this long-run adjustment of facilities and operations could
take 20 years or more. Over an horizon of 5 to 10 years,
8-95
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adjustment of output will be accomplished primarily by modi-
fications and expansions of existing plants that are, or can
become, economically efficient. Since battery production is
dominated by the 2000 BPD and larger plants, and since the cost
pass-through of smaller plants will be constrained, the medium
long-term market price increase will probably be in the $.30
to $.40 price per battery range. This represents from 1.6%
to 2.2% of the estimated 1976 manufacturer's price of approx-
imately $18 per auto battery and about 1 to 1.5% of auto
battery prices at retail.*
Short-Run Responseof Market Price to NSPS
In the short-run, existing battery plants will have to
meet only the sulfuric acid mist control standard. The rela-
tively minor long-term battery price increase resulting from
NSPS should be mitigated by the gradual pace at which the
regulations will become effective. Since the regulations
affect existing plants only insofar as they expand, modernize,
or replace major equipment items, operating costs will not
increase at these plants (as a result of NSPS) until they
undertake such investments. Over time, the number and output
of plants that have not expanded and replaced equipment will
steadily decline. Many of the plants that make replacements
will do so on a facility-by-facility basis and thus will incur
the incremental NSPS costs gradually. The full price increase
attributable to NSPS should become effective only when the
*Estimate obtained from those plants responding to EPA inquiry
(Section 114 letters}.
8-96 "
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total potential output from (a) plants that have not made
replacements or expansions in all of their facilities, and
(b) new fully reconstructed plants is insufficient to meet
the expanding demand for batteries.
8.4.2.5 Growth Effects
The impact on industry growth should not be significant.
The 1 to 1.5% increase in price at retail will be effected
over a number of years. In the original equipment market
the demand for batteries should show little or no decrease
and will continue to be primarily dependent on the cyclical
nature of the auto industry. In the replacement market de-
mand may be more sensitive to price. Any decrease in smaller
company production will be accomodated by expanded production
from larger companies. In this way the control costs can be
spread over an even larger production. An increase of 1 to
1.5% in the price of a battery will not stimulate faster
research into alternative products to the lead-acid battery
and it should remain the only feasible product in its many
applications for the foreseeable future.
8.4.3 Other Costs
Although the NSPS regulations alone should have a rela-
tively minor impact on battery industry prices and output,
their implications are more serious when considered as part
of a package of government regulations. The industry either
recently has, or shortly will, incur significant additional
capital and operating expenditures due to water pollution
8-97
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control, solid waste disposal, new OSHA regulations and lead
ambient air regulations. As these expenditures (which generally
neither increase output nor reduce manufacturing costs) wi-11
all be required of the industry within a few years, the major
adverse impacts arising from their cumulative force will be
difficult to assess in terms of the individual regulatory
components.
The overall impact of these regulations on the industry
is likely to be significant. Cumulative annual costs of BAT
water pollution costs and solid wastes costs, as shown in
Table 8.50 for the 2000 BPD plant, represent 3.1 percent of
the estimated 1976 manufacturer's price of $18. Cumulative
costs will be significantly higher at plants where current
OSHA and SIP regulations are not. now being met.
8.4.4 Impact on Small Plants
8.4.4.1 Introduction
As noted earlier in section 8.1, approximately 50 per-
cent of the plants in the lead-acid battery industry produce
fewer than 500 BPD. Because small plants are such a large
portion of the industry and because small plants are generally
affected more severely than large firms, two small plant sizes
have been selected, 100 BPD and 250 BPD, for a detailed analy-
sis of the economic impact of both the sulfuric acid mist
control costs and the incremental NSPS lead control costs.
/Small lead acid battery plants have a number of pro-
duction and marketing characteristics which distinguish them
8-98
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from larger battery producers. Most of these smaller plants
have all of the production capabilities of the larger firms
with the exception of lead oxide production and lead recla-
mation; i.e., these firms have parts casters, grid casters,
paste mixers, three process (3-P) operation and formation
capability. These firms will be referred to here as "manufac-
turers". A smaller segment (approximately 31 plants) produces
lead acid batteries without the capability of producing and
pasting grids. These firms, referred to here as "assemblers",
generally have only the 3-P and formation capability. In effect
the assemblers purchase all of the parts required for a battery
and assemble them into a finished battery.
Another distinguishing characteristic of the small
battery producers is the manner in which they form (charge)
batteries. There are two processes available for forming
the battery: wet formation and dry formation. Few, if any,
small plants are dry forming all of their batteries. Most
plants which have dry formation also have wet formation capa-
bility. The majority of plants have only wet formation capa-
bility.
Most independent small firms are one-plant operations
and specialize in producing either Starting, Lighting and
Ignition (SLI) batteries or industrial batteries, though
some plants either allot a small amount of production or
purchase for resale the type in whose production they are
8-99
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not specializing. Both SLI and industrial batteries are avail-
able in numerous sizes, and industrial batteries are generally
larger than SLI batteries. The production processes required
to produce SLI and industrial batteries are the same. There
are only slight differences in the major pieces of necessary
equipment. The distinguishing characteristic is the size of
the plates. Industrial batteries require larger plates which
are produced by using larger grid casting molds on the casting
machine. The amount of paste on the plate may also be greater
on some industrial batteries. In some cases industrial bat-
teries are custom-made to meet the client demand and, in such
cases, the small firm will also typically service the batteries
after sale. The majority of small plants, however, specialize
in the production of SLI batteries.
Although the small plants serve several markets, their
major market segments are large and small fleet accounts such
as bus and truck companies and local government. Sales are
also made to warehouse distributors and to off-the-street
customers. Different markups are applied to each market
segment.
As was seen in Section 8.4.2.4, the average battery price
of large producers taken from Section 114 letters was $18 per
battery. For small producers the average price used in the
calculations which follow is $27. This difference in price
is probably explained in the lower production costs of large
manufacturers and the fact that smaller plants can receive
8-100
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larger .markups because of the markets they serve. Battery
•distribution is generally performed only regionally and trans-
portation costs prohibit a plant from distributing to larger
geographical markets. Small plants deliver to accounts higher
up in the marketing chain and deliver directly to their clients
so that they receive the entire markup applied to these market
segments.
Most industry representatives do not forecast construc-
tion of new small plants. Demand will be accommodated from
existing plants which replace their facilities. For this
reason the economic impact discussion which follows is based
on those plants which will reconstruct/modify their existing
facilities. Replacement of existing facilities will consti-
tute a reconstruction.
8.4.4.2 Methodology
This section will describe the general methodology
used to measure the economic impact on small plants.
The economic impact is evaluated by developing model
plants based on representative characteristics of small lead
acid battery producers. As will be seen, these characteris-
tics include production capabilities, asset size and other
financial characteristics. The models do not represent any
particular firm as any individual firm will differ in one or
more o£ these characteristics. The models are meant to pro-
vide an indication of the degree of impact on all firms by
incorporatincj in the model the major charcteristics prevail-
ing in this segment of the industry.
8-101
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Eight model plants are considered here as follows:
each of the two model size plants, 100 BPD and 250 BPD,
are distinguished by two production capabilities, manufac-
turing and assembling. A further distinction is made on
the basis of the formation capability, i.e., whether the
batteries are formed wet or both wet and dry. Dry forma-
tion alone is not included because no small plant using
dry formation only was identified in field investigations
and during interviews with industry representatives.
These distinctions, in addition to plant size, are
included in the analysis for two reasons;
• Costs associated with NSPS lead control* will
differ between manufacturers and assemblers.
* Costs associated with sulfuric acid mist control
will differ between wet and dry forming plants.
Since assemblers do not have casting and pasting capa-
bility, no incremental lead control costs are imposed on
them for these processes and the economic impact differs
between assemblers and manufacturers. Since control costs
for sulfuric acid mist will be imposed primarily on dry
forming plants,** control costs are higher for these plants
*Lead control costs are incremental control costs, i.e.,
costs over and above that required for meeting SIP.
**The recommended standards for formation operations are
written for "any formation process which forms before the
battery is completely assembled (including installation
of battery filler cups) or which forms over a period of
less th'an 24 hours". Most wet formation processes will
occur in a period over 24 hours.
8-102
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and, therefore, the economic impact will differ between plants
on this account.
The regulatory alternatives under consideration for
the lead-acid battery industry include acid mist controls
on the dry formation process. Should a standard be promulgated
for acid mist emissions under section lll(b) of the Clean Air
Act, States would be required to develop standards for acid
mist emissions from existing formation processes.
For this reason sulfuric acid mist control costs are analyzed
individually on existing plants. They are also analyzed with
lead NSPS control costs on reconstructed/modified plants be-
cause reconstructed/modified plants will also have to meet
sulfuric acid mist control in the aosence of a specific NSPS
for sulfuric acid.
The first step in the analysis requires establishing
the total assets of each size plant before the imposition
of sulfuric acid mist or lead controls. This result provides
"baseline" conditions upon which the return on investment
(ROI)* is calculated. Total assets will consist of fixed
assets after depreciation and current assets.
*Defined as (Earnings Before Tax)/(Total Assets); the
ROI indicates the investment efficiency of the plant,
a-103
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The second step estimates the current earnings and
profit rate for both manufacturers and assemblers in each
of the selected size plants before imposition of the incre-
mental control coats. This procedure is necessary in order
to be able to measure the effect of the incremental control
costs on earning and, therefore, ROI and the ability of the
firm to finance these costs.
The next step uses the total assets from step 1, earn-
ings level from step 2 and the control costs developed in
Section 8.2 to determine the ROI before and after incremen-
tal control costs are required. This ROI analysis has been
conducted for three different scenarios:
• For existing wet/dry forming plants from sulfuric
acid mist control alone.
* Lead and sulfuric acid mist control for wet/dry
forming reconstructed/modified plants who would
be replacing all of their facilities immediately.
• Lead control for wet forming reconstructed/modi-
fied plants who would be replacing all of their
facilities immediately.
In order to complete this analysis, attention has been
given to the fraction of the increase in cost of production
due to controls that could be recouped through increased
prices (cost pass-through) and the amount that would have
to be absorbed. The manner in which the cost pass-through
was derived is explained in section 8.4.4.5.
8-104
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The final step involves the evaluation of the capa-
/
bility of firms to finance the control equipment which is
needed to meet the standard. This capability is estimated
for two scenarios, a "worst case" situation where no control
cost could be passed through, and where a portion of the cost
as established in the preceding step could be passed through.
This financing capability is based on determining the debt
coverage* for each firm after incremental control costs are
imposed, i.e., the ability of.their annual cash flow** to
support repayment of control equipment debt in addition to
existing debt repayment.
8.4.4.3 Baseline Economics
Table 8.54 shows the total assets of existing lead-acid
battery manufacturing and assembling plants forming by both the
wet and dry process. Fixed investment consists of the equip-
ment, land and building required for production in each size
and type of plant in addition to OSHA and SIP control equipment.
Current values for equipment and building were deflated to 1967
values by use of the Chemical Engineering equipment arid machin-
ery index and the Engineering News-Record building index, res-
pectively, to develop historical equipment and building costs.
*Defined as (Annual Cash Flow)/(Annual Debt Repayment).
**The term cash flow is used as an abbreviation for "net funds
inflow from operations". Since we are using earnings before
interest and taxes it is not comparable to the traditional
use of the term cash flow which is computed by adding depre-
ciation to net earnings without adding back interest expense,
8-10B
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Table 8.54
BASELINE ECONOMICS
CAPITAL INVESTMENT FOR EXISTING LEAD-ACID BATTERY PLANTS
WET
(In
AND DRY
FORMATION
Thousand of Dollars)
Manufacturing
100 BPD 250 BPD
Fixed Investment
Casting
Pasting
3-P Process
Formation
Land
Building
Other Fixed Investment
OSHA
SIP - particulates
Total Fixed Investment
Accumulated Depreciation^-
Fixed Investment After
Depreciation
Current Assets2
Total Assets Before
Control
$ 15.0
6.7
10.0
12.5
15.0
68.6
23,3
35.0
$186.1
54.1
132.0
132.0
$264.0
$ 24.5
10.0
11.6
17.5
20.0
101.8
26.0
35.0
246.4
77.1
169.3
169.3
$338.6
Assembling
100 BPD
$
10.0
12.5
15.0
60,0
15.8
113.3
32.0
81.3
81.3
$162.6
250 BPD
$
11.6
17.5
10.0
98.3
15.4
152.8
46.0
106.8
106.8
$213.6
^-Building at .25 ; process equipment at .66; OSHA, SIP at .133.
2At 100% of fixed investment after depreciation.
8-106
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Deflation of equipment and building values was necessary because
existing plants whose facilities had been purchased in the past
were analyzed and current depreciation is dependent on this
historical purchase price. Accumulated depreciation was subtrac-
ted to derive fixed investment after depreciation. Accumulated
depreciation is based on process equipment being depreciated
by 66%, building by 251 and OSHA and SIP equipment by 13.3%.
Only the major pieces of equipment were included in the asset
base. The process equipment in this industry has a long useful
life span, 25 to 30 years or more.
Many plants visited had fully depreciated their equipment
while others had newer equipment, i.e., less than 10 years old.
The average age of equipment was taken to be 10 years old and
depreciated at 6.6% per year to yield accumulated depreciation
of 66%. The age of the building tends to vary greatly from
plant to plant and the 25% rate, used as representative of the
industry, is based on a 10 year old building being depreciated
at 2.5% per year. OSHA and SIP control equipment is assumed to
have been put in place two years ago so that with a useful life
of 15 years 13.3% of the cost is depreciated.
In the ROI analysis that follows, RQI before control
appears high relative to other industries. This stems from
two factors: the first is characteristic of the industry,
the second is dependent on the manner in which models are
constructed. Small plant production is labor intensive rela-
tive to the amount of capital required for production. This
8-107
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labor intensity can be shown by the labor cost per battery
relative to depreciation cost per battery. Figures which
were developed during this analysis show a relationship of
labor cost to capital cost per battery of approximately 10
to 1, Even if capital costs were doubled so that a 5 to 1
ratio prevailed this would still indicate labor intensity.
Because of the high value added by labor, ROI will tend to
be high relative to industries where larger capital require-
ments are necessary for production. The second reason for
these seemingly high ROI figures arises from the small total
asset base (ROI = net earnings/total assets) which was used.
Our model asset parameters include only the major pieces
of equipment and plant required for production. Ancillary
equipment such as fork lift trucks, delivery .trucks, office
furniture, and minor pieces of equipment such as a number
of different sized casting molds were excluded. Also exclu-
ded were additional warehouse space which a number of larger
small plants have in different locations. For these reasons
the asset base is low and the ROI developed is high relative
to what would be shown if a complete inventory of fixed assets
were included. This qualification does not negate the impact
which will be shown in the following analysis,
In order to derive total assets, current assets had to
be added to fixed assets after depreciation. Current assets
are based on 100% of fixed assets after depreciation. While
-------
this rate cannot be as fully substantiated as the other rates,
one firm visited has current assets of 135% of fixed assets
after depreciation but the building was carried as a personal
asset of the owner.
Table 8.55 shows the baseline economics for plants with
only wet formation capability and is constructed in the same
manner as Table 8.54. The principal difference in Table 8.55
from Table 8.54 is fixed investment in formation equipment.
Wet forming requires less investment in equipment than wet
and dry forming together. Accumulated depreciation is there-
fore changed as are current assets. The total assets before
control for wet forming plants is shown in the last row of
Table 8.55. Both current OSHA and SIP investment costs are
assumed fully in place and are included in the total asset
base.
8.4,4.4 Estimated JSarnings Before Control
Tables 8.56 and 8,5? indicate, for manufacturing and
assembling plants, respectively, the estimated earnings before,
imposition of sulfuric acid mist and lead incremental control
costs. In these tables, revenue is based on an operating rate
of 80% and a battery price of $27. The operating rate is based
on information supplied through interviews with plant owners,
and varies from 50 to 100%. The battery price is calculated
from a price list of 23 types of SLI batteries supplied by a
firm to different market segments such as warehouses, fleets
and off-the-street sales. Since prices vary by market segment
8-109
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Table 8.55
BASELINE ECONOMICS
CAPITAL INVESTMENT FOR EXISTING LEAD-ACIDBATTERY PLANTS
WET FORMATION OMLY
(In Thousand of Dollars)
Manufacturing Assembling
100 BPD 250 BPD 100 BPD 250 BPD
Fixed Investment
Casting $ 15.0 $ 24.5 $ - - $ -
Pasting 6.7 10.0
3-P Process 10.0 11.6 10.0 11.6
Formation 5.0 7.5 5.0 7.5
Land 15.0 20.0 15.0 20.0
Building 68.5 106.8 60.0 98.3
Other Fixed Investment
OSHA 23.3 26.0 15.8 15.4
SIP - particulates 35.0 35.0 ^_ ^
Total Fixed Investment $178.5 241.4 105.8 152.8
Accumulated Depreciation1 49.3 60.1 26.0 39.2
Fixed Investment After
Depreciation 129.2 181.3 79.8 113.6
Current Assets2 129.2 181.3 79.8 113.6
Total Assets Before
Control $258.4 $362.6 $159.6 $227.2
^Building at .25; process equipment at .b6 ; OSHA, SIP at .133.
100% of fixed investment after depreciation.
/
tf-110
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Table 8.56
ESTIMATED FINANCIAL DATA
for
SMALL LEAD-ACID BATTERY MANUFACTURING PLANTS1
BEFORE NSPS LEAD AND SULFURIC ACID MIST CONTROLS
Model Plant Size
Revenue^
Operating Expenses
Earnings Before Taxes
Earnings Rate Before Taxes
Taxes3
Earnings After Taxes
Earnings Rate After Taxes
100 BPD
$540,000
$470,400
$ 69, 600
12.9%
$ 20,400
$ 49,200
9.1%
250 BPD
$1,350,000
$1,168,500
$ 181,500
13.4%
$ 74,100
$ 107,400
8.0%
Wet and Wet/Dry Formation.
2Based on operating rate of 80% and battery price of $27.00
per battery.
Calculated at 22% of first $50,000 and 48% on remainder of
earnings before taxes rather than at official rate of 20% of
first $25,000, 22% of next $25,000 and 48% of remainder over
$50,000.
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Table 8.57
ESTIMATED FINANCIAL DATA
for
SMALL LEAD-ACID BATTERY ASSEMBLING PLANTS*
BEFORE NSPS LEAD AND SULFURIC ACID MIST CONTROLS
Model Plant Size
100 BPD 250 BPD
Revenue2 $540,000 $1,350,000
Operating Expenses $487,400 $1,215,500
Earnings Before Taxes $ 52,600 $ 134,500
Earnings Rate Before Taxes 9.7% 10.0%
Taxes3 $ 12,200 $ 51,600
Earnings After Taxes $ 40,400 $ 82,900
Earnings Rate After Taxes 7.5% 6.1%
Ip'or Wet and Wet/Dry Formation.
2eased on operating rate of 80% and battery price of $27.00
per battery. <>
3Calculated at 22% of first $50,000 and 48% on remainder of V
earnings before taxes rather than at official rate of 20% ol ^
first $25,000, 22% of next $25,000 and 48% of remainder over
$50,000.
8-112
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due to the discount/markup structure, an average pricfe for
different types of batteries sold to each market segment was
developed. This price was then weighted by the corresponding
share of the market segment to derive a weighted average price
of SLl batteries for small plants.
Operating expenses have been calculated from information
supplied at various interviews. Cost of production is derived
from data such as the amount of lead necesary for each part,
miscellaneous supplies such as battery cases, labor manhours
per battery and wage rates provided during interviews. Deli-
very and utility costs are included and plant and equipment
depreciation determined from the baseline economics. Plant
was depreciated at the rate of 2.5% per year and equipment
at 6.6% per year. An overhead charge of 40% of labor cost
is also included. Earnings before taxes is the difference
between revenue and operating expenses. Applicable Federal
tax rates are used to derive earnings after taxes. The per- ,
cent earnings before tax are in the range of 8 to 15% which
are supported by data obtained during field interviews.
8 .4 .4 .'5 Return on Investment (ROI) Impact
As discussed in Section 8.4.4.1 sulfuric acid mist con-
tr'dl will affect all plants doing any dry forming of batteries,
Table 8.58 shows the decline in ROI from sulfuric acid mist
control on those small plants doing a combination of wet and
dry forming. Data included in Table 8.58 are derived as fol-
lows: Earnings before tax is taken from Tables 8.56 and 8.57
8-113 '
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Table 8.58
RETURN ON INVESTMENT IMPACT
SMALL LEAD-ACID BATTERY PLANTS
COS7 PASS-THROUGH -
(In Thousand of Dollars)
Type of Plant
Type of Formation
Type of Control
Existing
Wet and Dry
Sulfuric Acid Mist
Manufacturing
Assembling
Earnings Before Tax
Total Assets
R_OI_ Before Control
Total Annualized Control
Cost
Control Cost Per Battery^
Cost Pass Through
Earnings Before Tax and
After Control2 $ 65.8
Total Assets After Control $278.4
ROI After Control 23.6%
100
$ 69
$264
26
$ 9
$
$
BPD
.6
.0
.4%
.0
.45
.26
250
$181
$338
53
$ 14
S
$
BPD
.5
.6
.5%
.7
,29
.26
100
$ 52
$162
32
$ 9
$
$
BPD
.6
.6
.3%
.0
.45
.26
250
$134
$213
62
$ 14
$
$
BPD
.5
.6
.9%
.7
.29
.26
$180.0 $ 48.8 $133.0
$368.6 $177.0 $243.6
48.8% 27.6% 54.6%
80% operating rate.
total annualized control cost absorbed subtracted.
8-11*
-------
and total assets from Table 8.54. The annual sulfuric acid
mist control cost Is taken from Table 8.43 and is divided by
the number of batteries produced at an 80% operating rate
(250 working days per year is used in calculating annual
production) to yield control cost per battery. The cost
pass-through per battery, which will be developed further
below, is determined in Table 8.59.
Earnings before tax and after control is determined
by subtracting total annualized control cost absorbed fron
earnings before control. In the case of the 100 BPD manu-
facturer, $0.19 per battery is absorbed ($0.45-$0.26) or
$3,800 so that earnings before control is reduced by $3,800
($65,800 = $69,600 - $3,800).
Table 8.59 presents the derivation of the cost pass-
through of $0.26 per battery after sulfuric acid mist con-
trols. Because there are few adequate substitutes for lead-
acid batteries in the SLI category, the industry as a whole
should be able to pass on part or all of the control cost
which it has to incur without a significant impact to its
earnings potential. However, the smaller operations must
compete with larger companies in various markets. Because
control cost is lower for larger producers the staall opera-
tors cannot pass on the entire amount of their cost increase
without incurring losses in their market segments.
Table 8.51 in Section 8.4.2.2 showed the sulfuric acid
mist control cost per battery at capacity and at an 80% oper-
ating rate for the 50C, 2000 and 6500 BPD manufacturer. The
•"8-115
-------
Table 8.59
COST PASS-THROUGH PER BATTERY
SULFURIC ACID MIST CONTROL ONLY
EXISTING PLANTS
Description
£l
Market
Large Plant
Price
Increase
Markup With
Respect to
Warehouse f
Charged by
Small Plant
Distribution
of Small
Plant Sales
By Market
Partial Pass
Through
By Market
* Warehouse
$.20
* Large Fleets .20
Small Fleets .20
1.25
1.33
$.02
.10
.11
* Off-the-Street
Retail .20
1.45
.03
Total AverageCost PassThrough per Battery
$.26
-------
main cost pass-through restraint"to the small producer is taken
to be the manufacturer in the 2000 BPD area. The 6500'BPD
operator is generally selling to the large OEM markets and to
large retail accounts. A $.20 per battery cost pass-through
is assumed which is slightly larger than the 2000 BPD operator's
at an 80% operating rate.
The major market for the smaller battery companies,
including the 500 BPD operator, are fleet accounts. In this
market, the small plants are faced with competition from the
larger producers, i.e., through warehouse distributors who
handle the larger companies' batteries and market them to
fleet accounts. Therefore the control cost which the larger
producers incur is inflated in the battery price to fleet
accounts by the distributors* markup. Although price compe-
tition prevails, there are significant non-price reasons,
(such as faster delivery time, better credit arrangements
and ability to service the batteries) for the fleet account's
preference for the small plant.
The small firms can then pass through $.20 per battery
to their lowest price client, which is the warehouse. But
since the ^market share to this market is only 10% of produc-
tion, the control cost captured is only $.02 per battery taken
*s
ov.er all production. The market shares are meant to represent
the model plant's distribution of sales to various market
segments. As can be seen the bulk of sales is to the fleet
accounts. From the warehouse price the small plant will
ft-117
-------
generally markup his price 25% to large fleet accounts or
$0.25. Therefore, with 40% of sales going to this account
$0.10 per battery of the control cost is captured taken over
all production.
With these various market shares and markups, the small
operator can recapture an estimated $0.26 of the $0.45 per
battery control cost.
The 100 BPD manufacturer and assembler must therefore
absorb $0.19 per battery of the sulfuric acid mist control
cost and the 250 BPD manufacturer and assembler $0.03 per
battery. Table 8.58 shows that ROI declines after control.
For both manufacturer and asembler this decline is not sub-
stantial with sulfuric acid mist control alone.
Table 8.60 shows the ROI impact of both sulfuric acid
mist control and NSPS lead control if the operators replace
all of the affected facilities immediately after the stan-
dards are promulgated. The total assets with new investment
are determined from Table 8.54 by adding total assets before
control to new investment in process equipment. Mew invest-
ment cost is based on the current market price of the process
equipment for the affected facilities: casting, pasting, three
process (3-P) operation, and formation. The annual control cost
is taken from Table 8-38, Alternative Vi for lead and Ta81ev
8-43 for sulfuric acid mist control.
The combination of NSPS lead and sulfuric acid mist
/
control costs increase the control cost per battery substan-
tially from sulfuric acid mist control alone. The cost pass-
8-118
-------
Table 8.60
RETURN ON INVESTMENT IMPACT
SHALL LEAD-ACID BATTERY PLANTS
COST PASS-THROUGH
(In Thousand of Dollars)
Type of Plant
Type of Formation
Type of Control
Reconstructed/Modified
Wet and Dry
Sulfuric Acid Mist and NSPS Lead
Manufacturing
As_sembl ing
Earnings Before Tax
Total Assets
ROI Before Control
Total Annualized Control
Cost
Control Cost Per Battery1
Cost Pass Through
Earnings Before Tax and
After Control2
Total Assets After Control $474.0
ROI After Control
100
$
$3
$
$
$
$
69
52
19
41
2
33
$474
7
BPD
.6
.6
.7%
.8
.09
.574
.4
.0
.0%
250
$181
$4
$
$
$
$1
65
39
49
52
$609
25
BPD
.5
.9
.0%
.6
.99
.574
.2
.9
.0%
100
$
52
$207
$
$
$
$
$3
25
40
2
20
24
6
BPD
.6
.7
.3%
.2
.01
.574
.9
.1
.4%
250
$134
$271
$
$
$
49
47
$111
$409
27
BPD
.5
.9
.5%
.7
.95
.574
.8
.9
.2%
80% operating rate.
2After control cost absorbed and equipment depreciation subtracted.
8-119
-------
through per battery under this condition, calculated in Table
8.61, is taken from Table 8.52 and is slightly above the cost
per battery for the 2000 BPD plant at an 80%- operating rate.
The manner in which effective cost pass-through is determined
in Table 8.61 is the same as that used above in Table 8.59,
i.e., by market-segment analysis. The cost pass-through for
Table 8.61 is used in Table 8.60 to calculate earnings impact
after controls due to absorbed costs. The ROI declines for all
situations analyzed in Table 8.60 for NSPS lead and sulfuric
acid mist controls taken together show a range of from 12 to
22 percent.
Table 8.62 indicates the ROI impact on small plants
forming batteries by the wet process only. These plants would
incur only NSPS lead control. Annual control cost in Table
8.62 is taken from Table 8.38. Other entries are derived in
a manner similar to that described above for Tables 8.58 and
8.60. Immediate replacement of all of their affected facili-
ties after the initiation of the standard would decrease the
ROI by 10 to 11 percentage points for manufacturers and by 16
to 17 percentage points for assemblers.
As Table 8.58 indicates, all existing wet/dry forming
plants should be able to meet the sulfuric acid mist control
standard without incurring severe economic impacts. Declines
in ROI range from 3 to 3 percentage points and the resulting
ROI after control is sufficiently high relative to alterna-
tive investment opportunities to permit continued operation
in the industry.
8-120
-------
Table 8.61
COST PAgS-'fl-mOUGH PER BATTERY
SULFURIC ACID MIST AND NSPS LEAD CONTROLS
EXISTING PLANTS
Markup With
Description
of
Market
Large Plant
Price
Increase
Respect to
Warehouse ,
Charged by
Small Plant
Distribution
of Small
Plant Sales
By Market
Partial Pass
Through
By Market
• Warehouse
S.45
* Large Fleets .45
• Small Fleets
,45
* Off-the-Street
Retail .45
1.25
1.33
1.45
.1
.4
.4
.1
$.045
.225
.239
.065
Total Average Cost Pass Through per Battery
$.574
8-121
-------
Table 3.62
RETURN ON INVESTMENT IMPACT
SMALL LEAD-ACID BATTERY PLANTS
COST PASS-THROUGH
(In Thousand of Dollars)
Type ofPlant Reconstructed/Modified
Type_of Formation Wet
of Control NSPS Lead
Manufacturing Assembling
100 BPD 250 BPD 100BPD 250 BPD
Earnings Before Tax $ 69.6 $181.5 $ 52.6 $134.5
Total Assets $332.0 , $469.9 $189.7 $265.5
ROI Before Control 21.0% 38.6% 2?1?% • 50.7%
Total Annualized Control
Cost $ 32.8 $ 34.9 $ 31.2 $ 33.0
Control Cost Per Battery! $ 1.64 $ .70 $ 1.56 $ .66
Cost Pass Through $ .574 $ .574 $ .574 $ .574
Earnings Before Tax and
After Control2 $ 43.4 $168.0 $ 30,9 $127.6
Total Assets After Control $439.0 $583.9 $291.7 $373.5
ROI After Control 9.9% 28.7% 10.5% 34.1%
80% operating rate.
control cost absorbed and equipment depreciation subtracted.
8-122
-------
Although most small plants are using only the wet forming
process, there will be certain cases where a wet forming small
plant is competing in the same area as a wet/dry forming small
plant. In this case the wet forming plant will have a competi-
tive advantage over the wet/dry forming plant.
The wet/dry forming plant operator may have to decide
whether to completely absorb the contol cost or to discontinue
dry forming. To completely absorb the control cost will de-
crease ROI another 2.0%, from 23.6% to 21.7% for the 100 BPD
manufacturer. Since dry forming is likely to be a minor por-
tion of battery production,* the more likely alternative may
be to discontinue dry forming production.
8.4.4.6 Control Equipment Financing Capability
This section presents an analysis of the potential
ability of plants to obtain financing for the required control
equipment necessary to meet the standards. The analysis is
based on the debt coverage ratio which shows the ability of
annual cash flows to repay existing and new debt incurred.
Debt coverage is an objective means of determining a firm's
ability to repay a loan, but financial institutions also look
at management capability, long-term relationship between the
company and the financial institution, etc. These evalua-
tions can only be made on a case-by-case basis and cannot
be analyzed here.
*In the few plants where this combination was observed, dry
forming ranged from 10% to 30% of production.
8-123
-------
In Table 8.63 Earnings Before Interest and Taxes (EBIT)
after control is derived by taking the earnings before tax
figure from Tables 8.56 and 8.57 and adding back interest on
existing debt and new process equipment debt, where applicable.
Annual control cost exclusive of interest is then subtracted.
Since existing debt is composed of both long term liabilities
of a year or longer (in most cases 5 to 20 year duration) and
short term debt of a term less than a year, interest on exist-
ing debt was calculated by using a 10% interest rate on debt
of an average 10 year duration, a capital recovery factor [CRF]
of .16275. Interest on control equipment was based on a CRF
of .132, 10% interest over 15 years. The annual interest used
was the annual average over the term of the loan. Depreciation
is the sum of annual depreciation of the building and process
equipment, added to annual depreciation of the control equip-
ment. Annual cash flow is the summation of EBIT and deprecia-
tion.
Annual debt repayment consists of debt items which must
be paid from company funds - principal and interest for exist-
ing control equipment and new process equipment debt, where
applicable. The annual interest and principal are taken as
the annual average over the term of the debt. The principal
for each category was converted to the pretax amount which
is needed to yield an after-tax outlay equal to the fixed
charge for each category of debt.* This was required in
*The tax rate used was the effective tax rate as calculated
from Tables 8.56 and 8.57.
8-124
-------
Table 8.63
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
ASSUMING NO COST PASS-THROUGH
(In Thousand of Dollars)
Type of Plant Existing
Type of Formation Wet and Dry
T y pe of Cont r o 1 Sulfuric Acid Mist
Manufacturing Assembling
100 BPD 250 BPD 100 BPD 250 BPD
EBIT After Control $ 71,3 $179.4 $ 50.7 $128.4
Depreciation After
Control1 $ 8.1 13.5 5.5 9.9
Annual Cash Flow 79.4 192.9 56.2 138.3
Total Assets $264.0 $338.6 $162.6 213.6
Debt Obligations Before
Control^ 132.0 169.3 81.3 103.6
Annual Debt Repayment3
Existing Debt 26.4 39.7 23.5 23.3
Control Equipment Debt 2. 2 5.2 2.2 5.1
Total Annual Debt
Repayment28.6 44.9 25.7 28.4
Debt Coverage4 2.8 4.3 2.2 4^9
Ifiuilding at .025? equipment at .066; OSHA, SIP and new
control equipment at .066.
2At 50% of total assets before controls.
3CRF = 0.16275 for existing debt; = 0.132 for control
equipment debt.
^Annual cash flow/total annual debt repayment.
8-125
-------
order to briny it to a basis comparable to that of the tax
deductible fixed charges. Annual interest for each category
is then added to the converted principal amount, summed for
each category and compared to cash flow to determine the
adequacy of cash flow to cover the debt repayment.
As Table 8.63 shows annual cash flow for all size plants
for sulfuric acid mist control in the "worst case"* situation
is adequate to support both existing debt and control equipment
debt repayment.
Table 8.64 presents the financial capability of recon-
structed/modified plants to support both sulfuric acid mist
and NSPS lead control costs in the worst case situation. In
this scenario plants must not only be able to support existing
and control equipment debt repayment but also new process
equipment debt repayment which engenders the lead control
costs, New equipment debt is based on 100% financing of the
affected process facilities. New equipment debt is based on
a CRF of .132, 10% interest over 15 years. For this scenario
the annual cash flow is barely sufficient to cover debt repay-
ment for both the 100 BPD manufacturer and assembler. Finan-
cial institutions would not be very likely to grant financing
of the control equipment under these conditions, and the plant
would have to look elsewhere such as the Small Business Admin-
istration for financing.
*Described here as without any cost pass-through.
8-126
-------
Table 8.64
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERV PLANTS
ASSUMING NO COST PASS-THROUGH
(In Thousand of Dollars)
Type of Plant
Type of Formation
Type of Control
EBIT After Control
Depreciation After
Control1
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt^
New Equipment Debt^
Annual Debt Repayment4
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage5
Reconstructed/Modified
Wet and Dry
Sulfuric Acid Mist and NSPS Lead
Manufacturing
100 BPD
$ 53.8
$ 19.3
73.1
$352.6
221.0
132.4
88.6
26.6
13.7
18.3
58.6
1.2
$160.1
24.6
184.7
$465.9
Assembling
250 BPD 100 BPD
$ 30.9
13.2
44.1
$207.7
250 BPD
$108.1
16.2
124.3
$271.9
296.6
169.3
127.3
39.7
17.7
23.4
80.8
2.3
126.4
81.3
45.1
15.6
6.7
17.6
39.9
1.1
158.6
103.6
55.0
23.3
9.2
22.7
55.2
2.3
^Building at .025; equipment at .066; OSHA, SIP and new
control equipment at .066.
2At 50% of total assets before new investment, same as Table
8.54.
3At 100% financing.
4cRF.= 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
^Annual cash flow/total annual debt repayment.
8-127
-------
Debt coverage for reconstructed/modified wet formation
plants is improved when NSPS lead controls are considered alone
(Table 8.65). Nevertheless, both the 100 BPD manufacturer and
assembler will still be unlikely to finance the new process and
control equipment,
No financial capability analysis was performed for sul-
furic acid mist controls alone with partial cost pass-through
because in the worst case situation (as depicted in Table 8.63)
the cash flow was sufficient to support debt repayment. The
analysis performed for sulfuric acid mist and NSPS lead con-
trols together (Table 8.66) and NSPS lead controls alone (Table
8.67) with partial cost pass-through shows that both the 100
BPD manufacturer and assembler would still have a difficult
time in obtaining financing based on consideration of debt
coverage ratios alone.
In the "worst case" situation, sulfuric acid mist control
equipment financing should be possible for all existing plants,
even if all the control cost must be absorbed. The 250 BPD
plants should be able even in the worst case situation to
obtain financing from financial institutions. Their debt
coverage is sufficient to allow institutions to grant finan-
cing.
The 100 BPD plants are not likely to be able to obtain
financing in the worst case situations. With partial cost
pass-through of $.574 per battery financing should still
prove difficult, particularly so for the plants incurring
-------
Table 8.65
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
ASSUMING NO COST PASS-THROUGH
(In Thousand of Dollars)
Type of Plant Reconstructed/Modified
Type of Formation Wet
Type of Control
EBIT After Control
Depreciation After
Control-1-
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt2
New Equipment Debt3
Annual Debt Repayment4
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage^
NSPS
Manufac
100 BPD
$ 59.9
$ 17 . 4
77.3
$332.0
213.2
139.6
73.6
28.3
11.5
16.3
56.1 •
1.4
Lead
:turing
250 BPD
$175.4
21.3
196.7
$469.9
288.6
181.3
107.3
41.4
18.5
19.4
79.3
2.5
Assembling
100 BPD 250 BPD
$ 37.2 $120.8
11.2
48.4
$189.7 $265.5
109.9 151.9
79.8 113.6
30.1 38.3
16.9 25.0
4.6 6.3
15.2 18.0
36.7 49.3
1.3 2.7
Ifiuilding at .025; equipment at .066; OSHA, SIP and new
control equipment at .066,
2At 50% of total assets before control, same as Table
8.55.
^At 100* financing.
4CRF = 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
cash flow/total annual debt repayment.
8-129
-------
Table 8.66
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
WITH PARTIAL COST PASS-THROUGH1
(In Thousand of Dollars)
Type of Plant
Typeof Formation
of Control
EBIT After Control
Depreciation After
Control2
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing
New Equipment
Annual Debt Repayment^
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage6
Reconstructed/Modi fled
Wet and Dry
Sulfuric Acid and NSPS Lead
Manufacturing
Assembling
100 BPD
$ 65.3
$ 19.3
85.6
$352.6
220.4
131.8
88.6
26.6
13.7
18.3
250 BPD
$189,8
24.6
214.4
$465.9
296.6
169.3
127.3
39.7
17.7
23.4
100 BPD
$ 41.9
13.2
55.1
$207.7
126.5
81.3
45.1
15.6
6.7
17.6
250 BPD
$136.8
16.2
153.0
$271.9
159.3
103.6
55.7
23.3
9.2
22.7
58.6
1.5
80.8
2.7
39.9
1.4
1-Cost pass through of $.574 per battery.
2Building at .025; equipment at .066; OSHA, SIP and new
control equipment at .GG6.
•^At 50% of total assets before control, same as Table
8.54.
4At 100% financing.
5CRF = 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
^Annual cash flow/total annual debt repayment.
55.2
2.8
8-130
-------
Table 8,67
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
WITH PARTIAL COST PASS-THROUGH1
(In Thousand of Dollars)
Type of Plant Reconstructed/Modified
Type of Formation wet
Type of Control
EBIT After Control
Depreciation After
Control2
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt3
New Equipment Debt^
Annual Debt Repayment^
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage6
NSPS Le
Manuf actu
100 BPD
$ 71.4
$ 17.4
88.8
$332.0
213.2
139.6
73.6
28.3
11.5
16.3
56.1
1.6
ad
ring
250 BPD
$204.1
21.3
223.4
$469.9
288.6
181.3
107.3
41.4
18.5
19.4
79.3
2.8
As_sembl_i_ng
100 BPD 250 BPD
$ 48.7 $149.5
11.2 13.1
59.9 162.6
$189.7 $265.5
109.9 151.9
79.8 113.6
30.1 38.3
16.9 25,0
4.6 6.3
15.2 18.0
36.7 49.3
1.6 3.3
Icost pass through of $.574 per battery.
2Building at .025; equipment at .U66; OSHA, SIP and new
control equipment at .066.
3&t 50% of total assets before control, same as Table
8.55.
4At 100% financing.
SCRF = 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
^Annual cash flow/total annual debt repayment.
8-131
-------
both sulfuric acid mist and lead NSPS control costs. In
the latter case it is likely that the wet/dry forming plant
may consider discontinuing dry formation as this would en-
hance debt coverage and possible ability to finance the lead
control equipment.
The preceding analysis was based on an operating rate
of 80 percent. If conditions for individual 100 BPD plants
should allow them to operate closer to capacity, their debt
coverage would be improved, though not substantially.
For both sulfuric acid mist and lead control together
or lead control alone, obtaining financing is still proble-
matic for the 100 BPD plant.
8.4.4.7 Compliance Testing Costs
Sulfuric acid mist and lead particulate compliance test-
ing costs for manufacturers and assemblers are shown in Table
8.68. Tables 8.69 to 8.76 show the ROI impact and financing
capability for existing and reconstructed/ modified plants when
compliance testing cost is considered in addition to the equip-
ment control cost.
The testing costs were assumed to be 100 percent financed
at 10 percent interest over 7 years. The CRF of .20541 was then
applied to determine the annualized cost for testing. This cost
was applied to the ROI and financial capability tables exclusive
of testing costs.
As can be seen in the Summary table in section 8.4.4.9,
testing costs aggravate the impacts facing all size plants.
8-132
-------
The 100 BPD manufacturers and assemblers facing both sulfuric
acid mist and NSPS lead control or NSPS lead control alone
experience an even lower ROI. Their ability to finance
control equipment and testing costs together is further
deteriorated.
Table 8.68
COMPLIANCE TESTING ANNUALIZED COSTS
SMALL PLANTS
Plant Description Testing Costs1
Sulfuric Acid Mist
(Wet/Dry Existing)
Manufacturing $11,500
Assembling $11,500
S u 1 f uric Acid Mist
and NSPS Lead
(Wet/Dry Reconstructed)
Manufacturing $23,500
Assembling $17,500
NSPS Lead
(Wet Reconstructed)
Manufacturing $13,500
Assembling $ 7,500
•l-Costs are independent of plant size but depend on
emission being tested and number of stacks tested.
8-133?
-------
Table 8.69
RJ2TURN ON INVESTMENT
T.J.EAD^ACID BATTERY PLAfjTS
COST PASS-THROUGH
TESTING COST INCLUDED
(In Thousand of Dollars)
Type of Plant Existing
Type o£ Formation Wet and Dry
Type of ConTror" Sulfuric Acid Mist
Assembling
Earnings Before Tax
Total Assets
Total^Annualized Control
Control Cost Per Battery*
$ 69.6
$264.0
26 .4%
$ .57
$ * 2 o
$ 63.4
$278.4
77.74
250 BPD
$181 .5
$338.6
53.6%
$ 17.1
$ .34
$ .26
$177.5
$368.6
48.1%
100 BPD 250 BPD
$ 52.6 $134.5
$162.6 $213.6
32.3% 63.0%
$ 11.4 $ 17.1
$ .-57 $ .34
$ '.26 $ .26
$ 46.4 $130.5
$177.0 $243.6
26.2% 53.6%
Earnings Before Tax and
After Control2
Total Assets After Control $278.4
ROI After control
lAt 80% operating rate.
2After control cost and testing cost absorbed and equipment
depreciation subtracted.
8-134
-------
Table 8.70
RETURN ON INVESTMENT __IMPACT
SMALL LEAD-ACID BATTERY PLANTS
COST PASS-THROUGH
TESTING COST INCLUDED
(In Thousand of Dollars}
Type of Plant
Type of Formation
Type of Control
Reconstructed/Modi fled
Wet and Dry
Sulfuric Acid Mist and NSPS Lead
Manufacturing
Assembling
Earnings Before Tax
Total Assets
ROI Before Control
Total Annualized Control
Cost
Control Cost Per Battery^
Cost Pass Through
Earnings Before Tax and
After Control2
Total Assets After Control $474.0
ROI After Control
100 BPD
$ 69.6
$352.6
$
$
$
$
$4
19.8%
46.6
2.33
.574
28.6
74.0
6.0%
250 BPD
$181.5
$465.9
39.0%
$ 54.6
$ 1.09
$ .574
$147.2
$609.9
24.1%
100 BPD
$ 52.6
$207.7
25.3%
$ 43.8
$ 2.19
$ .574
$ 17.3
$324.1
5.3%
250 BPD
$134.5
$271.9
49.5%
$ 51.7
$ 1.03
$ .574
$107.8
$409.9
26.3%
80% operating rate,
2After control cost and testing cost absorbed and equipment
depreciation subtracted.
8-135
-------
Table 8.71
RETURN ON INVESTMENT IMPACT
SMALLLEAD-ACID BATTERY PLAMTS
COST PASS-THROUGH
TESTING COST INCLUDED
{In Thousand of Dollars)
Type of Plant
Typ_e of Formation
Type of Control
Reconstructed/Modified
Wet
NSPS Lead
Manufacturing
100 BPD
Assembling
250 BPD 100 BPD 250 BPD
Earnings Before Tax
Total Assets with
New Investments
ROI Before Control
$ 69.6 $181.5 $ 52.6 $134.5
$332.0 $469.9 $189.7 $265.5
21.0% 38.6% 27.7% 50.7%
Total Annualized Control
Cost . $ 35.6
Control Cost Per Battery1 $ 1.78
Co st Pass Through $ .574
Earnings Before Tax and
After Control2 $ 40,6
Total Assets After Control $439.0
ROI After Control 9.2%
$ 37.4 $ 32.7 $ 34.5
$ .75 $ 1.64 $ .69
$ .574 $ .574 $ .574
$ 29.3 $126.1
$291.7 $373.5
10.0% 33.7%
80% operating rate.
er control cost and testing cost absorbed and equipment
depreciation subtracted.
8-136
-------
Table 8.72
FINANCIAL CAPABILITY ANALYSIS
OF SMALLLEAD-ACID BATTERY PLANTS
WORST CASE SITUATION1
TESTING COST INCLUDED
(In Thousand of Dollars)
Type of Plant Existing
Type of Formation Wet and Dry
Ty[.e of Control Sulfuric Acid Mist
Manufacturing Assembling
100 BPD 250 BPD 100 BPD 250 BPD
EBIT After Control $ 69.7 $177.8 $ 49.1 $126.8
Depreciation After
Control2 $ 8.1 13.5 5.5 9.9
Annual Cash Flow 77.8 191.3 54.6 136.7
Total Assets $264.0 ' $338.6 $162.6 $213.6
Debt Obligations Before
Control3 132.4 169.3 81.3 103.6
Annual Debt Repayment4
Existing Debt 26.4 39.7 23.5 23.3
Control Equipment Debt 5.3 8.7 5.1 8.j
Total Annual Debt
Repayment 31.7 48.4 28.6 31.8
Debt Coverage5 2.5 4.0 1.9 4.3
^Assuming no cost pass-through.
2Building at .025; equipment at .0-36; OSHA, SIP and new
control equipment at .066.
3At 50% of total assets before control, same as Table
8.55.
4CKF = 0.16275 for existing debt; = 0.132 for control
equipment debt.
^Annual cash flow/total annual debt repayment.
8-137
-------
Taole 8.73
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
WORST CASE SITUATION1
TESTING COST INCLUDED
(In Thousand of Dollars)
Type of Plant Reconstructed/Modified
Type of Formation
Type of Control
EBIT After Control
Depreciation After
Control^
Annual Cash Plow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt3
New Equipment Debt^
Annual Debt Repayment^
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage**
Wet and Dry
Sulfuric Acid Mist
Manufacturing
100 BPD
$ 50.5
$ 19.3
69.3
$352.6
220.4
131.8
88.6
26.6
13.7
24.4
64.7
1.1
250 BPD
$156.8
24.6
181.4
$465.9
296.6
169.3
127.3
39.7
17.7
30.5
87.9
2.1
and NSPS Lead
Assembling
100 BPD
$ 28.5
13.2
41.7
$207.7
126.4
81.3
45.1
15.6
6.7
22.0
44.3
0.9
250 BPD
$105.7
16.2
121.9
$271.9
158.6
103.6
55.0
23.3
9.2
27.8
60.3
2.0
•'•Assuming no cost pass-through.
^Building at .025» equipment at .066; OSHA, SIP and new
control equipment at .066.
^At 50% of total assets before control, same as Table
8.55.
4At 100% financing. -
5CRF = 0.16275 for existing debt; = 0.132 for new equipment
^.and control equipment debt.
°Annual cash flow/total annual debt repayment.
8-13R
-------
Table 8.74
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
WORST CASE SITUATION1
TESTING COST INCLUDED
(In Thousand of Dollars)
Type jaf Plant
Reconstructed/Modified
Type of formation Wet
Type of Control
KBIT After Control
Depreciation After
Control2
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt3
New Equipment Debt^
Annual Debt Repayment^
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage6
NSPS
Manuf ac
100 BPD
$ 58.0
$ 17.4
75,4
$332.0
213.2
139.6
73. G
28.3
11.5
24.4
64.2
1.2
Lead
:turing
250 BPD
$173.5
21.3
194.8
$469.9
288.6
181.3
107.3
41.4
18.5
30.5
90.4
2.2
Assembling
100 BPD 250 BPD
$ 36.2 $119.8
11.2 13.1
47.4 132.9
$189.7 $265.5
109.9 151.9
79.8 113.6
30.1 38.3
16.9 25.0
4.6 6.3
22.0 27.8
43.5 59.1
1.1 2.2
^-Assuming no cost pass-through.
2Building at .025; equipment at .066; OSHA, SIP and new
control equipment at .066.
3At 50% of total assets before control, same as Table
8.55.
4At 100% financing.
5CRF = 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
^Annual cash flow/total annual debt repayment.
8-139
-------
Table 8.75
FINANCIAL CAPABILITY ANALYSIS
OP SMALL
LEAD- AC ID BATTERY PLANTS
WITH PARTIAL COST PASS-THROUGH1
T
(In
Type of Plant
ESTING COST INCLUDED
Thousand of Dollars)
Recons true ted/Mod if
ied
Type of Formation Wet and Dry
Type of Control
EBIT After Control
Depreciation After
Control2
Annual Cash Flow
Total Assets with New
Investment
Debt Obligations Before
Control
Existing Debt-^
New Equipment Debt^
Annual Debt Repayment 5
Existing Debt
New Equipment Debt
Control Equipment Debt
Total Annual Debt
Repayment
Debt Coverage^
Sulfuric Acid Mist
Manufacturing
100 BPD 250 BPD
$ 62.0 §186.5
$ 19.3 24.6
81.3 211.1
$352.6 $465.9
220.4 296.6
131.3 169.3
88.6 127.3
26.6 39.6
13.7 17.7
24.4 30.5
64.7 87.8
1.3 2.4
and NSPS Lead
Assembling
100 BPD 250
$ 39.5 $134
13.2 16
52.7 150
$207.7 $271
126.4 159
81.3 103
45.1 55
15,6 23
6.7 9
22,0 27
44.3 60
1.2 2
BPD
.4
.2
.6
.9
.3
.6
.7
.3
.2
.8
.3
.5
pass through of $.574 per battery.
2Building at .025; equipment at .066; OSHA, SIP and new
control equipment at ,066.
^At 50% of total assets before control, same as Table
8.55.
4At 100% financing.
5CRF = 0.16275 for existing debt; = 0.132 for new equipment
and control equipment debt.
"Annual cash flow/total annual debt repayment.
8-140
-------
Table 8.76
FINANCIAL CAPABILITY ANALYSIS
OF SMALL LEAD-ACID BATTERY PLANTS
WITH PARTIAL COST PASS-THROUGH1
TESTING COST INCLUDED
(In Thousand of Dollars)
Type of Plant Reconstructed/Modified
Type of Foinflation Wet
Type of Control NSPS Lead
_Manufacturlng Assembling
100 BPD 250 BPD 100 BPD 250 BPD
EBIT After Control $ 69,5 $202.2 $ 47.7 $148.5
Depreciation After
Control2 $ 17.4 21.3 11.2 13.1
Annual Cash Flow 86.9 223.5 58.9 161.6
Total Assets with New
Investment $332.0 $469.9 $189.7 $265.5
Debt Obligations Before
Control 213.2 288.6 109.9 151.9
Existing Debt3 139.6 181.3 79.8 113.6
New Equipment Debt4 73.6 107.3 30.1 38.3
Annual Debt Repayment^
Existing Debt 28.3 41.4 16.9 25.0
New Equipment Debt 11.5 18.5 4.6 6.3
Control Equipment Debt 19.6 23.2 17.0 20.1
Total Annual Debt
Repayment 59.4 83.1 38.5 51.4
Debt Coverage6 1.5 2.7 1.5 3.1
3-Cost pass through of $.574 per battery.
2suilding at .025; equipment at .06.6f OSHA, SIP and new
control equipment at .066.
-*At 50% of total assets before control, same as Table
8.55.
4At 100% financing.
SCRF = 0.16275 for existing debt? = 0.132 for new equipment
and control equipment debt.
^Annual cash flow/total annual debt repayment.
8-141
-------
8.4.4.8 Other Cost Considerations
Not considered in the previous analysis were solid waste costs,
water pollution costs and costs associated with meeting the recently
established Occupational Safety and Health Administration's (OSHA)
50 yg/m lead-inair standard. All of these costs will have to be met
in the future.
Annual solid waste costs are given in Tables 8.45 and 8.46.
Plants discharging wastewater to navigable waters will be subject to
effluent limitations when these are promulgated. However, most
plants are located in urban areas, and are probably discharging to
municipal sewers. The majority of plants will, therefore, be subject
to pretreatment standards.
The pretreatment standard is expected to be the same as the BPT
standard. Table 8.77 compares the control cost estimated to meet the
BPT standards* (which should be similar to pretreatment costs) and
the control cost required to meet the NSPS lead control standard.
The pretreatment cost for assemblers would be the same as shown for
manufacturers. As can be seen these costs approach and, in the case
of the 250 BPD wet/dry plant, exceed the lead control costs. No cost
estimate is available for meeting the 50 pg/m OSHA standard in the
lead acid battery industry.
When these anticipated costs are imposed on small plants the
effects shown for the 100 BPD operator will be aggravated.
*Costs for wet forming plants from Table 8.44. For wet/dry forming
calculated from Table 8.44.
8-142
-------
Plants larger than 100 BPD will begin to show the same decline
of ROI to low levels and a similar decline in debt coverage
ratios.
Table 8.77
COMPARISON OF CONTROL COSTS FOR PRETREATMENT AND NSPS LEAD
ANNUALI2ED CONTROL COSTS
(In Thousands of Dollars)
Wet Forming Wet/Dry Forming1
Manufacturing
100 BPD
$18.6
32.8
250 BPD
$30.6
34.9
Manufacturing
100 BPD 250 BPD
$29.7
32.8
$48.8
34.9
Pretreatment
NSPS Lead
(Reconstructed/
Modified plants)
1 Based on 80% of production wet, 20% dry.
8-4.4.9 Conclusion
Table 8.78 shows a summary of the economic impacts which
were discussed in previous sections. As can be seen, existing
wet/dry plants which have to meet sulfuric acid mist control
should be able to meet the standard without incurring signifi-
cant impacts. ROI* does not decrease drastically and their
debt coverage remains adequate to obtain financing after
control costs are incurred.
*It should be reiterated here that these ROI figures in Table
8.78 are high for reasons cited in section 8.4.4.3.
8-143
-------
Table 8.73
SUMMARY OF ECONOMIC IMPACTS
ROI
Before
Plant Description
_Sulfuric_Acid Mist
(Wet/Dry Existing)
Manufacturing
100 BPD
250 BPD
Assembling
100 BPD
250 BPD
Sulfuric Acid Mist
andMSPS_Lead
(Wet/Dry Reconstructed)
Manufacturing
100 BPD
250 BPD
Assembling
100 BPD
250 EPD
NSPS Lead
(Wet Reconstructed)
Manufacturing
100 BPD
250 BPD
Assembling
100 BPD
250 BPD
ROI
After
ROI
After
Control
and
Debt
Debt
Coverage
After
Cove rage Controj-
Control Control Testing (After Control)1 and Testing1
26.4%
53.5
32.3
62,9
19.7
39.0
25.3
49.5
21.0
38.6
27.7
50.7
23.6%
48.8
27.6
54.6
7.0
25.0
6.4
27.2
9.9
28.7
10.5
34.1
22.7%
48.1
26.2
53.6
6.0
24.1
5.3
26.3
9.2
28.3
10.0
33.7
2,8
4.3
2.2
4.9
1.5
2.7
1.4
2.8
1.6
2.8
1.6
3.3
2.5
4.0
1.9
4.3
1.3
2.4
1.2
2.5
1.5
2.7
1.5
3.1
partial cost pass through except for sulfuric acid wist
control alone where no cost pass through is assumed.
8-144
-------
Though ROI declines by 15 percentage points for the
250 BPD wet/dry reconstructed manufacturing plants and 23
percentage points for the assembling plants meeting both
sulfuric acid mist control and NSPS lead control, their ROI
is still sufficiently high (even if the calculated asset base
were doubled) relative to alternative investments for them
to remain in the industry. Obtaining financing for control
equipment and testing costs should also prove possible based
on their debt coverage ratio. The 100 BPD plant is unlikely
to be able to finance the required control equipment and may
be unwilling to remain in the industry with the depressed ROI
which develops after control, even with some cost pass through.
The 250 BPD wet reconstructed plants who have to meet
only the NSPS lead control standard are less severely impacted
than the wet/dry plants in all respects. In only having to
meet NSPS lead standard, their ROI and debt coverage are both
*
adequate and higher than the wet/dry plant. The 100 BPD wet
plant would be in a situation after control where he way also
consider leaving the industry. With his debt coverage of 1.5
it should not prove possible to obtain conventional financing.
Another financing possibility for the 100 BPD operator
is to seek financing through the SBA. Long-term, low interest
loans for control equipment, which may include process changes
as control methods, will enable him to spread his annual
capital cost burden over a longer time span.
-------
In the preceding analysis it was assumed that all affec-
ted facilities, namely, casting, pasting and the 3-P operation,
would be replaced simultaneously shortly after the promulgation
of the standards, and, therefore, would all require NSPS con-
trols at the same time. It is felt that this is very unlikely
to happen in reality,
A number of realistic alternatives exist for the small
operator even after the promulgation of lead and sulfuric acid
mist regulations. The small operator could continue and is
likely to utilize his existing process equipment without sub-
stantial reconstruction or replacement up to a point in the
future when the equipment maintenance costs become prohibitive.
At that time his market position is likely to dictate his stra-
tegy. Should his business sales be expanding the small plant
management could then decide to replace each affected facility
over a period of time. This strategy would insure that the
»
incurring of control costs would take place over a period of
time and at his own convenience and would mitigate the ROI
and cash flow problems shown in previous sections. Should his
sales be constant or decreasing he could decide to discontinue
battery production entirely and expand the service part of the
business, or to become a distributor of larger companies batter-
ies. In certain cases where the plant is in a stronger finan-
cial position and where the market is somewhat protected by
transportation costs or product specialization, the company may
attempt to expand to spread the control costs over a larger
sales base.
8-146
-------
With each of the alternatives listed above, the economic
impact of the NSPS lead standard will be felt gradually over
a long period of time instead of immediately after the promul-
gation of the standard, and all at once, as depicted in the
analysis above.
As mentioned in Section 8.4.4.5, the wet/dry plant has
the option of discontinuing dry formation to avoid the sul-
furic acid mist control. This cost cannot be postponed, how-
ever, because it applies to existing plants as well as to new
and reconstructed/modified plants. When pretreatment water
pollution control costs are also considered, the incentive
to discontinue dry production becomes even more pronounced
for the small plant.
Thus, the impact of NSPS lead and sulfuric acid mist
regulations is to generally favor a status-quo in terms of
exisitng plant equipment. New plants are not expected to
be built with capacities of 500 BPD or less, and any replace-
ment, reconstruction or modification of an existing plant can
be so structured as to minimize a one-time, immediate, signi-
ficant economic impact projected in the preceding analysis,
and to spread it out at the discretion of the plant management.
There is no data on the size distribution of the approxi-
mately* 91 small plants. Most assemblers, though, would probably
be in the 100 BPD area so that minimum estimate of the number
of small plants which would be severely impacted is approximately
30.
8-147
-------
REFERENCES
1. Annual Review, 1977 - U.S. Lead Industry, Lead Industries
Association, Inc., New York. 1978. p. 6.
2. Ibid., p. 4.
3. Share-of-Market Report. New York. Economic Information
Systems, Inc. July 1975. p. 1, 2, and 5.
4. Thakker, B. Screening Study to Develop Background Informa-
tion and Determine the Significance of Emissions from Lead
Battery Manufacture. Vulcan-Cincinnati, Inc. Prepared for
the U.S. Environmental Protection Agency under Contract No.
68-02-0299, Task No. 3. December 1972. p. 5.
5. Data developed under EPA Contract No. 68-02-2804 in Support
of Lead Ambient Air Standard.
6. Economic Impact of Proposed OSHA Lead Standards, The Stor-
age Battery Industry, Charles River Associates, March, 1977,
p. 3-9.
7. Standard and Poor's Industry Surveys. Volume I. Mew York.
Standard & Poor's Corporation, 1977. p. AlSl.
8. Globe-Union, Annual Report, 1974. Globe-Union, Inc.
Milwaukee, Wisconsin. November 1974. p. 4.
9. Burkard, R.A., "Batteries Are Our Business", Globe-Union,
May, 1978.
10. Op. cit. Ref. 6. pp. 3-51.
11. Private Communication Between Donald Henz of PEDCo Environ-
mental, Inc., Cincinnati, Ohio and Allen Edwards of the Mev^
Jersey Air Pollution Control Agency, Central Field Office,
April 27, 1976.
12. Private Communication Between David Augenstein of PEDCo
Environmental, Inc., Cincinnati, Ohio and Ben Sax of
American Air Filter, Cincinnati, Ohio Sales Representa-
tative .
13. Private Communication Between David Augenstein of PEDCo
Environmental, Inc., Cincinnati, Ohio and Mel Hott of
Tri-Mer Corporation, Cincinnati, Ohio Sales Representa-
tive,
-------
14. Op, cit. Ref. 12.
15. Op. cit. Ref. 13.
16. Perry, R. H, and C. H. chilton, Chemical Engineers Hand-
book. 5th Edition. McGraw-Hill. New York, Mew York.
1973. p. 25-16.
17. Private Communication Between Donald lienz of PEDCo Envi-
ronmental, Inc., Cincinnati, Ohio and Douglas Bradley of
Tonolli Foundry, Toronto, Canada. June 24, 1976.
18, Private Communication Between Donald Henz of PEDCo Envi-
ronmental, Inc., Cincinnati, Ohio and John Bitler of
General Battery Corp., Reading, Pa. June 1, 1976.
19. Op. cit. Ref. 17.
20. McCandless, W., R. Wetzel, et al. Assessment of indus-
trial Hazardous Waste Practices, Storage and Primary
Batteries Industries. Versar, Inc., Springfield, Vir-
ginia. Contract No. EPA-68-01-2276. Prepared for U.S.
Environmental Protection Agency. January 1975. p. 30.
21. Ibid. p. 132.
22. Op. cit. Ref. 20. p. 133.
23. Op. cit. Ref. 20. p. 134
24. Op. cit. Ref. 20 p..175.
25. Op. cit. Ref. 20. p. 132
26. Op. cit. Ref. 20. p. 133
27. Development Document for Effluent Limitations Guidelines
and Standards of performance for the Machinery and Mechan-
ical Point Source Category, Vol. 4, Hamilton Standard.
Prepared for the U.S. Environmental Protection Agency
Under Contract No. 68-01-2914. June 1975 (Draft).
p. 8-37 and 8-50.
28. Op. cit. Ref. 20. p, 174.
29. Op. cit. Ref. 20. p. 175.
30. Private Communication Between David Augenstein of PEDCo
Environmental, Inc., Cincinnati, Ohio and William Pallies
of ESBr Inc., Philadelphia, Pa. March 10, 1976.
8-149
-------
31. Building Construction Cost Data, 1977. Robert Snow
Means Company, Inc. Duxbury, Mass. 1977. 346 p.
32. Confidential data developed for EPA under EPA contract
No. 68-01-3273.
8-150
-------
9.0 RATIONALE FOR THE PROPOSED STANDARDS
9.1 SELECTION OF SOURCE FOR CONTROL
The largest single use of lead in the United States is in the
manufacture of lead-acid, or secondary, storage batteries. There are
approximately 190 lead-acid storage battery manufacturing plants in the
United States. Projections of growth rate in the lead-acid battery
industry range from 3 to 5 percent annually over the next 5 years.
Facilities at lead-acid battery plants emit lead-bearing and non-
lead-bearing particulates, and sulfuric-acid mist. Both lead and sulfuric
acid mist have been determined to be health related pollutants. Total
lead emissions from the industry in 1975 were estimated to be about 82 Mg
(90 tons), or about 0.4 percent of the total atmospheric lead emissions
from stationary sources in the United States. Most lead-acid battery
plants are located near residential areas. Therefore, under the provisions
of Section lll(b)(l)(A) of the Clean Air Act, as amended, the Administrator
has included the lead-acid battery industry as an air pollution source
category which may reasonably be anticipated to endanger public health
or welfare.
9.2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
9.2.1 Selection of Pollutants
Lead-acid battery plants emit both lead-bearing and nonlead-bearing
particulate matter from lead oxide production, grid casting, paste mixing,
lead reclamation and assembling facilities. As mentioned earlier, it has
9-1
-------
been determined that lead is a health related pollutant. Atmospheric
dispersion modeling was used to estimate maximum ambient concentrations
of lead in the vicinity of lead-acid battery plants. The results of this
study are discussed in detail in Section 7.1.1.1. The estimated annual
ambient impacts of 500 and 6500 bpd plants controlled only to the extent
•3 . •>
required by existing State regulations are 4 ug/m and 8 wg/m , respectively.
3
The National Ambient Air Quality Standard for lead is 1,5 yg/m on a
quarterly basis. For this reason, and because most lead-acid battery
plants are located near residential areas, standards are proposed for
the lead fraction of the particulate emissions. The reduction of lead
emissions to the levels of the proposed standards at affected 500 and 6500
bpd plants would result in the reduction of the average annual ambient
impacts of lead emissions from these plants to less than 1 ug/m .
Standards are not proposed for the nonlead fraction of particulate
emissions for two reasons. First, such emissions are slight. Second,
limitation of the lead emissions will also reduce emissions of other
particulates.
In addition to lead-bearing particulate matter, plants using dry
formation techniques emit sulfun'c acid mist. This mist results from the
entrainment of sulfuric acid in hydrogen bubbles which are generated during
the formation process. Wet formation takes place in covered battery
cases. Therefore, acid mist emissions from wet formation are small. Two
literature sources indicate acid mist emission rates from dry formation
of 14 Kg (30 lb) and 19 Kg (42 Ib) per 1000 batteries.2'3
Because sulfuric acid mist has been determined to be a health related
pollutant, the Administrator considered proposing standards for the lead-
acid battery manufacturing industry which would limit acid mist emissions
9-2
-------
as well as lead emissions. If the emission rate measured by EPA for dry
formation had been as high as the rates presented in the literature, there
may have been cause to propose acid mist standards. However, EPA tests or
dry formation at one plant indicate that the sulfuric acid mist emission
rate from this facility is only about 1.1 Kg per 1000 batteries (see Section
7.1.2). Dispersion modeling studies based the results of EPA emission
tests indicate that the maximum ambient impact of sulfuric acid mist
emissions from the dry formation process at a plant as large as 6500
3
batteries per day would be less than 1 jig/m . Therefore, standards for
acid mist are not being proposed at this time.
EPA is required to review new source performance standards at least
every four years, and, if appropriate, revise them. Thus, new source
performance standards for lead-acid battery manufacture may be revised
in the future to include standards limiting sulfuric acid mist emissions.
9.2.2 Applicability
The proposed standards of performance would apply to facilities at any
lead-acid battery plant that has a production capacity greater than or equal
to 500 bpd. Plants with capacities smaller than 500 bpd are exempted from
the proposed standards for several reasons. First, projections of the
economic impact of standards on existing small plants (100 and 250 bpd)
undergoing reconstruction or modification indicated that standards would
have a severe negative impact on such plants. Also, although almost 50
percent of the lead-acid battery plants in the United States produce fewer
than 500 bpd, these plants account for only about 2 percent of total lead-
acid battery production. Finally, industry representatives do not forecast
construction or expansion of small plants. In fact there has been a trend
9-3
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in recent years of small plants closing due to unprofitability. Increased
demand for batteries in the future is expected to be accommodated by
expansion of existing plants producing over 2000 bpd.
9.2.3 Selection of Affected Facilities
Processes selected as affected facilities are grid casting, lead
oxide production, paste mixing, three-process operation, lead reclamation,
and other lead-emitting operations. These processes often consist of
several machines or production lines which perform the same function and
which are located in the same area and ducted to the same control device.
Therefore, for each of the processes mentioned above, the affected
facility is the entire operation. '.;
9.2.2.1 Grid Casting—
The grid casting operation includes grid casting furnaces, which
melt the lead, and grid casting machine which cast the liquid metal into
grids. Although emissions from the grid casting operations are generally
loWj most grid casting work areas must be ventilated to comply with the
3
in-plant OSHA lead concentration standard of 50 pg/m . Source tests for
the present study detected uncontrolled lead emissions of approximately
0.4 kg (0.9 lb) per 1000 batteries. This is about 3.2 percent of the
overall plant uncontrolled lead emissions of 12,6 kg (27.7 Ib) per 1000
batteries (including lead reclamation and lead oxide production).
Therefore, grid casting is designated an affected facility.
9.2.2.2 Lead Oxide Manufacturing—
The lead monoxide used in battery paste production is called lead
oxide, black oxide, or battery oxide. It is produced either by the ball
mill or the Barton process. Fabric filters are always used as part of
the process for product recovery. Source tests for this study indicate
lead emissions of 0.05 kg (0.116 Ib) per 1000 batteries from a typical
lead oxide facility. Although the lead emissions from a typical lead
9-4
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oxide manufacturing process are low, it is estimated that well-controlled
lead oxide manufacturing facilities emit only half as much lead as one
designed only for economical recovery of lead oxide. Thus, the lead
oxide production process is designated an affected facility.
9,2.2.3 Paste Mixing--
The paste making operation is a batch process that consists of
materials charging followed by blending in either a muller, Day, or
dough-type mixer. Emissions are in the form of lead oxide with small
amounts of other paste constituents such as Dyne!, organics, and carbon
black. Paste mixing is selected as an affected facility because un-
controlled lead emissions from the process are approximately 5.1 kg
(11.2 lb) per 1000 batteries. This is 40 percent of the total estimated
lead emissions from a lead-acid battery plant.
9.2.2.4 Three-process Operation--
The three-process operation includes plate stacking, burning, and
assembly of elements into the battery case. Emissions consist of lead,
lead oxide, and nonlead bearing particulate from the separators. These
emissions are generated during plate handling, plate stacking, and
burning or casting operations. Source tests indicate that lead emissions
from the three-process operation are 6.7 kg (14.7 Ib) per 1000 batteries.
This is over 50 percent of the estimated emissions of lead from a lead-
acid battery plant. Therefore, the three-process operation is designated
as an affected facility.
9.2.2.5 Lead Reclamation—
'Lead reclamation is an operation wherein relatively clean scrap is
remelted and cast into ingots for use in the process. This is often a
9-5
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sporadic operation, on stream only wben large quantities of defective
small parts, grids, and plates are available. The lead is melted at
relatively low temperatures 370° C (700° F)» but lead emissions can be
high during scrap charging or dross removal. Lead emissions are estimated
at 0.35 kg (0,77 Ib) per 1000 batteries or 3.0 kg/Mg {5.9 Ib/ton) of
lead charged. A 4000-bpd plant that operates its lead reclamation
facility for an 8-hour shift every 2 weeks would emit approximately 1.7
kg/h (3.8 Ib/h) during operation. This amount is comparable to lead
emissions from the three-process operation at the same plant. Thus, the
lead reclamation operation has been designated as an affected facility.
Reverberatory furnaces which are used for lead reclamation but which are
affected by standards of performance for secondary lead smelters (40 CFR
60.120) would not be affected under the proposed standards.
9.2.2.6 Other Lead-Emitting Operations--
Any lead-acid battery plant facility from which lead emissions are
collected and ducted and not considered part of the grid casting, paste
.mixing, three-process operation, lead oxide production, or lead reclamation
facilities, and which is not a reverberatory furnace affected by standards
of performance for secondary lead smelters is considered an "other lead
emitting operation". An example is slitting, a process whereby lead
grids, cast in doublets, are slit (with an enclosed saw) into separate
plates. These types of facilities could be controlled by a separate
control device, but are usually ducted to a control device serving other
facilities. EPA has selected other lead emitting operations as affected
facilities to ensure that these processes are controlled.
9.3 SELECTION OF THE BEST SYSTEM OF EMISSION REDUCTION
CONSIDERING COSTS
Emission control alternatives for a lead-acid battery plant are
9-6
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Table 9-1. SELECTED CONTROL ALTERNATIVES FOR
LEAD-ACID BATTERY MANUFACTURING INDUSTRY
Plant
size, Control
BPD alternative
Facilities'
Control system
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Fabric filter, 2/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Impingement and entrainment
scrubber
Fabric filter, 2/1 A/CC
500,
2000,
I
II
A, B, F
C, E
D
B, C, E
F
1
6E
« III C, E
>00 A, B, F
D
IV A, B, C
E
F
D
V A, B, C, F
E
UT ART
E
100
S . VII A, B, C, E
250d
VIII A, B, C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 2/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 2/1 A/CL
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
Fabric filter, 2/1 A/CC
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Fabric filter, 6/1 A/C
Impingement and entrainment
scrubber
Fabric filter, 6/1 A/C
facilities key: A - grid casting furnace; B - grid casting
machines; C - paste mixer; D - lead oxide manufacturing',
E - three-process operation; F - lead reclamation furnace.
facilities are vented to common control systems as shown.
cSmall plants (500 bpd or less) are assumed to have no lead oxide
manufacturing facilities.
^Plants smaller than 500 BPD are assumed to have no lead reclamation
facilities.
9-7
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I
Table 9-2. SUMMARY OF ALTERNATIVE CONTROL SYSTEMS tQSTS AHO CONTROL £FFKTI¥O(ESS
FOR LEAD-ACID BATTOY PLANTS (METRIC UNITS)
VO
CO
Control
alternative
I
n
in
IV
¥
VI
VI!
VIII
Plant Lead emissions,
capacity, kg/day
bpd
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6SOO
SCO
2000
6500
1QQ
250
100
250
100
250
Uncontrolled
6.2
25.0
81.6
6.2
25.0
81.6
6.2
25.0
81.6
6.2
25.0
81.6
6.2
25.0
61 .6
1.22
3.04
1.22
3.04
1.22
3.04
Control 1 ed
0.06
0.30
0.99
0.09
0.40
1.31
0.10
0.42
1.43
0.33
1.30
4.38
0.33
1.30
4,41
0.0122
0.0304
0.0122
0.0304
0.0615
0.154
Lead
removal ,
%
99.0
98.8
. 98.8
38,6
98.4
98,4
98.4
98.3
98.3
94.8
98.4
94.6
94.8
98.4
94.6
9t.O
99.0
99.0
99.0
94.9
94.9
New
control
cost..
Installed6
125
211
453
151
228
474
120
200
423
110
154
295
$9
119
252
89
95
124
136
94
100
plant
systems
$1Q005 .
Annual! zed
47.4
108
284
56.9
122
303
47.6
107
277
30.2
48.1
91
19.4
36.9
78
28.6
30,4
44,3
47.0
26.1
27.6
Existing plant
control systems
cijst, $1000 j
Installs?"
106
253
544
181
274
569
144
240
SOS
132
185
354
83
143
302
107
H4
149
163
113
120
Annu all zed"
53.6
n«
305
64.1
133
326
53.4
117
29?
3S.4
55.8
105
22.7
42.6
100
32.8
34.9
50.2
53.5
30.6
32.4
A description of each control alternative is presented 1n Chapter i. Hone of there alternatives include acid mist control.
bMid-1976 dollars.
Excludes SIP compliance costs estimated at $35,000, $35,000, $91,000, $95,000, and $105,000 for plants with capacities
of 100, 250, 500, 2000, and 6500 bod, respectively.
Excludes costs of controlling facilities that require controls to meet SIP regulations.
-------
to
Table 9-2A. SUMMARY OF ALTERNATIVE CONTROL SYSTEMS COSTS AND CONTROL EFFECTIVENESS
FOR LEAO-ACIO BATTERY PUNTS (ENGLISH UNITS)
Control
alternative
I
II
III
IV
V
VI
VII
VIII
Plant
capacity,
bpd
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
500
2000
6500
100
250
100
2iO
100
250
Lead emissions,
1 b/day
Uncontrolled
13.8
55.3
180
13.8
55.3
180
13.8
55.3
180
13.8
55.3
180
13.8
55,3
180
2.68
5.70
2.68
6.70
2.68
6.70
Controlled
0.138
0.665
2.18
0.193
0.885
2.89
0.214
0.940
3.15
0,718
2.88
9.i7
0.718
2.88
9.73
0.0268
0,0670
0.0268
0.0670
0.136
0.339
Lead
removal ,
99.0
98.8
98.8
98.6
98.4
98.4
98.4
98.3
98.3
94.8
94.8
94.6
94.8
94.8
94.6
99.0
99.0
99.0
99.0
94.9
94.9
New plant
control systems
cost, $1000°
Installed
125
211
453
151
228
474
120
200
423 .
no
154
295
69
119
252
89
95
124
136
94
100
Annualized"
47.4
108
284
56.9
122
303
47.6
107
277
30.2
48.1
91
19.4
36.9
78
28.6
30.4
44.3
47.0
26.1
27.6
Existing plant
control systems
cost, $1000 j
Installed
105
253
544
181
274
569
144
240
508
132
185
354
83
143
302
107
114
149
163
113
120
Annual ized"
53.6
118
305
64.1
133
326
53.4
117
297
35.4
55.8
105
22.7
42.6
100
32.8
34.9
50.2
53.5
30.6
32.4
aA description of each control alternative 1s presented 1n Chapter 6. None of there alternatives include acid mist control
bMid-1976 dollars.
cExcludes SIP compliance casts
100, 250, 500, 2000, and 6500
estimated at $35,000, $35,000, $91,000, $95,000, and $105,000 for plants with capacities of
bpd, respectively.
Excludes costs of controlling facilities that require controls to meet SIP regulations.
-------
discussed in Chapter 6, and the economic impacts of the alternatives are
discussed in Chapter 8. Table 9-1 summarizes control alternatives for
lead emissions, while Tables 9-2 and 9-2A summarize the costs of the
alternatives and their overall lead removal efficiencies. The control
alternatives and their economic impacts are discussed in further detail
in Chapters 6 and 8.
The impacts of alternatives I through V were analyzed for 500,
2000, and 6500 bpd plants. Alternatives VI through VIII are control
alternatives for smaller plants, and take into account the differences
between these plants and larger plants. The impacts of these alternatives
were analyzed for 100 and 250 bpd plants. For reasons discussed earlier,
standards are not being proposed for plants smaller than 500 bpd.
As discussed in Chapter 8f for plants with capacities greater than
500 bpd, the costs of any control alternative are not viewed as being a
detriment to industry expansion, nor are they of the magnitude that
would impose a negative impact on the debt structure of an individual
company. Plants of this size can pass on control costs to the consumer
with little effect on sales. The replacement demand for lead batteries
will remain high since substitutes have not yet been proven feasible for
general use. The original equipment market for lead batteries will not
be affected since the battery cost compared to the final product (e.g.,
automobiles, etc.) is small.
The proposed standards are based on the control of all lead emissions
from lead-acid battery plants by fabric filtration (Alternative I).
This basis was chosen because fabric filters achieve a better degree of
emission reduction than low energy scrubbers at a reasonable cost, and
because, the use of fabric filtration to control all lead emissions from
lead-acid battery plants is possible if spark arresters are used when
necessary and exhaust gases are kept above the dew point,
9-10
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The use of control techniques other than fabric filtration would not
be precluded by the proposed standards. High energy impingement scrubbers
could be used to meet the emission limits. However, these would have
higher operating costs and energy requirements than fabric filters.
Scrubbers would also generate lead contaminated water, which would probably
require treatment prior to disposal.
9.4 SELECTION OF THE FORMAT OF THE PROPOSED STANDARD
In general, lead-acid battery manufacturing facilities may be
considered independent of one another in that there is no continuous
flow of materials. Grid casting operations, lead oxide production
operations, paste mixing operations, lead reclamation operations, and
three-process operations are independent. Also, not all plants have
lead reclamation and lead oxide production operations, and some plants
sell lead oxide.
Because of the independent nature of the facilities, two different
forms were chosen for the proposed standards. The format of the proposed
standards applicable to grid casting, paste mixing, three-process operation,
lead reclamation, and other lead-emitting operations, is a concentration
standard. The format of the standard for lead oxide manufacturing is
mass per unit of lead input.
These forms were chosen for the proposed standards from a group of
several possible formats. The standards could, for example, have been
expressed in terms of grams of lead emissions per 1000 batteries, or in
9-11
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terms of the lead removal efficiency of the emission control system. The
rationale for the choice of the forms of the proposed standards over
other possible forms is discussed in detail below.
9.4.1 Multiple Forms
Each affected facility or each process within an affected facility
could be subjected to standards having different forms. For example,
the standard for paste mixing could be expressed in terms of grams of lead
emissions per kilograms of lead oxide charged to the mixer, whereas the
standard for the three-process operation could be expressed as grams of
lead emissions per 1000 batteries produced. Although this may seem to
be the best approach on an individual process basis, the practice of
exhausting more than one facility to a common cntrol device complicates
the application of different standards to combined gas streams. The
difficulties lie in designating the emissions in an acceptable common
form and determining an allowable limit for the combined processes 'or
facilities,
A standard that also requires that each affected facility be
exhausted to an individual control system would allow various forms to
be applied easily to different processes. However, such a standard, by
requiring several control systems where one may have sufficed, would
increase both the cost of compliance and the cost of compliance testing.
9.4.2 ProcessThroughput
A standard based on an allowable mass of emissions per mass of process
throughput was considered for lead reclamation, three-process operation,
grid casting, and paste mixing. However, though lead throughput can usually
9-12
-------
be determined for each of these processes, emissions depend more on other
factors such as the type of scrap processed by a lead reclamation furnace,
the number (rather than the weight) of plates processed by a grid casting
operation, the method of battery assembly, and the length of the formation
cycle. Also, some of these processes typically share control devices with
other processes. Therefore, a format of process throughput is not proposed
for lead reclamation, the three-process operation, grid casting, paste
mixing, and other miscellaneous facilities.
The device controlling emissions from a lead oxide production facility
is never shared by other processes. Therefore, a standard based on pro-
duction throughput could be applied to this process. Also, the amount of
lead used by the facility can be readily determined. Concentration units
could be applied to the process, but would provide no incentive for the
operator to minimize the amount of air which bleeds into the process,
which operates under negative pressure. For these reasons, the recommended
format of the lead oxide production standard is allowable mass per unit
of lead feed (g/kg).
9.4.3 Common Control System
Consideration was given to a standard that would require all
facilities to be vented to one control system. This would facilitate
compliance testing and would allow placement of all plants on the same
unit basis. A standard with this format might also encourage the reduction
of handling steps and more efficient production techniques to reduce
emissions. If all processes were vented to one system, a single lead
standard could apply to each plant regardless of the production techniques.
There are also disadvantages to implementing a standard that requires a
single control system. It would limit acceptable plant layout designs to
9-13
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those that minimize ductwork to the control device. Also, plants covered
by the modification and reconstruction provisions could not use existing
controls. In addition, these plants might find it impractical to install
the long ducts needed to vent all facilities to a common device. During
compliance tests, a shutdown of one facility would invalidate the test,
and more than one process engineer would be required to monitor normal
operation at all processes during compliance tests.
It is not recommended that a common control system condition be
added to the standard because of possible plant design problems, potential
higher cost of a common control system, and the difficulties associated
with compliance testing.
9.4.4 Removal Eff 1 cjency_Stan_dard
An efficiency format would encourage optimum performance of all
controls. This type of format, however, would double the sampling effort
since both inlet and outlet samples would be required. Also, an increase
in lead control efficiency does not necessarily indicate a decrease in
atmospheric lead emissions.
9.4.5 Concentration Standard
Concentration units [milligrams per cubic meter (grains per dry
standard cubic foot)] are recommended for the standard for grid casting,
paste mixing, three-process operation, lead reclamation", and other lead-
emitting operations.
Concentration units have the disadvantage of being dependent on the air
volume flow rate. In the lead-acid battery industry, the minimim air flow
requirement is dictated by the OSHA in-plant regulation of 50 ug lead/m of
9-14
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air based on an 8-hour time-weighted average. Each process must be ventilated
sufficiently to meet these standards. No data regarding the optimum
ventilation requirements for lead-acid battery manufacturing processes
has been uncovered in this study. A maximum air flow rate would be
limited by the economics of the greater energy requirements to heat and
cool makeup air and the required fan systems. Since the industry is
already acutely aware of the high cost of makeup air, it is unlikely that
dilution will be used to circumvent a standard that requires the presence
of a control device.
On the other hand, gas flow rates are routinely measured as part of
the source test procedures; with these flow rate values, emissions in
concentration units can be calculated easily. Concentration units will
place the standards for the above facilities on a common basis, and thus
will eliminate the problems involved in interpretation of the standards
for processes vented to a common control device.
With the recommended form of the standard, the major processes
common to all battery plants can be assigned a quantitative concentration
limit. Lead reclamation and other lead-emitting operations can be
vented to a common control device and are also assigned a concentration
limit. Standards for the lead oxide production facility, which is not
common to all battery plants, and always has its own control system can
be based on process throughput.
9.5 SELECTION OF EMISSION LIMITS
Table 9-3 summarizes the recommended emission limits that reflect
the degree of emission reduction achievable through the application of
the best system of emission reduction based on the Administrator's
judgment. The cost of achieving the emission reduction, the nonair-quality health
9-15
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Table 9-3. RECOMMENDED EMISSION LIMITS FOR
LEAD-ACID BATTERY PLANTS
Facility
Grid casting
Paste mixing
Three process
PbO mfg
Lead reclamation
Other lead- emitting
operations
Pollutant
lead
lead
lead
lead
lead
lead
Recommended Standards*
0,05 mg/m3 (0.00002 gr/dscf)
1.00 mg/m3 (0.00044 gr/dscf)
1 .00 mg/m3 (0.00044 gr/dscf)
5.0 mg/Kg (0,010 Ib/ton)
2.00 mg/m3 (0.00088 gr/dscf)
1 .00 mg/m3 (0.00044 gr/dscf)
*Recommended standards for lead oxide manufacture are in terms of
allowed emissions per Kg of lead processed, while those for other
facilities are in terms of allowed concentrations in exhaust air.
9-16
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and environmental impacts, and the energy requirements have been taken
into consideration in determining these standards.
The proposed limits for lead emission from grid casting, paste
mixing, three-process operation, lead oxide production, lead reclamation,
and other lead emitting facilities are based on emissions levels attainable
using fabric filtration. In the development of background data for the
proposed standards, atmospheric lead emissions from facilities at four
lead-acid battery plants were measured using the proposed Method 12. In
a previous study, lead emissions from facilities at two lead-acid battery
manufacturing plants and one lead oxide manufacturing plant were measured
using a similar test method.
The emission limit for three-process operation facilities, lead-
oxide production facilities, and other lead emitting facilities are
based on lead levels measured in exhausts from fabric filters controlling
emissions from such facilities. Fabric filters are not currently used
in the lead-acid battery industry to control emissions from grid casting
or lead reclamation; and are not generally used to control emissions
from the mixing phase of paste mixing. The emission limits for grid
casting, paste mixing, and lead reclamation are, therefore, based on
lead levels found in uncontrolled emissions from such facilities, and on
the demonstrated emission reduction capabilities of fabric filters.
Three-process facilities controlled by fabric filters indicated
fabric filter lead collection efficiencies of about 99 percent. Because
particulate emissions from all lead emitting facilities at battery
plants are simliar in composition and particle size, the Administrator
has determined that comparable collection efficiencies can be achieved
for emissions from grid casting, paste mixing, and lead reclamation. It
should also be noted that control efficiencies
9-17
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of 99 percent and greater are achieved by well maintained fabric filters
4 5
in other applications. '
9.5.1 Grid Casting
Impingement scrubbing, rather than fabric filtration, is currently
used in the lead-acid battery manufacturing industry to control emissions
from grid casting. Emissions from grid casting facilities were measured
at two plants. At one of these plants, grid casting emissions were
controlled by an impingement scrubber. At the other, grid casting
emissions were not controlled. The average lead concentration in exhaust
from the uncontrolled facility was 4.37 mg/m (19.1 x 10 gr/dscf).
Average uncontrolled and controlled lead emissions from the scrubber
controlled facility were 2.65 mg/m3 (11.6 x 10~4 gr/dscf} and 0.32 mg/m3
(1,4 x 10 gr/dscf}, respectively. Thus the lead collection efficiency
of the scrubber was about 90 percent.
Fabric filtration can be used to control these emissions if spark
arresters are used and the exhaust gas is kept above the dew point.
Also, because of the low concentration of lead in the exhaust, proper
maintenance of the fabric filter would be important. The lead standard
for grid casting, 0.05 mg/m (0.2 x 10 gr/dscf), is based on the
exhaust concentration achievable using a fabric filter with about 99
percent collection efficiency to control emissions.
9.5.2 Paste Mixing
Lead emissions from a paste mixing facility equipped with an impingement
scrubber were measured. Average uncontrolled and controlled lead concen-
3
trations from this facility were 77.4 mg/m (33!
10.8 mg/m3 (47.0 x 10"4 gr/dscf), respectively.
trations from this facility were 77.4 mg/m (338 x 10 gr/dscf) and
9-18
-------
Fabric filtration is not generally used to control emissions from the ,
entire paste mixing cycle because of the high moisture content of paste
mixer exhaust during the mixing cycle. However, fabric filtration can be
used to control emissions from the entire cycle if the exhaust gas is kept
above the dew point. The proposed lead emission standard for paste mixing,
1 mg/m (4.4 x 10" gr/dscf), is based on the level achievable using a
fabric filter with about 99 percent collection efficiency for the entire
cycle.
In developi»ig data for the proposed standards, EPA conducted tests at
a plant where paste mixing emissions were controlled by two separate systems.
At this plant, paste mixing required a total of 21 to 24 minutes per batch.
During the first 14 to 16 minutes of a cycle (the charging phase), exhaust
from the paste mixer was ducted to a fabric filter which also controlled
emissions from a grid slitting (separating) operation. During the remainder
of the cycle (mixing), paste mixer exhaust was ducted to an impingement
scrubber which also controlled emissions from the grid casting operation.
Uncontrolled or controlled emissions for the paste alone were not tested.
The average concentration of lead in emissions from the fabric filtration
system used to control charging emissions was 1.3 mg/m (5.5 x 10" gr/dscf).
The average lead content of exhaust from the scrubber used to control
mixing emissions was 0.25 mg/m (1.1 x 10" gr/dscf). The average lead
3
concentration in controlled emissions from this facility was about 0.95 mg/m
(4.2 x 10 gr/dscf) which is slightly below the proposed emission limit of 1
mg/m (4.4 x 10 gr/dscf). A lower average emission concentration should be
achieved by using fabric filtration to control emissions from all phases of
paste mixing.
9-19
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9.5.3 Three-Process Operation
The proposed lead concentration limit for three-process operation emissions
is 1 mg/m (4.4 x 10 gr/dscf). This limit is based on the results of
EPA tests conducted at four plants where fabric filtration was used to
control three-process operation emissions. All of these tests showed
lead concentration below the proposed limit in controlled emissions from
the three-process operation facilities.
9,1.4 Lead Reclamation
Lead emissions from a lead reclamation facility where emissions
controlled by an impingement scrubber were measured. The average lead
.concentrations "in the inlet and outlet streams of the scrubber were 227
mg/m3 (990 x 10 gr/dscf} and 3.7 mg/m (16 x 10" gr/dscf), respectively.
The collection efficiency of the scrubber was, therefore, about 98
percent.
Fabric filtration is not currently used to control emissions from
lead reclamation facilities because of the high temperature of lead
reclamation exhaust. However, fabric filters have been applied to hot
exhaust streams at secondary lead smelters and in other industries.
Therefore, the proposed standard for lead reclamation facilities of 2
mg/m (8.8 x 10" gr/dscf), is based on the emission level attainable
using a fabric filter with a collection efficiency of about 99 percent.
9.5.5 Lead Oxide Manufacturing
The proposed standard for lead oxide production is 5 milligrams of
lead per kilogram of lead processed (10 Ib/ton). This limit is based on
the results of tests of emissions from a ball mill lead oxide production
facility with a fabric filter emission control system. The tests showed
an average controlled lead emission rate of 4.2 mg/Kg (8.4 Ib/ton) for
this facility. EPA has not conducted tests of emissions from a well
'controlled Barton process. However, in both the ball mill process and
9-20
-------
the Barton process, lead oxide product must be removed from an air
stream. Also, EPA tests of a Barton process indicated that Barton and
ball mill processes have similar air flow rates per unit production rate
(see Appendix c). Therefore, it has been determined that a similar
level of control could be achieved for a Barton process as has been
demonstrated for the ball mill process.
9,5.6 Other Lead Emitting Ojgerations
Emissions from other lead emitting operations are generally collected
and ducted to minimize worker exposure. Emissions from these operations
are similar in composition and concentration to emissions from non-
automated three-process operations. The proposed standard for other
lead emitting operations is 1 mg/m3 (4.4 x 10" gr/dscf) because emissions
from these operations can be controlled to the same extent as emissions
from three-process operation facilities.
Emissions were measured from a slitting facility which would be
classified as an "other lead emitting operation", controlled by a fabric
filter. Controlled emissions from the fabric filter had an average lead
•5 4
content of 0.938 mg/m (4.1 x 10 gr/dscf), which is below the proposed
emission limit for other lead emitting operations.
9.6 OPACITY STANDARDS
A standard of 0 percent opacity is proposed for emissions from all
affected facilities in order to ensure proper operation of emission
control equipment. Grid casting, paste mixing, three-process operation,
and lead oxide manufacturing facilities were observed by EPA to have emissions
with 0 percent opacity during periods of. 7 hours and 16 minutes; 1 hour
and 30 minutes; 3 hours and 51 minutes; and 3 hours and 19 minutes,
respectively. Emissions ranging from 5 to 20 percent opacity were
observed for a total of 11 minutes and 15 seconds during 3 hours and 22
minutes of observation at the lead reclamation operation source tested
9-21
-------
by EPA, which was controlled by a low-energy scrubber. However, the
proposed standard is based on control of this process by a fabric filter,
similar to three-process operations and paste mixers for which emissions with
0 percent opacity have been observed. A standard of 0 percent opacity is,
therefore, also proposed for emissions from lead reclamation furnaces.
Under the proposed standards, opacity would be determined by taking the
average opacity over a 6-minute period using EPA Test Method 9, and rounding
the average to the nearest whole percentage. The rounding procedure is
specified in the proposed standards in order to allow occasional brief emissions
with opacities greater than 0 percent. When a fabric filter is used to
control emissions, the outlet concentration from the filter may increase
immediately after a component filter bag is cleaned. In the case of a lead-
acid battery plant, filter cleaning may result in occasional emissions with
opacities greater than 0 percent. Under Method 9, individual opacity readings
are rounded to the nearest 5 percent. However, the average accuracy of any
particular opacity reading is + 7.5 percent opacity. Therefore, the opacity
of low level visible emissions during filter cleaning would be interpreted to
be 5 percent or greater. If the rounding off procedure were not specified,
one opacity reading of 5 percent during a 6-minute period could be considered
as indicative of a violation of the proposed 0 percent opacity standard.
However, the Administrator does not intend for occasional emissions greater
than 0 percent opacity occurring during filter cleaning to be considered
violations of the proposed standards. Therefore, the standards would specify
that the average opacity be rounded to the nearest whole percentage. With
this specification, 6-minute average opacities less than 0.5 percent would
not be considered violations of the proposed standards. Emissions which
result in 6-minute average opacities of 0.5 percent or greater are expected
to be indicative of fabric filter malfunctions rather than filter cleaning
emissions. 9-22
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9.7 MODIFICATIONS/RECONSTRUCTION CONSIDERATIONS
Emission limitations promulgated under Section m(b) of the Clean
Air Act {New Source Performance Standards or NSPS) apply to modified and
reconstructed facilities as well as to new facilities. The definitions
of modification and reconstruction and the applicability of these provisions
to the lead-acid battery industry are discussed in detail in Section 5.1.
Basically, with certain exceptions, a modification occurs when a physical or
operational change to an existing facility results in an increase in the
emission rate to tht: atmosphere of any pollutant to which an NSPS applies.
Irrespective of any change in pollutant emission rates, a replacement
of components of an existing facility may be deemed a reconstruction of
that facility if (1) the fixed capital cost of the new components exceeds
50 percent of the fixed capital cost that would be required to construct
a new facility, and (2) it is technologically and economically feasible
to meet the applicable standards. One such case could be the replacement
of the motor, paddle wheel, and shell of a paste mixer. These repairs would
likely exceed 50 percent of the cost of a new paste mixing facility.
The enforcement division of the appropriate EPA regional office should
be contacted whenever a source has questions regarding modification or
reconstruction. Their judgement will supercede any general examples that
can be given in a document such as this.
9.8 SELECTION OF MONITORING REQUIREMENTS
To provide a convenient means for enforcement personnel to ensure
that an emission control system installed to comply with standards of
performance is properly maintained and operated, monitoring requirements
are generally included in standards of performance.
9-23
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Continuous opacity monitoring is not recommended for lead battery
plants because EPA has not determined performance specifications for
opacity monitoring for this application. Because even uncontrolled
emissions are generally invisible, it is unlikely that available instruments
could detect control device malfunction by an opacity change for affected
facilities. Also, continuous monitors that directly measure lead concen-
trations are not commercially available. An indication of proper operation
of a scrubber or a,fabric filter that can easily be monitored is the
pressure drop across the device. This indicator can be continuously
monitored with a pressure gauge and strip chart. The installed cost
would be less than $2000 with about $400 per year required for operation
and maintenance expenses.
Records of the pressure drops for each control device should be-
kept up to 2 years before discarding. A decrease in pressure drop of
about 50 percent could indicate a decrease in lead removal efficiency
because of either a fabric filter bag failure or a decrease in scrubber
liquid-to-gas ratio. During plant visits, enforcement personnel can
examine the pressure charts to determine possible control device malfunctions,
9.9 SELECTION OF PERFORMANCE TEST METHODS
Proposed EPA Reference Method 12, "Determination of Lead Emissions
from Stationary Sources;" and EPA Method 9, "Visual Determination of the
Opacity of Emissions From Stationary Sources" were selected as the
performance test methods to determine compliance with standards of
performance limiting lead, and opacity, respectively, from lead battery
plants. Methods 1,2, and 4 are also used for sample and velocity
ttraverses, velocity and volumetric flow rate, and stack gas moisture.
9-24
-------
Proposed EPA Hethod 12 is essentialy the same method as was used in
gathering the NSPS data, except that it has been revised to include the
revisions to Method 5 (Federal Register, August 18, 1977). These
revisions were made to make the methods easier to use and to assure that
good testing practices were followed. The test results that were obtained
before the revisions followed good test practices and will not be affected.
Reputable testing firms were used for the lead-battery manufacturing
test program; the results obtained are accurate and reliable. Method 12
was developed by the EPA because of the low levels of lead anticipated
at the outlet of lead source control devices. This method has greater
sensitivity to lead concentrations than atomic absorption analysis of a
sample of particulate collected by Method 5.
Method 9 was selected for monitoring opacity. This method was used
in the test program and was judged to be applicable to lead battery
plants. The method is complete as to methodology, and provides consistent
procedures to be applied to all plants tested for compliance with the
NSPS,
During all tests, a process engineer should be stationed inside the
plant to assure normal operation. When the paste mixer is vented to two
control devices, a process engineer must coordinate the process operation
with compliance tests. Process downtimes are normally of short duration
and should not invalidate the compliance test.
If different processes within a three-process operation facility
are controlled by different control devices, source tests must be run on
all applicable stacks and an equivalent concentration determined. Total
lead emissions from all the stacks can be determined and divided by the
total exhaust flow rate. This equivalent concentration can then be
compared with the standard.
9-25
-------
To determine compliance when two or more facilities at the same
plant are ducted to a common control device, the exhaust rate from each
source and the controlled lead concentrations must be measured. An
equivalent standard for the applicable facilities can be calculated by
multiplying each applicable standard by the fractional exhaust flow rate
of that facility and adding the numbers. This equivalent standard can
then be compared with the measured concentration to determine compliance.
During performance tests on the lead oxide manufacturing the process
feed rate must be recorded. This is needed so that lead emission rates
for the lead oxide manufacturing process can be expressed in terms of
process throughput and compared with the NSPS.
9-26
-------
REFERENCES FOR CHAPTER 9
1. Data developed by JACA Consulting, Inc., Philadelphia, Pennsylvania,
under EPA Contract No. 68-02-2804 in Support of Lead Ambient Air
Standard.
2, Thakker, B. Screening Study to Develop Background Information and
Determine the Significance of Emissions from Lead Battery Manufacture.
Vulcan-Cincinnati, Inc. Prepared for the U. S. Environmental Protec-
tion Agency under Contract No. 68-02-0299, Task No. 3. December 1972.
p. 16.
3. Boyle, T. F., and R. B. Reznik. Lead-Acid Batteries, Source Assess-
ment Document No, 17. Prepared by Monsanto Research Corporation,
Dayton, Ohio, for the U. S. Environmental Protection Agency.
Cincinnati, Ohio. Contract No. 68-02-1874. June 1976 (Draft), p. 42.
4. Compilation of Air Pollutant Emission Factors, Third Edition. U. S.
Environmental Protection Agency. AP-42. August 1977.
5. Air Pollution Engineering Manual. U. S. Environmental Protection
Agency. AP-40. 1967.
9-27
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APPENDIX A
EVOLUTION OF THE SELECTION OF THE
BEST SYSTEMS OF EMISSION REDUCTION
In development of Standards of Performance for lead-acid
battery plants, emissions from selected plants were sampled to
help determine the best demonstrated control technology available
for new plants. The following steps were involved:
1) Selection of candidate best-controlled plants.
2) Selection of plants to be source tested.
3) Selection of test procedures.
4) Sampling of emissions.
5) Analysis of samples, resolution of data, and develon-
ment of recommendations.
A chronology of these events is presented in Table A-l.
A.I SELECTION OF CANDIDATE BEST-CONTROLLED PLANTS
The best controlled lead-acid battery plants were selected
by identifying the major emission sources of concern in the
industry and then identifying plants that control emissions from
these sources effectively. Information was obtained from source
test emission data, industry manuals and publications, earlier
surveys, and literature on air pollution control and process
A-l
-------
Table A-l.
CHRONOLOGY OF EVENTS LEADING TO THE BACKGROUND DOCUMENT FOR
NEW SOURCE PERFORMANCE STANDARDS FOR LEAD-ACID BATTERY PLANTS
Date
Event
July 29, 1975
August 5, 1975
August 5, 1975
August 28, 1975
August-September, 1975
September 8, 1975
September 9, 1975
October 20, 1975
October 21, 1975
October 22, 1975
October 23, 1975
November 11, 1975
November 18, 1975
Initial meeting for study regarding
Lead Industry New Source Performance
Standards at EPA offices in Durham,
North Carolina.
Meeting with Mr. John Bitler,
Chairman of the Air and Water
Standards Committee, Battery Council
International (BCI) in Reading,
Pennsylvania.
Visit to General Battery Corporation,
Reading, Pennsylvania.
Written requests for information
regarding lead-acid battery facili-
ties mailed to state air agencies.
Written requests for information
regarding lead-acid battery facili-
ties mailed to industry representatives.
Interim Report No. 1 completed,
(Contractor) Project Manager attended
Chicago meeting of BCI Air and
Water Standards Committee.
Visit to Plant G.
Visit to Plant B.
Visit to Plant D.
Visit to Plant F.
Visit to Plant E.
Visit to Plant C.
A-2
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Table A-l (continued).
Date
Event
December 5, 1975
December 31, 1975
February 16, 1976
June 14-24, 1976
August 16-20, 1976
August 23-26, 1976
February 8-10, 1977
April 18-22, 1977
September 27-28, 1977
September 27, 1978
May 1979
Visit to Plant A.
Interim Report No. 2 completed.
Meeting for review of Interim
Report No. 2 at EPA offices in
Durham. Best-controlled plants
selected for source testing.
Source tests conducted at Plant D.
Grid casting, paste mixing, and
three-process-operations were
tested.
Source tests conducted at Plant
B. Three-process-operations
and lead oxide production were
tested.
Source tests conducted at Plant
G. Formation and lead reclamation
processes were tested.
Visits to formation facilities at
ESB, Inc., Allentown, Pennsylvania;
and General Battery Co. in City of
Industry, California.
Source tests conducted at the forma-
tion process of Plant L.
National Air Pollution Control
Techniques Advisory Committee
Meeting (NAPCTAC), Alexandria,
Kentucky.
EPA Working Group Meeting, Durham,
North Carolina.
Steering Committee Review
A-3
-------
equipment. More than 60 representatives of battery manufacturing
companies, trade associations, and air pollution control agencies
were contacted through verbal and written communications.
A.1.1 Pollutant Selection
Emissions from lead-acid battery operations are primarily
particulate matter containing lead and lead oxide, and sulfuric acid
fumes. The available data indicate that emissions from uncontrolled
processes could cause ambient levels of lead to exceed 5 pg/m3 (24-
hr average) in the vicinity of the larger plants. These levels may
cause symptoms of lead poisoning to appear in certain individuals.
Emissions of sulfuric acid mist are sensibly detectable at some
formation facilities. Plant discharges are generally invisible even
when uncontrolled, and particulate emission rates are well below
state standards.
Lead was selected as a pollutant for control because of the
potential impact of uncontrolled emissions. Because the acid mist
emission rate from battery plants was found to be very low, acid mist
was not selected for control.
A.1.2 Plant Se1ection
After selection of the pollutants of concern, the plants that
best control these pollutants were identified. Eight plants were
selected by consultation with representatives of all the major battery
manufacturers, the two battery trade associations, the lead trade
association, and state air regulatory agencies. The investigating
team visited these plants to determine the facilities to be recom-
mended for source testing. Table A-2 lists the plants and their
locations.
A-4
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TABLE A-2. LEAD-ACID BATTERY PLANTS SELECTED
FOR INVESTIGATION
Plant Location
General Battery Corporation Reading, Pennsylvania
General Battery Corporation Los Angeles, California
ESB Incorporated Buffalo, New York
ESB Incorporated Allentown, Pennsylvania
ESB Canada Limited Mississauga, Ontario,
Canada
Globe Union Canby, Oregon
Estee Battery Company Los Angeles, California
Douglas Battery Manufacturing Winston-Salem, North
Carolina
Delco Battery Manufacturing Anaheim, California
Standard Electric Company San Antonio, Texas
A.2 SELECTION OF PLANTS TO BE TESTED
Process and emissions information was obtained during tours
of the candidate plants. On the basis of this information,
processes from four lead-acid battery plants were recommended
for source testing. The recommendations were based on the degree
of emissions or process control exercised at the plants and on
locations of the source test sites. Relative control effici-
encies were evaluated through conversations with plant operators,
review of available test data, and visual observations. Table
A-3 lists the processes, test locations, and control systems
selected for source testing.
A-5
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TABLE A-3. PROCESSES, TEST LOCATIONS, AND CONTROL SYSTEMS
RECOMMENDED FOR SOURCE TESTING
Plant
Process
Grid casting
PbO manufacture
Paste mixing
Three-process
operations
Lead reclamation
Formation
D
B
D
D
B
Control
device
Roto-Clone
Baghouse
Roto-Clone
(mixing cycle)
Baghouse
(materials charging)
Baghouse
Baghouse
Cascade
scrubber
Packed bed
mist eliminator
Foam 4- scrubber
mist eliminator
Test
locations'
Inlet
Outlet
Outlet
Inlet
Outlet
Inlet
Outlet
Inlet
Outlet
Inlet
Outlet
Inlet
Outlet
Outlet
Inlet
Outlet
Locations relative to control device.
A. 3 SELECTION OF TEST PROCEDURES
Standard EPA test methods were available for the pollutants
of concern. The EPA Methods provide detailed sampling methodology.
Selection of the sampling site and the number of sampling points
were well defined. This level of detail was considered necessary
for compliance testing to minimize subjectivity and to ensure
accuracy, reproducibility, and representativeness.
A-6
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Unlike in-stack filter methods such as the ASME PTC27 Method
and WP-50 Method, EPA specifies all-glass construction except for
the probe. A glass probe is required only if the probe length
is less than about 8 feet and stack temperatures do not exceed
1320°C (608°F). This will usually be the case in battery plants.
Glass equipment is believed superior because it is less reactive.
Therefore, it was decided that the EPA methods would be used
for determination of lead and sulfuric acid emissions and of
opacities. EPA Methods 5 and 8 were recommended for collection
of particulate and sulfuric acid mist emissions, respectively.
The lead content of the particulate sample collected by Method 5
was then determined by atomic absorption analysis.
A proposed EPA Method 12 was developed for testing lead emis-
sions at the outlet of the control device because of the low con-
centrations anticipated at that point. The method was developed
to provide greater sensitivity. To confirm the accuracy of the
proposed Method 12 for lead-acid battery plant lead emissions,
EPA personnel decided to run two sample trains concurrently to
determine lead emissions from control device outlets, one train
extracting the sample in accordance with EPA Method 5 and the
other incorporating .a nitric acid impinger train followed by a
filter.
The recommended test methods were complete as to both
•sample extraction and analysis. In addition to the analyses
specified in the EPA test methods, particle size classifications
A-7
-------
were performed by use of impactors, arid samples of trace elements
were collected. Process data were collected from plant produc-
tion records and by direct observation,
A.4 DEVELOPMENT OF THE DATA BASE FOR THE STANDARD
Source tests were conducted at the three selected plants
during June and August 1976, and April 1977. Results of these
tests are summarized in Appendix C. These data, along with
values delineating the cost and environmental impacts of several
levels of emission control, were presented to the National Air
Pollution Control Techniques Advisory Committee (NAPCTAC) in
1977.
A-8
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APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency guidelines for preparing regulatory
action Environmental impact Statements
(39 Fr 37419; October 21, 1974)
Location within the standards support
and Environmental Impact Statement
Background and description of proposed action;
Summary of proposed standards.
statutory basis for proposed standards.
Relationship to other regulatory agency
actions.
Industry affected by the proposed standards.
Specific processes affected by the standard,
Alternatives to proposed standard.
Environmental impact.
The proposed standards are summarized in
Chapter 1, section 1.1.
The statutory basis for the proposed
standards is summarized in Chapter 2,
The various relationships between the
proposed standards and other regulatory
agency actions are summarized in Chapter 2,
A discussion of the industry affected by the
standards is presented in Chapter 3, section
3.1. Further details covering the "business/
economic" nature of the industry is presented
in Chapter 8.
The specific processes and facilities affected
by the proposed standards are summarised in
Chapter 1, Section 1.1. A discussion of the
rationale for selecting these particular pro-
cesses or facilities is presented in Chapter
9, Section 9.2,2, A detailed technical dis-
cussion of the sources and processes affected
by the proposed standards is presented in
Chapter 3, Section 3.2 through 3.1,
h discussion of the alternative emission
control systems and their effectiveness is
presented in Chapter 6. The costs associated
with these systems are presented in Chapter 8,
Section 8.2.
Estimates of primary and secondary impact of
the proposed standards are discussed in Chapter
7.
-------
APPENDIX C
SUMMARY OF TEST DATA
Four lead-acid storage battery plants were tested by EPA to
evaluate the best control techniques for controlling lead emis-
sions from grid casting, paste mixing, three-process operation,
lead oxide manufacturing, and lead reclamation. Also, a vat-type
formation process (dry formation) was tested for emissions of
sulfuric acid mist. .A brief description of each plant and a
summary of the test results are presented in Sections C.I through
C.4.
C.I PLANT B '• .
P.lant B has a normal operating output of 3500 bpd, with a
maximum of 4500 bpd.
The major operations are lead oxide production, grid cast-
ing, paste mixing, battery assembly (the three-process opera-
tion) , and formation. Figure C-l illustrates the general flow of
material through Plant B.
The plant manufactures lead oxide by the ball mill process,
operating two production lines 5 days per week, 24 hours per day.
The normal feed rate for each production line is fifteen 100-
pound lead pigs per hour {3000 Ib/hr total). The pigs are fed
into a Harding rotary mill, which tumbles the pigs to form lead
C-l
-------
--£> "S
L
4J
d
&
g
-------
oxide. The material is then screened with a vibrating rotary
screen and milled with a Raymond impact mill? the product, col-
lected with a cyclone, consists of approximately 70 percent lead
oxide and 30 percent lead. Each lead oxide production line is
equipped with two baghouses to provide particulate control and
also to collect the product that is not retained by the cyclone
separator. Water sprays maintain rotary mill temperatures at
about 210°C (410°F).
Production line 1 is controlled by two Mikropul two-compart-
ment baghouses, each having air-to-cloth ratios of 2/1 with both
compartments on line. One baghouse controls the screens that
follow the rotary mill, and the other controls the product re-
covery cylone separator and the barrel filling station. The
felted dacron bags are cleaned in each compartment every 15
minutes by shaking. During shaking the air-to-cloth ratio is
4/1. These units were rebagged in April 1976.
Lead oxide production line 2 is controlled by two Mikro-
pulsaire baghouses (model no. 64S-6-POTR), each having air-to-
cloth ratios of 4/1. One baghouse controls the screens following
the rotary mill and the other controls the product recovery
cylone separator, a vibrating screen following the cyclone, and
the barrel filling station. The felted dacron bags are continu-
ously cleaned by pulse jet.
Exhausts from all four baghouses are combined and released
to the atmosphere through a 15-m (50-ft) stack.
C-3
-------
The grid casting facility consists of four machines. Each
grid cast makes two battery plates after pasting and slitting.
The cast grids are taken to the grid pasting machine, where both
positive and negative pastes are applied to the grids. After
pasting, these double plates are dried, slit in half to make two
plates, stacked, and formed.
The paste is produced by mixing dry lead oxide powder,
water, and sulfuric acid in two 907-kg/hr (2000-lb/hr) paste
mixers. Each mixer is controlled by a separate low-energy
impingement-type wet collector designed for. a pressure drop of
1992 to 2490 Pa (8-10 in. W.G.) at 56.6 m3/min (2000 acfm).
The plates used in the dry battery production line are
formed in vats of sulfuric acid. After charging, or forming, the
plates are rinsed, slit, and stored.
Plates for both wet and dry batteries are processed simi-
larly in the three-process operation. The plates and separators
are automatically or manually stacked in the proper sequence.
Plant B has four hand stacking stations and two automated sta-
tions, (a Reed stacker and a Winkel stacker). Leads (pronounced
leeds) and posts are cast on some of these stacks of plates to
form elements. Two automatic element assembly units (cast-on-
strap machines) are used. The balance of the stacks of plates
are processed on a proprietary system, in which the stacks are
inserted into specially constructed battery cases and the leads
and posts are connected to the plate stacks at a burning station.
C-4
-------
The three-process operation is controlled by a Mikro-pulsaire
(Model No. IIP 26410) baghouse. Ducts from each process are
joined into a 0.76 m (30-inch) duct, and the baghouse exhausts
through a 15-m (48-foot) stack that is 0.76 m (30 in.} in diameter.
The baghouse is bagged with felted bags and is rated at 566
m3/min (20,000 acfm) with an air-to-cloth ratio of 6.5/1. The
felted bags are continuously cleaned by pulse jet.
Following the three-process operation, batteries from the
dry battery line are washed, painted, and sent to shipping;
batteries from the wet production line are sent to be formed.
These batteries are filled with dilute sulfuric acid and formation
is initiated. After the batteries are formed, the acid is re-
placed with fresh acid. The wet formed batteries are then given
a boost charge, washed, painted, and sent to shipping.
At Plant B, source tests were performed on the three-process
operation and the lead oxide production facility. The test
results are summarized in Tables C-l and C-1A.
Qualified observers were present during the tests and saw no
visible emissions from the stacks being tested.
C.2 PLANT D
Plant D has a normal operating output of 2400 bpd with a
maximum of 4000 bpd. The plant is a conventional wet-battery
operation, except that the finished units are sent to another
plant for formation. Figure C-2 is a schematic diagram of Plant
D production flows.
C-5
-------
Table C-l. TEST RESULTS SUMMARY FOR PLANT B (METRIC UNITS)
Process
Three-process
Lead oxide mill
Test
No,
1
2
3
AVC.
4
S
6
AVG.
Exhaust flow,
m^/min
Inlet
504
516
516
512
N/M
N/M
N/M
N/H
Outlet
580
565
567
571
65
67
67
66
Exhaust flow,
sm^/min
Inlet
530
547
548
542
N/M
N/M
N/M
N/H
Outlet
580
599
604
594
76
78
78
77
Pb concentration,
rng/rnS
Inlet
29.9
33,6
19.9
27.9
H/M
H/M
N/M
N/H
Outlet
0,444
0,0732
0.0435
0,188
1.13
2.27
1.12
1.51
Pb emissions,
kg/hr
Inlet
0.903
1,043
0.621
O.B56
N/M
H/M
N/H
N/H
outlet
0,016
0,003
0.001
0.007
0.005
0.010
0,005
0.007
Process
through-
put
0,28a
0,283
0.283
0,28a
1361b
136113
1361*>
1361b
Emission
factor
q/ throughput
Inlet
3225
3724
2218
3056
N/M
N/M
N/M
N/M
Outlet
S6.;:5
9.07
5.44
23.59
3.18
6.35
3. 18
4.29
Control
efficiency
*
98, 3
99.76
99.75
99,3
N/M
N/M
N/M
N/M
o
I
Cft
a 1000 batteries/hour
b kg of lead input/hour
w/M -Not Measured
-------
Table C-1A. TEST RESULTS SUMMARY FOR PLANT B {ENGLISH UNITS)
Process
Three-process
Lead oxide mill
Test
No.
- 1
2
3
AVG.
4
5
6
ftVG,
Exhaust flow,
dscfm
Inlet
17,800
18,210
Outlet
20,490
19,950
18,210 20,010
18,070
N/M
N/M
N/M
N/M
20,150
2,310
2,370
2,370
2,350
Exhaust flow,
acfra
Inlet
18,710
19,320
19,360
19,130
N/M
N/M
N/M
N/ri
Outlet
21,340
21,150
21,340
21,280
2,680
2,760
2,750
2,730
Pb concentration,
gr/dscf
Inlet
0.0131
0.0147
0.0087
0.0122
N/M
N/M
N/M
N/M
Outlet
0,000194
0.000032
0.000019
0.000082
0.000494
0.000994
0.000489
0 .000659
Pb emissions,
Ib/hr
Inlet
1.99
2,30
1,37
1.89
N/M
N/M
N/tl
N/M
Outlet
0.0347
0.0056
0.0033
0.0145
0.0105
0.0217
0.0106
0.0143
Process
through-
put
0.28a
0.28a
0,28a
0.28a
l.Sb-
1.5l>
1.5b'
l.Sb
Emission
factor
lb/'throu$hput
inlet
7.11
8.21
'4,89
6.74
N/M
N/M
N/H
N/M
Outlet
0,124
0.020
0.012
0.052
0.007
0.014
0.007
0 .009
Control
e£ f. ic iency
%
98 . 3
99.76
99.75
99. 3,
:;/:•'.
VM
:•:/:-<.
Q
a 1000 batteries/hour
k Tons of lead input/hour
N/M - Not Measured
-------
o
I
CURING
PASTED
PLATES
STACK
No, 6
STACK
No. 1
! t
PftNEt
SLITTING
MACHINES
|
PANEL
DRYING
OVENS
PAiJiL
PASTtN-j
MAO" IKES
_t STA
«* —
i
CKif
STACK No. 3
BlO'aER OUTLET
PRIMARY SEPARATOR
SYSTEM ._
SECONDARY
BAY SEPARATORS
INLET
OTOCtONE
CENTRAL VACUUM SYSTEM
Figure C-2. Production flow diagram, Plant D.
-------
The plant operates three Wirtz grid-casting furnaces, each
with three grid casters (a total of nine casters) vented to a
common stack. The exhaust ducting is designed for a fourth
furnace. A small-parts casting furnace connects to the main
casting exhaust system, which is cleaned by an American Air
Filter Type N Roto-Clone system {size 24, Arrangement D). The
small parts produced are battery element straps used at the
Tiegel burning machine.
Plant D is operating one Beardsley and Piper paste mixer,
although two identical mixers were originally installed. The
second mixer, transfer conveyor, dryer, and curing station have
been removed. The common components, such as the baghouse and
lead oxide hopper, were designed as part of the mixer system.
Positive batches require 1088 kg (2400 Ib) of lead oxide; nega-
'
tive batches require 816 kg (1800 Ib) of lead oxide.
The paste mixer exhaust vents to two separate control
systems. As the lead oxide is dumped, the gases are vented
through an American Air Filter Type 3-96 baghouse, equipped with
a 56 -;W (75-hp) fan. This baghouse has three compartments,
with a .total of 636 bags. Total cloth area is 813 m2 (8755 ft ),
yielding an air-to-cloth ratio of 3.3/1. One compartment is
closed for .approximately 1 minute each 30 minutes for shaking.
The air-to-cloth ratio during shaking increases to 4.9/1. The
exhaust gases are rerouted during mixing via an automatic damper
to the AAF Type N Roto-Clone, which also cleans the casting
operation exhaust gas.
C-9
-------
The paste is continuously applied to the grids as they are
automatically fed to the pasting machine. The pasted grid is
then dried, slit (each grid becomes two plates after pasting and
slitting)» and stacked. The pasting operation is not vented, but
the drying operation is. Slitting and stacking operations are
vented to the same baghouse that controls the mixer during the
portion of the mixing cycle when dry ingredients are added to the
mix. The slitting machine can handle 23,500 plates per hour. A
spare slitting machine that is used periodically is also vented
to the baghouse. This machine was idle during the tests, and its
exhaust system was dampered from the baghouse.
The plates are stacked in the proper sequence and joined on
three production lines. Two of these lines are equipped with
mechanical stackers and a COS machine that casts the straps onto
the elements. The other line uses a mechanical stacker, but the
elements are joined by burning on leads with a Tiegel machine,
which operates much more slowly than the COS machines. The COS
machines produce six-celled batteries exclusively; the Tiegel
machine produces industrial batteries with three, four, and six
cells. Vents from the assembly area enter a common 0.914-m (36-
in.)- diameter manifold, which connects to an AAP Type 3-106
baghouse equipped with a 75 kW (100-hp) fan. Total cloth area
is 9757 square feet, yielding an air-to-cloth ratio of 3.3/1.
One compartment is closed for approximately 1 minute each 30
minutes for shaking. The air-to-cloth ratio during shaking .
increases to 4.9/1. The assembly area hoods and ducts were
designed to capture particulate emissions.
C-10
-------
Tests were performed on the grid casting, paste mixing, and
the three-process operation at Plant D, The results are sum-
marized in Tables C-2 and C-2A. Qualified observers were present
during the tests and saw no visible emissions from the stacks
being tested.
C.3 PLANT G
Plant G has a capacity of 1800 bpd and a normal operating
output of 1500 bpd. The major facilities include grid casting,
paste mixing, the three-process operation, and formation. There
is also a small parts casting unit and a lead reclaim pot. Both
wet and dry batteries are produced. Figure C-3 is a schematic
diagram of Plant G production flow.
Grids are cast on six grid casting machines, which receive
lead from two melting pots. This process is not controlled.
One paste mixer is used for both positive and negative
pastes. The mixer emissions are controlled by a Schneible, type
F61BL, low-energy cascade type, 116-m /min {4100-acfm) wet scrub-
ber with a pressure drop of about 1743 to 1992 Pa (7 to 8 in.
W.G.).
Finished grids are pasted, dried, and stored. The plate
drying ovens are vented to the atmosphere by natural draft. The
dried plates can be sent to formation if they are to be used in
making dry batteries or to the three-process operation for:use in
wet batteries.
C-ll
-------
Table C-2. TEST RESULTS SUMMARY FOR PLANT D (METRIC UNITS)
Process
Three-process
operation
Grid casting
(Roto-Clone
controlled)
Grid casting
and full
mixing cycle
(Roto-Clone
controlled)
Grid casting
and mixing
(Roto-Clone
controlled)
Slitting
(Baghouse con-
trolled)
Slitting and
full mixing
cycle (Baghouse
controlled)
Slitting and mixer
charging (Bag-
house controlled)
Test
No,
1
2
3a
AVG.
fib
7b
12=
13t>
ftVG.
4
7b
I3b
15
AVG,
5
6b
14
AVG.
10
9
8
11
AVG,
Exhaust flow,
fli-Vitiin
Inlet
964
893
897
918
414
399
' 437
438
422
435
N/M
N/M
477
456
435
N/M
482
458
631
649
681
671
676
Outlet
803
698
805
769
N/M
N/M
473
N/M
473
469
462
487
526
506
452
459
485
465
685
702
685
697
691
Exhaust flow,
amVrnin
Inlet
981
918
920
940
502
480
515
499
499
499
N/M
N/M
548
524
498
N/M
548
523
733
699
726
708
717
Outlet
809
700
808
772
N/M
N/M
496
N/M
496
498
512
525
562
524
490
504
505
500
693
712
689
691
690
Pb concentration,
rog/rn3
Inlet
40.0
53.5
2,44
31.9
0.89
1.01
5.86
2.81
2.65
25.5
N/M
N/M
2.43
14.0
1.60
N/M
3.18
2.38
43.1
66.6
115
33.7
74.6
Outlet
0.664
1.01
0.664
0.778
N/M
N/M
0.320
N/M
0.320
0.275
0.252
0.206
0.'229
0.229
0.160
0.2S2
0.320
0,252
0.938
1.17
1.17
1.35
1.26
Pb emissions,
kq/hr
Inlet
2.309
2.862
0.132
1.768
0.022
0.024
0.154
0.077
0.069
0.696
N/M
N/M
0.072
0.384
0.044
N/M
0.096
0.070
1.838
2.709
4.925
1.416
3.170
Outlet
0.032
0.042
0.032
0.035
N/M
N/M
0.009
N/M
0.009
0.008
0.007
0.006
0.008
0.007
0.005
0.007
0.010
0.007
0.028
0.051
0.050
0.059
0.054
Emission factor,
g Pb/1000
batteries
Inlet
9661
11935
549
4481
92
100
644
308
286
2784
N/M
N/M
289
1536
174 '
N/M
384
279
7340
10845
19700
5680
12690
Outlet
134.5
176.1
134.5
148.4
N/M
N/M
37.9
N/M
37.9
32.2
28.4
24.6
30.3
28.9
18.0
28.4
25.6
24.0
113.7
204.6
200.8
234.9
217.8
Control
efficiency
%
98.6
98.5
75.5
90.9
n/::
N/M
94.1
N/M
94.1
98.8
N/K
N/K
89.5
94.2
89.6
N/M
89.7
89.6
98.5
98.1
99.0
96.0
97.5
o
I
I-1
a Several equipment downtimes during test.
b inlet tested prior to merger of grid casting and mixing exhaust.
c Filter broke. Catch was still collected.
N/M - Not Measured
-------
Table C-2A. TEST RESULTS SUMMARY FOR PLANT D (ENGLISH UNITS)
Process
Three-process
Operation
Grid Casting
(Koto -Clone
controlled )
Grid Casting
and full
mixing cycle
(Roto-Clone
controlled)
Grid Casting
and mixing
(Roto-Clone
controlled)
Slitting
(Baghouse con-
trolled)
Slitting and
full mixing
cycle (Baghouse
controlled)
itting and mixer
larging (Bag-
ouse controlled)
Test
No.
1
2
3a
AVG.
6K
7b
12C
U*>
AVG.
4
7b
13b
15
AVG.
5
6b
14
AVG.
10
9
8
11
AVG.
Exhaust flow,
dscfm
Inlet
34,026
31,525
31,074
32,408
14,609
14 ,095
15,432
15,484
14,905
15,359
N/M
N/M
16,852
16,105
15,347
N/M
17,032
16,190
24,038
22,935
24 ,064
23,701
23,882
Outlet
28,366
24,641
~3,4i3
27,140
N/M
N/M
16,718
N/M
16,718
16,569
16,313
17,208
18,559
17,162
15,949
16,219
17,130
16,433
24,179
24 ,806
24,180
24 ,614
24,397
Exhaust flow,
acftn
Inlet
34,660
32,423
32 , Suw
33,194
17,724
16,934
18,199
17,627
17,621
17,651
N/M
N/M
19,358
18,494
17,599
N/M
19,353
18,476
25,882
24,679
25,636
24 ,996
25,316
Outlet
28,572
24,712
23 ,523
27,269
N/M
N/M
17,521
N/M
17,521
17,594
18,073
18,548
19,849
18,516
17,312
17,787
17,842
17,647
24,485
25,142
24,346
24,391
24,368
Pb concentration,
gr/dscf
Inlet
0.01746
0.02334
u . uulub
0.01395
0.00039
0.00044
0.00256
0.0012'}
0.00116
0.01114
N/M
N/M
0.00106
0.00610
0.00070
N/M
0.00139
0.00104
0.01884
0.02909
0.05046
0,01471
0.03258
Outlet
0.00029
0.00044
U.OUO29
0.00034
N/M
N/M
0.00014
N/M
0.00014
0.00012
0.00011
0.00009
0.00010
0,00010
0.00007
0.00011
0.00014
0.00011
0.00041
0.00051
0.00051
0.00059
0.00055
Pb emissions,
Ib/hr
Inlet
5.09
6.31
0. 29
3.90
0.0488
n.ns32
0.339
0.163
0.151
1.47
N/M
N/M
0.153
0.811
0.0921
N/M
0.203
0.1476
3.88
5.72
10.4
2.99
6.70
Outlet
0,071
0.093
0.071
0.078
N/M
W/M
0.020
N/M
0.0^0
0.017
0.015
0.013
0.016
0.015
0.0096
0.015
0.021
0.015
0.060
0.108
0.106
0.124
0.115
Emission factor
Ib Pb/1000
batter i-cs
Inlet
20.4
25.2
1.16
15.6
0.195
0.213
1.36
0.652
0.605
5.88
N/M
N/M
0.612
3 .24
0.368
N/M
0.812
0.590
15.5
22.9
41.6
12.0
26.8
Outlet
0.284
0.372
0,284
0.313
N/M
N/M
0.08
N/M
0.08
0.068
0.060
0.052
0.064
0.061 '
0.038
0,060
0.034
0.061
0.24
0.432
0.424
0.496
0.459
Control
efficiency
%
98.6
32.5
75. 1
90. S
N/M
N/M
94.1
N/M
94 . 1
98.8
N/M
N/M
89.5
94 .2
89.6
N/M
89.7
89.7
98.5
98.1
99.0
96.0
97.5
o
I
M
U)
a Several equipment downtimes during test.
k Inlet tested prior to merger of grid casting and mixing exhaust.
c Filter broke. Catch was still collected.
N/M - Not Measured.
-------
TO ATMOSPHERE
i
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TO *TKOS:>K£«
UTS
US
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Figure C-3. Production flow diagram, Plant G.
-------
The dry formation process is totally enclosed and is vented
through two Tri-Mer mist eliminators installed in parallel.
These units, designed to operate with a water spray, are operated
in a dry mode. The packed beds are manually flushed after each
cycle with a water and detergent: solution. Sulfuric acid mist is
collected and recycled. Part of the cleaned air from each scrub-
ber is returned to the formation room for ventilation and the
remainder is exhausted to the atmosphere through two stacks.
After formation, the elements are dried, rinsed, and sent to
the three-process operation.
The three-process operation for both dry and wet battery
manufacture consists of stacking the plates, element burning to
connect the plates, cell setting (inserting the assemblies into
a battery case) and post burning. Emissions from the stacking
operation and lead oxide production are vented in a common duct
to a 212-m /min (7500-acfm) Mikro-Pulsaire, type 8FTV fabric
filter. Cell setting and plate welding emissions are vented in a
common duct to an identical fabric filter. Exhausts from both
baghouses are ducted in turn to a common stack. A 30 kW (40-hp)
fan provides suction for both baghouses.
After the three-process operation, the dry batteries are
washed, painted, and shipped; the wet batteries are sent to for-
mation. Acid mist from the wet forming room is vented through
a Heil water spray scrubber. Wet batteries are washed, painted,
and shipped following the formation process.
C-15
-------
Deformed grids, posts, connectors, and some scrap plates are
remelted in a reclamation furnace and formed into lead pigs to be
reused. Most scrap plates and elements along with reclamation
furnace slag are sent to a lead smelter for recovery. The rec-
lamation furnace and the small-parts casting facility are vented
in a common duct to a Schneible Model No. F-41 multiwash scrubber
operating with a water-to-gas ratio of 15,2 to 19.0 liters per
3
28.3 m (4 to 5 gallons per 1000 acf). The pressure drop is
typically 498 to 747 Pa (2 to 3 in. W.G.) with a rated exhaust
rate of 99 to 119 m /min (3500 to 4200 acfm).
Source tests were performed on the lead reclamation and
formation processes at Plant G. Results of the reclamation
facility tests are summarized in Tables C-3 and C-3A. Qualified
observers were present during the tests and saw no visible emis-
sions from the stacks that were tested.
C.4 PLANT L
Plant L produces about 6000 lead-acid storage batteries per
day, using four vat-type formation rooms for manufacturing dry-
charged batteries. The plant also manufactures wet-charged
batteries. The formation room tested houses two formation cir-
cuits, and forms about" 20,000 battery plates per day.
The formation process begins with the insertion of pasted
battery plates into individual slots in formation tanks, which
are about 18 inches wide and 3 feet long. After the plates are
loaded into the tanks, the positive plates are connected in a
C-16
-------
Table C-3. TEST RESULTS SUMMARY FOR PLANT G (METRIC UNITS)
Process
Lead reclama-
tion
(Cascade
scrubber
controlled)
Test
NO.
1
2
3
AVG.
Exhaust flow,
m3/niin
Inlet
92
94
96
94
Outlet
100
102
100
101
Exhaust flow.
am^/min
Inlet
101
107
108
105
Outlet
107
111
109
109
Pb concentration,
mg/m^
Inlet
293
175
214
229
Outlet
2.14
4.39
3.80
3.44
Pb emissions?
kip/hr
Inlet
0.95
1.21
1.57
1.26
Outlet
0.013
0.027
0,023
0.021
Scrap
input.
kg/hr
430.9
403.7
SOB.Q
447.5
Emission
factor
g/kg feed
Inlet
2.12
2.92
3.20
2.75
Outlet
0.032
0.071
0,048
0.050
Control
efficiency,
1
98.0
97.8
98.6
98. 3
o
I
-------
Table C-3A. TEST RESULTS SUMMARY FOR PLANT G (ENGLISH UNITS)
Process
Lead reclama-
tion
(Cascade
scrubber
controlled)
Test
No.
1
2
3
AVG.
Exhauat flow.
(Jscfra
Inlet
3255
3341
3407
3334
Outlet
3464
3594
3520
3526
Exhaust flow.
acftn
Inlet
3540
3756
3904
3700
Outlet
377S
3915
3800
3830
Pb concentration.
qr/dscf
Inlet
0,0765
0.0937
0.128
0.0994
Outlet
0.000936
0.00192
0.00166
0,00150
Pb emissions,
Ib/hr
Inlet
2.10
2.69
3.72
2.84
Outlet
0.0283
0.0591
0.0503
0.0459
Scrap
input,
tons/hr
0.4.75
0.445
0.560
0.493
Emission
factor
Ib/ton £eed
Inlet
4.72
6.45
7.09
6.09
Outlet
0.064
0.142
0.096
0.101
Control
efficiency
*
98.6
97.8
98.6
98.3
n
i
i-1
O3
-------
positive source of direct current (DC) and the negative plates
are connected to a negative DC source. The tanks are then filled
with sulfuric acid which has a specific gravity of about 1.04.
After the acid has been added, a foaming agent called Alkanol is
added to each tank, and the current is switched on. During the
formation process, the lead oxide paste on the positive plates is
oxidized to lead peroxide and the lead oxide paste on the nega-
tive plates is reduced to metallic lead.
The current is applied to the plates for about 18 hours,
which encompasses the entire second and third (evening and night)
shifts. The formed plates are removed and unformed plates loaded
during the first (day) shift.
Sulfuric acid mist emissions from the process are controlled
in two ways. First, emissions from the acid bath contact the
foam layer at the surface of the bath and are partially absorbed
by the foam layer. The second control mechanism is collection of
the unabsorbed mist particles in a Heil Model 704 scrubber which
has a water-to-gas ratio of 0.035 to 0.07 liters per cubic meter
(1-2 gal./lOOO acf) and a pressure drop of 498 to 747 pascal (23
inches of water-gage).
Emissions from parts of four formation cycles were sampled.
Only one cycle (Cycle No. 3) was sampled throughout the entire
cycle. All emission tests except those on Cycle No. 3 were
performed when emissions from the process were controlled using a
C-19
-------
combination of foam and scrubbing. Emission results from tests
on Cycle No. 3 show emissions when the process is controlled by
scrubbing only. Additional information on these tests is pre-
sented in Tables C4 and C4A.
C.5 OTHER TEST DATA
Other test data used in this study are summarized in Tables
C5 and C5A. The data were obtained from tests performed at
Plants 8, J, and K prior to this study. Both Plants B and J
manufacture lead acid batteries while Plant K produces lead oxide.
C-20
-------
Table C-4. TEST RESULTS SUMMARY FOR PLANT L {METHIC UNITS)
Plant
L
L
L
; i.
L
L
• i.
L
L
L
L
Process
Formation
Formation
Formation
Formation
Formation
Itormation
Formation
Formation
Fo rotation
Formation
Formation
Formation
Cycle No.__
1
1
2
2
2
3
3
3
3
3
4
Test
No.
lc
2
3
4
5
6
7
8
9
10
11
Approximate
Number of
Hours into the
Formation Cvclca
Start r.nci
6.5
11.0
8.0
12.0
1S.O
0.0
3.0
8.0
9.5
13.0
12. S
10.5
16.0
10.0
14.0
16.0
3,0
8. 5
9.5
13.0
16.0
16.0
Exhaust
Flow
ni'Vmin
Inlet Outlet
81.59
78.53
83.15
78.79
84.02
85.04
77.78
78.53
80.29
76.33
77,66
107.37
92.51
87,14
91.72
94.47
95.94
101.74
N/M
92.99
89,37
82.21
Actual
Exhaust Flow
amVntin
Inlet Outlet
87.56
84.79
91,98
87.11
93.19
92.63
84.90
85.81
87.87
83.68
86.80
113.6
96.73
93.11
96.47
99.64
101.46
107.54
N/M
98.14
94.58
88,13
H2S04 Mist
Concentrat ion
n'g/m3
Inlet
6.56
55.21
53.34
76.17
109,49
21.82
33.55
54.64
86.96
65.21
24.42
Outlet
0.57
0.87
0.30
2.20
5,23
0,63
0.60
N/M
1.37
1.60
0.90
II2SCI) Mist
limissions ,
Xhr-~ , .
Inlet
0.032
0.259
0.263
0.3S8
0,549
0.109
0.159
0.254
0.417
0.299
0.113
uut let
0.0046
0,0050
0.0014
0.0122
0.0295
0.0036
0.0036
N/M
0.0077
0.0086
0,0045
»** "": '" ' '
Control
l.tTiciency,
|h
89
98
99
97
95
97
98
N/M
98
97
96
'"This was a 16 hour formation cycle. The numbers in these columns represent the approximate length of time the process was sampled, and
the phase of the formation cycle that was sampled (e.g., Test No. 2 was performed during the last five hours of the first cycle sampled).
bSince inlet and outlet samples were not-collected simultaneously, these efficiencies are estimates,
cltesults invalidated by sample equipment failure.
N/M - Not Measured
-------
Table C-4A. TEST RESULTS SUMMARY FOR PLANT L (ENGLISH UNITS)
I'lmU
L
| L
L
L
L
L
L
L
L
L
L
•
Process
Formation
Formation
Format ion
formation
Formation
Formation
Formation
Formation
Format ion
Formation
formation
Formation
Cvclu No.
1
1
1
2
2
2
3
3
3
3
3
4
Test
No.
1C
2
3
• 4
5
6
7
8
9
10
11
Approximate
Niunber of
Hours into the
Tonnat ion (\clea
Start l-:nd
6.5
11.0
8.0
12.0
15.0
0.0
3.0
8.0
9.5
13.0
12.5
10.5
16.0
10.0
14,0
16.0
3.0
8.5
9,S
13.0
16.0
16,0
llxhau.st
!:low Rale,
ilscfin
Inlet Outlet
2883
277S
2933
2784
2969
300S
2748
277S
2837
2697
2744
3794
3269
3079
3241
3338
3390
3595
N/M
3286
3158
2905
Actual
How Rate,
scfrn
Inlet Outlet
3094
2996
3250
3078
3293
3273
3003
3032
3105
2957
3067
4014
3418
3290
3409
3521
3585
3800
N/M
3468
3342
3114
II2S04 Mist
Emissions,
10 •* j-rAtscf
Inlet Outlet
28.67
241.29
233.99
333.07
478.52
95.36
146,64
238.80
380.05
285.00
106, 73
2. 46
3.80
1.31
9.67
22.86
2.75
2.62
N/M
5.99
6.99
3.93
ii>S04 Mist
limissions ,
Ih/hr
fnlct Outlet
0.07
0.57
0.56
0.79
1.21
0.24
0.35
0.56
0.92
0.66
0.25
0.008
0.011
0.003
0.027
0.06S
0.008
0,008
N/M
0.017
0.019
0.010
Control
Efficiency,
89
98
:
99
97
95
97
;
.
98
N/M
98
97
96
,
(1
I
CO
111 is was a 16 hour formation cycle. The numbers in these columns represent the approximate length of time the process was sampled, and
the phase of the formation cycle that was sampled (e.g., Test No. 2 was performed during the last five hours of the first cycle sampled).
Since inlet and outlet samples were not collected simultaneously, these efficiencies are estimates,
tesults invalidated by sajtple equipment failure.
N/M - Not Measured
-------
Table C-5. TEST RESULTS SUMMARY FOR PLANTS B, J, AND K (METRIC UNITS)
Plant
fl
B
J
J
J
K
Process
PbO Mill
(Ball Mill)
Three-
process
Grid
Casting
Paste
mixer
Three-
process
PbO Mill
(Barton
Pot)
Control
Device
Product
recovery
fabric
filter
Fabric
Filter
Uncon-
trolled
Schneible
Scrubber
Fabric
Filter
Product
recovery
fabric
filter
Test
No.
1
2
3
AVG.
1
2
3
AVG.
1
2
3
AVG.
1
2
3
AVG.
1
2
3
AVG.
1
2
3
AVG.
Process
throughput,
Mg/hr,
1.4
1.4
1.4
1.4
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
0.70
0.68
0.60
0.66
Exhaust Flow
Rate,
m^/min
Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
26.5
26.8
25.5
26.3
321.34
331.42
321.85
324.88
N/M
N/M
N/M
N/M
Outlet
72.32
80.50
77.11
76.63
526.95
445.71
438 .97
470.54
11.9
11.6
10.5
11.3
27.6
23.7
25.9
25.7
355.23
352.66
360.16
356.02
35.4
32,8
35.4
34.5
Actual Exhaust
Flow Rate,
am^/min
Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
28.71
29.82
28.74
29.08
325.05
347.19
334.39
335.55
N/H
N/M
N/M
N/M
Outlet
87.16
93.98
92.68
91.27
555.18
470.71
473.09
499.65
15.7
15.5
14 .1
15.1
29.59
25.85
28.32
27 .92
374.63
368 .86
375.00
372.82
47.0
44 .4
48.4
46.6
Pb Concentration,
mg/m3
Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
63.2
84.0
84.9
77.4
5.95
2.63
4.28
4.28
N/M
N/M
N/M
N/M
Outlet
0.45
0.30
0.43
0.40
0.05
0.27
0.14
0.15
3.41
7.05
2.70
4.39
10,5
10.0
11.7
10.8
0.17
0.07
0.15
0.13
54.2
57.2
104.4
71.9
Pb Emissions,
kg/hr
Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/H
N/M
N/M
N/M
N/H
N/H
0.100
0.135
0.130
0.122
0.115
0.053
0.083
0.083
N/M
N/M
N/M
N/M
Outlet
0.0020
0.0015
0.0020
0.0018
0.0015
0.0073
0.0037
0.0042
0.0025
0.0049
0.0017
0.0030
0.0187
0.0255
0.0199
0.0181
0,0035
0.0015
0.0033
0.0028
0.115
0.113
0.223
0.150
Control
efficiency
%
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
81.4
88.5
85.2
85.0
96.9
97.2
96.0
9S.7
N/M
N/M
H/M
N/M
rr
i
K>
U>
N/M - Not Measured
-------
Table C-5A. TEST RESULTS SUMMARY FOR PLANTS Bf J, AND K (ENGLISH UNITS)
riant
B
B
J
J
J
K
Process
PbO Mill
(Ball Mill)
Three-
process
Grid
casting
Paste
mixer
Three -
process
PbO «ill
(Batten
Pot)
Control
Device
Product
recovery
fabric
filter
Fabric
Filter
Uncon-
trolled
Schneible
Scrubber
Fabric
Filter
Product
recovery
fabric
filter
Test
NO.-
1
2
3
AVG,
1
2
3
AVG.
1 .
2
3
JWG,
1
2
3
AVG.
1
2
3
AVG.
1
2
3
AVG.
Process
throughput,
ton/hr
1.5
1,5
1.5
1.5
N/M
N/M
N/M
N/M
N/M
N/M
N/«
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
M/M
0.77
0.75
0.66
0.73
Exhaust Flow
Rate,
dsofm
Inlet
N/M
N/M
N/M
N/M
N/M
N/H
N/M
N/M
N/M
N/M
N/M
N/H
936
945
901
927
11348
11704
11366
11473
N/M
N/M
M/M
N/M
Outlet
2554
2843
2723
2706
18609
15740
15502
16617
420
410
370
400
974
837
916
909
12545
12454
12719
12573
1250
1160
1250
1220
Actual Exhaust
Flow Rate,
ae£m
Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/H
N/M
M/M
N/H
N/M
N/M
1014
1053
1015
1027
11479
12261
11809
11850
K/H
N/M
B/M
N/M
Outlet
3078
3319
3273
3223
19606
16623
16707
17645
555
548
497
533
1045
913
1000
986
13230
13026
13243
13166
1660
1570
1710
1650
Pb Concentration,
lD-4qr/dscf
i Inlet
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
B/M
N/M
276
'367
371
•338
26.0
11.5
18.7
18.7
N/M
N/M
N/M
N/M
Outlet
1.97
1.33
1.88
1.73
0.215
1.19
0.609
0.671
14.9
30.8
11.8
19.2
46.0
43.7
51.3
47.0
0.73
0.30
0.66
0.56
237
250
456
314
Pb Emissions,
Ib/hr
Inlet
N/M
N/M
N/M
N/M
N/H
N/M
N/M
N/M
N/M
N/M
N/M
N/M
0.221
0.297
0.2i6
0.268
0.253
0.116
0.182
0.184
N/M
N/M
N/M
N/M
Outlet
0.0043
0.0032
0.0044
0.0040
0.0034
0.0161
0.0081
0.0092
0.0054
0.0108
0.0037
0.0066
0.0412
0.0342
0.0439
0.039B
0.0078
0.0032
0.0072
0,0061
0.253
0.249
0.491
0.331'
Control
efficiency
%
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/M
N/«
81.4
88. 5
85.2
85.0
96.9
97.2
96.0
96.7
N/M
N/M
N/M
N/M
o
I
N/M - Not Measured
-------
APPENDIX D
EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
As part of the work done under EPA Contract No. 68021219,
Arthur D. Little, Inc. performed a review of the recent litera-
ture pertaining to lead sampling and analysis. Their recommen-
dation was to employ a Modified EPA Method 5 sampling train for
sample collection, with lead analysis to be performed by atomic
absorption spectrometry (AAS). Based on this advice, EPA com-
bined these techniques in a working draft, "Determination of Lead
Emissions from the Manufacturing of Lead Batteries".
The new source performance standards were based on the
results of lead sampling conducted with this method by EPA on
grid casting furnaces, paste mixing operations, three process
operation, lead oxide production, and lead reclamation.
In this adaptation of the Method 5 sampling train, 100 ml of
O.lN HN03 was placed in each of the first two impingers to facil-
itate collection of gaseous lead. Since no separation of gaseous
and particulate lead was attempted, a filter, which was of high
purity glass fiber, was located between the third and fourth
impingers as a backup collector. After sampling was completed,
the filter portion was extracted for lead in a nitric acid reflux
procedure.
D-l
-------
A rigourous pretreatment with HNO_ of all sample-exposed
surfaces and containers, blank analyses of filters and 0.1N ENO,,
and the most recent revisions of the Method 5 sample recovery
procedure were all employed to insure that high quality samples
were obtained.
Since emissions from the manufacture of lead batteries are
relatively free of other pollutants, possible sample matrix
effects associated with AAS were insignificant insofar as the
impinger portion of the sample from this source was concerned.
However, as a precaution against this problem with the filter
portion due to the presence of the filter, the analytical tech-
nique known as the Method of Standard Additions was used for that
fraction of the sample. In addition to lead determination, data
were obtained by EPA at one plant on the formation process for
sulfuric acid mist.
D.2 CONTINUOUS MONITORING
EPA has not determined performance specifications for opacity
monitoring at lead battery plants. Opacity monitoring is, how-
ever, considered feasible, except when a wet scrubber is used to
control lead emissions.
The equipment and installation costs for a single opacity
monitor are estimated to be approximately $18,000 to $20,000.
Annual operating costs, including data recording and reduction,
are estimated to be between $8,000 and $9,000.
D-2
-------
D.3 PERFORMANCE TEST METHODS
EPA Method 12 is recommended as the performance test method for
lead emission from lead acid storage battery plants. EPA Method 9 is
recommended for the determination of opacity. EPA Method 8 is recommended
for the determination of sulfuric acid mist emissions.
EPA Method 12 is essentially the same method as was used in gathering
the NSPS data, except that it has been revised to include all of the
recent revisions to Method 5,
The cost of a test consisting of three lead runs with analysis and
the determination of visible emissions is estimated to be about 6 to 8
thousand dollars. This cost estimate is based on the assumption that
the testing is performed by independent contractors; the use of in-house
or plant personnel will slightly reduce the cost.
D-3
-------
APPENDIX E
ENFORCEMENT ASPECTS
E.1 GENERAL
The recommended standards of performance will limit emis-
sions of lead from grid casting, lead oxide production, paste
mixing, the three-process operation, and "other lead-emitting
operations" and emissions of sulfuric acid rnist from the forma-
tion process. The control systems that can be installed to
comply with the lead standards are combinations of scrubbers
and fabric filters. Scrubbers and mist eliminators can control
formation emissions. The control system may serve one or several
affected facilities simultaneously. Aspects of enforcing these
standards are discussed below for each affected facility.
E.2 GRID CASTING
The design and operation of the grid casting units affect
the level of uncontrolled emissions from the operation. Machine
design is fixed and cannot be altered during tests. The casting
operation is automatic, but each operator may control the temper-
ature of his melting pot if there is not a central pot. During
compliance testing, each pot should be at its normal operating
temperature and all grid casting machines should be operating.
E-l
-------
The rate of grid production is fixed by a constant machine speed.
Thus, the operation of all machines indicates a maximum produc-
tion rate.
Because of the units of the standard (gr/dscf), lead through-
put data is not required. The process engineer should observe
the process and record any operating problems that can affect
compliance test results, such as breakdown of a machine or shut-
down by the operator, A process monitor is necessary because
production records alone may not be adequate to determine normal
operation. The quantity of deformed plates produced generally is
not recorded, but emissions are generated by the casting of both
perfect and malformed plates. Thus, although production records
may show a low production figure for the test day, the lead
throughput during the test may be at a maximum.
Short downtimes during the test should not invalidate the
results. It is often necessary to spray the molds with a special
cork solution to prevent the grids from sticking. The process
engineer will determine whether process downtime during the
compliance test is excessive.
E.3 PASTE MIXING
Paste mixing is a batch operation done in a muller, day, or
dough-type mixer. The process design for a given facility is
fixed and cannot be changed during a compliance test. The paste
mixing process involves two phases, materials charging and blend-
ing. Often each phase is controlled by a different device. At
plants using two devices for the mixing cycle, the compliance
E-2
-------
test will require two different test locations. The tests should
be performed only while the mixer is ducted to the control device
tested. A process engineer can coordinate process operation with
compliance tests,
Compliance tests should be performed while the mixer is
operating at maximum load. Process operating records should be
consulted to verify that the paste recipe during compliance tests
is the one normally used at that facility. If the same mixer is
used for both positive and negative batches, tests should be run
during mixing of positive batches when possible. Typically more
dry lead oxide is used in positive batches, since a wet lead
oxide sludge (recovered from deformed plates) is often used in
negative batches. The positive batches, therefore, may generate
more lead emissions. The source tests performed in this study
showed no significant differences in controlled lead emissions
from mixing of positive and negative batches.
E.4 THREE-PROCESS OPERATION
The three-process operation consists of slitting and stack-
ing, burning, and assembly. These functions are done in many
different ways, as described in Chapter 3. Lead emissions depend
on the process design, the materials-handling techniques, and the
number of process steps. Compliance tests should be performed
during full operation. It is not practical to require that all
processes operate at all times throughout the tests, since a
minor breakdown or a changeover in the type of battery being
produced may require short downtimes that should not signifi-
E_ Q
_}
-------
cantly affect overall process emissions. The process engineer
must determine whether the downtimes of various three-process
operations are significant enough to invalidate the compliance
test.
In many three-process operations, one process may operate
only if another process is shutdown. For example, a hand stack-
ing station may operate only when an automatic unit is down or
vice versa depending on the needs of the plant. If there is any
indication that lead emissions from the two processes are sig-
nificantly different, the process judged to generate the greatest
amount of emissions should be operating during the compliance
test.
Some plants may control different processes within a three-
process operation facility with different control devices. In
such instances, source tests must be run on all applicable stacks
Since it is likely that lead concentrations will be different in
each exhaust stream, an equivalent concentration must be deter-
mined. This is done by determining total lead emissions in
grains per minute and dividing by the total exhaust flow rate in
dry standard cubic feet per minute. This equivalent concentra-
tion can then be compared with the standard.
E.5 LEAD OXIDE PRODUCTION
Lead oxide is produced by the ball mill and the Barton
processes. Each must comply with the standard. The process is
continuous, and equipment failures are few. If the equipment is
just starting up after a shutdown, at least 4 hours of operation
E-4
-------
should be allowed before compliance testing to ensure that steady-
state conditions have been achieved.
The lead oxide process may be controlled by more than one
baghouse. The baghouses may or may not exhaust through a common
stack. Only one test location is required if there is a common
exhaust. Otherwise each stack must be tested. Proper baghouse
operation can be checked by observing the pressure drop of the
control device.
Lead emissions are proportional to the lead feed rate to
the system. During compliance tests, the feed rate should be
normal. If the feed rate varies significantly, tests should be
performed during the maximum feed rate. The process engineer can
monitor feed rate by counting the number of lead ingots fed to
the system. The ingots typically weigh about the same.
E.6 LEAD RECLAMATION
The lead reclamation systems consist of a melting pot in
which relatively clean lead is remelted and cast into ingots for
use in the plant. This category does not include operations
similar to those in the secondary lead smelters on the premises
of a few lead-acid battery plants. Lead emissions depend on
scrap feed rate, type of scrap, and operating techniques. Com-
pliance tests should be performed at the maximum feed rate,
while the "dirtiest" scrap is fed to the recovery process, and
while operating techniques are normal. Since the lead reclama-
tion system is on-stream only periodically, the plant must be
E-5
-------
notified well in advance so that enough scrap can be stored for
all applicable tests.
Unlike most other lead-acid battery facilities, the opera-
tion of a lead reclamation facility is controlled mainly by the
operator. The lead pot is usually heated continuously, but the
temperature is raised from about 316°C to about 427°C (600°F to
about 800°F) when scrap is being dumped into the pot. After
dumping, the contents of the pot furnace is agitated with a metal
rod so that the lead will sink. This can be done manually or
automatically. Slag is removed from the surface periodically,
and when there is room in the pot, more scrap is dumped in. The
molten lead can be removed at any time and poured into molds.
The process engineer can judge by observation whether the process
is operating normally.
E.7 OTHER LEAD EMITTING OPERATIONS
Many lead-acid battery plants operate processes that are
not common to all plants. A process such as lug breaking may
be required at some plants because of the equipment used or the
type of battery produced. Under the standard, such processes
are required to be limited to lead emissions of not greater than
1.00 mg/m (0.00044 gr/dscf). Compliance with OSHA regulations
(50 ug/m ) requires that all processes emitting significant lead
emissions will be vented. These processes can normally be
vented to controls serving other processes.
E-6
-------
TECHNICAL REPORT DATA
(Please read Instructions on she reverse before completing)
1. REPORT NO.
EPA-450/3-028a
4. TITLE AND SUBTITLE
Lead-Acid Battery Manufacture - Background Information
for Proposed Emission Standards
5. REPORT DATE
November 1979
6. PERFORMING ORGANIZATION CODE
3. RECIPIENT'S ACCESSION NO.
7. AUTHORfS)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, 1C 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3057
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Rf><:parrh Triangle Park, NC 27711
IS. SUPPLEMENTARY NOTES
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
16. ABSTRACT
Standards of performance for the control of emissions'from lead-acid battery
manufacturing plants are being proposed under the authority of section 111 of the
Clean Air Act. These standards would apply to new, modified, or reconstructed
facilities at any lead-acid battery manufacturing plant with a production capacity
equal to or greater than 500 batteries per day. This document contains background
information, environmental and economic impact assessments, and the rationale for
the standards, as proposed under 40 CFR Part 60, Subpart KK.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTlRERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air pollution
Pollution control
Standards of performance
Lead-acid battery manufacturing plants
Lead
Sulfuric acid mist
Air Pollution Control
131
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
380
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLEI E •
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Office of Air Quality Planning and Standards
Research Triangle Park NC 27711
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Penalty for Private Use
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Publication No, EPA-450/3-79-028a
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v>EPA
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Environmental Protection
Agency
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Planning and Standards
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November 1980
Air
Lead-Acid Battery
Manufacture -
Background Information
for Promulgated
Standards
EIS
-------
EPA-450/3-79-028b
Lead-Acid Battery
Manufacture —
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
November 1980
-------
This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or.commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services Office (MD-35),
U.S. Environmental Protection Agency, Research Triangle Park,
N.C. 27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
Publication No, EPA-450/3-79-Q28b
11
-------
ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final
Environmental Impact Statement
for Lead-Acid Battery Manufacture
Prepared by:
Don R. Goodwin / (Date)
Director, Emission Standards and Engineering Division
U.S. Environmertal Protection Agency *
Research Triangle Park, NC 27711
1. The promulgated standards of performance limit emissions of lead from
new, modified, and reconstructed lead-acid battery manufacturing facilities,
Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, directs
the Administrator to establish standards of performance for any
category of new stationary source of air pollution that ". . . causes
or contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense, Transportation,
Agriculture, Commerce, Interior, and Energy; the National Science
Foundation; the Council on Environmental Quality; members of the State
and Territorial Air Pollution Program Administrators; the Association
of Local Air Pollution Control Officials; EPA Regional Administrators;
and other interested parties.
3, For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5421.
4. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
ill
-------
TABLE OF CONTENTS
Chapter 1. SUMMARY
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED
ACTION
Chapter 2. SUMMARY OF PUBLIC COMMENTS
2.1 GENERAL
, 2.2 EMISSIONS CONTROL TECHNOLOGY
2.3 MODIFICATION AND RECONSTRUCTION
2.4 ECONOMIC IMPACT
2.5 ENVIRONMENTAL IMPACT
2.6 LEGAL CONSIDERATIONS
2,7 TEST METHODS AND MONITORING
2.8 REPORTING AND RECORDKEEPING
2.9 MISCELLANEOUS
Page
1-1
1-1
1-3
2-1
2-1
2-12
2-20
2-20
2-22
2-23
2-25
2-26
2-27
-------
LIST OF TABLES
Table
Number . page
1-1 Summary of changes made to lead emission limitations
between proposal and promulgation 1-2
1-2 Control Alternatives considered for proposed action 1-4
l-3a Estimated impacts of proposed and promulgated standards
on atmospheric emissions (metric units) 1-6
l-3b Estimated impacts of proposed and promulgated standards
on atmospheric emissions (English units) 1-7
1-4 Comparison of ambient lead concentration impacts of
proposed and promulgated regulations 1-9
l-5a Comparison of water pollution impacts of promulgated
and proposed standards (metric units) 1-10
l-5b Comparison of water pollution impacts of promulgated
and proposed standards (English units) 1-11
1-6 Electricity requirements for proposed and promulgated
standards 1-13
1-7 Total energy requirements for proposed and promulgated
standards 1-15
1-8 Economic impacts of proposed and promulgated standards 1-17
2-1 List of commenters on the proposed standards of
performance for lead-acid battery manufacture 2-2
-------
1. SUMMARY
On January 14, 1980, the Administrator proposed standards of performance
for lead-acid battery manufacture (45 FR 2790) under Section 111 of the
Clean Air Act. Public comments were requested on the proposal in the Federal
Register. There were 21 commenters composed mainly of lead-acid battery
industry and State Agency representatives. Also commenting were representa-
tives of the U.S. Department of Commerce and industries not associated with
lead-acid battery manufacturing. The comments that were submitted, along
with responses to these comments, are summarized in this document. The
summary of comments and responses serves as the basis for the revisions made
to the standards between proposal and promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
A number of changes have been made to the standards since their proposal.
The most significant of these are changes in the emission limitations for
the grid casting and lead reclamation facilities. The promulgated emission
limits for these facilities are based on levels achievable using impingement
scrubbers, while the proposed emission limits were based on levels achievable
using fabric filtration. Also, the opacity standard for lead reclamation
has been changed from 0 to 5 percent, because of the change in the emission
limit for this facility. The changes in the standards of performance for
grid casting and lead reclamation are illustrated in Table 1-1, which
presents the proposed and promulgated emissions limitations for all facilities
affected by the standards.
Another change is the redefinition of the paste mixing facility to
include several operations ancillary to paste mixing. These ancillary
operations are lead oxide storage, conveying, weighing, and metering operations;
paste handling and cooling operations; and plate pasting, takeoff, cooling,
and drying operations.
1-1
-------
TABLE 1-1. SUMMARY OF CHANGES MADE TO LEAD EMISSION LIMITATIONS
BETWEEN PROPOSAL AND PROMULGATION
Affected facility
Proposed lead
emission limit
Promulgated lead
emission limit8
Lead oxide production
Grid casting
Paste mixing
Three-process operation
Lead reclamation
Other lead-emitting
operations
5,0 mg/kn (0,010 Ib/ton)
0.05 mg/dscm (0.00002 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
2.0 mg/dscm (0.00088 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
No change from proposed limit
0,40 mg/dscm (0.00024 gr/dscf)
No change from proposed limit
No change from proposed limit
4.5 mg/dscm (0.0022 gr/dscf)
No change from proposed limit
For lead oxide production, the emission limit is expressed 1n terms of lead emissions
per kilogram of lead processed.
For grid casting, paste mixing, three-process operation, lead reclamation, and other
lead-emitting facilities, emission limits are expressed in terms of lead emissions per
dry standard cubic meter of exhaust air.
1-2
-------
,f.r
', i
, ;;;,..- .,;.
In addition, the units of t&fslial 1-11 ze.-'cutoff for the standards for
lead-acid battery manufacture have;been ch'inged from batteries per day (bpd)
'•• *,"'<*?r""*£* • '>j5^' "-••">'•
to lead throughput. The promulgiy^ps^ahdardi'-'will affect new, modified,
or reconstructed facilities at.,afijLp.1;ant with-the capacity to produce in one
• ,;:^feiA-'-::|5 A-
day batteries which would contain^ :ih total, an amount of lead greater than
'•-.'5 V.':-'.-•-•
or equal to 5,9 Mg (6.5 tons). TttjxsA;cutaff "corresponds to the 500 bpd
cutoff in the proposed standardsV.and- is .Based on an average battery lead
content of 11.8 kg (26 lb) of lead per battery.
'JJ& •£*.'.:' '^':> ,4 '
The promulgated standards will- not require pressure drop monitoring and
recording for fabric filters. .The pressure .drop monitoring and recording
requirement has been retained fofrrScftubbe'r's.-,..However, the continuous
recording requirement has been changed to a requirement that pressure drop be
recorded every 15 minutes. Finally,. Because of the change in the standard
for grid casting, the minimum sampling time for this facility has been
reduced from 180 minutes to 60 minutes. *:
1.2 SUMMARY OF IMPACTS OF THE PROMULGATED ACTION
1.2.1 A]ternatryes to the Prgrou1 pated Action
The control alternatives considered for the lead-acid battery manufacture
source category are discussed in Chapter 6 of the Background Information
Document (BID) for the proposed standards (Volume I). Five regulatory
alternatives were considered for-, pi ants larger than the small size cutoff.
The control techniques on which,the alternatives were based are summarized
in Table 1-2. *f'* ''•' f; :
The promulgated standards correspond' to Alternative III, which is based
on the use of fabric filtration to control emissions from lead oxide production,
paste mixing, three process operation,,; and, other lead-emitting facilities,
.'tiPr-.",1- £ S . ( .-,• ' .'
and scrubbers typically used in the lead-tad''d battery manufacturing industry
'".'<* f: : >'•"»'., • --J '
to control emissions from grid caSt"ingc'arfdv Tead reclamation facilities. This
alternative is considered to reflect the "degree of emission control achievable
through the use of the best demonstrated technology considering costs, nonair
quality health and environmental impacts,/and energy requirements for lead-acid
battery manufacture. The rationaierfSr.'the'.selection of Alternative III as
a basis for the promulgated standards is discussed in Chapter 2, Section 2.2.
«',/:
- 1-3
-------
TABLE 1-2. CONTROL ALTERNATIVES CONSIDERED FOR PROPOSED ACTION
Control techniques on which regulatory alternatives were
liter-native
I
Lead oxide production
Grid casting — furnaces
— machines
Paste mixing
Three-process operation
Lead reclamation
A
Fa
v
F
F
F
Alternative
11
A
S
Fa
F
F
S
Alternative
III
A
S
S
F
F
S
Alternative
IV
A
S
S
S
F
S
based
Alternative
V
A
S
S
S
F
S
A — Fabric filter, 2:1 air to cloth ratio
F — Fabric filter, 6:1 air to cloth ratio
S ~ Impingement scrubber, AP = 1,25 kPa (5 in. W.G.)
aAs noted in the text, it has been determined that standards for grid casting and lead reclamation cannot be
based on fabric filtration.
-------
The proposed standards corresponded to Alternative I. The emission
limits and the impact analyses for this alternative had been based on the
application of fabric filters to all affected facilities; however, as noted
in the preamble to the proposed standards, the emissions limits for
Alternative I could also have been achieved using high energy venturi
scrubbers. In light of arguments presented by a number of commenters (Chapter 2,
Section 2.2), it has been determined that standards for grid casting and
lead reclamation facilities cannot be based on the use of fabric filters.
Therefore, the costs, and energy and water requirements of venturi scrubbers,
which would have met the proposed standards for grid casting and lead
reclamation, have been estimated. These estimates have been used to revise
the energy, economic, and water pollution impacts projected for Alternative I.
As noted in Volume I of the BID, growth projections for the lead-acid
battery manufacturing industry over the next five years range from 3 to
5 percent per year. The environmental, economic, and energy impacts estimated
for the promulgated standards in this chapter and in Volume I are based on
a growth rate of 3.5 percent per year.
1.2.2 Environmental Impactsof Promulgated Action
The environmental impacts of the regulatory alternatives for lead-acid
battery manufacture are discussed in Chapters 6 and 7 of the BIO for the
proposed standards. The impacts of the promulgated action are summarized
and compared to the impacts of the proposed regulation in this subsection.
The differences between the impacts of the promulgated standards and the
proposed standards are due to the changes in emissions limits for grid
casting and lead reclamation. The change in the paste mixing facility
definition and other changes are not expected to have significant impacts on
lead emissions. The following discussion in conjuction with the environmental
impact analysis in Volume I of the BID, represents the final Environmental Impact
Statement for the promulgated standards.
1,2.2.1 Air pollution impacts
The lead emission impact of the promulgated standards is compared with
the impact of the proposed standards in Table 1-3 for the 500, 2000 and
6500 bpd (5.9, 23.6 and 76.7 Mg/day or 6.5, 26.0, and 84.5 tons/day of lead)
1-5 • '
-------
TABLE l-3a.
ESTIMATED IMPACTS OF PROPOSED AND PROMULGATED STANDARDS
ON ATMOSPHERIC EMISSIONS
(metric units)
en
500 BPO Plant
2000
6500
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility
BPD Plant
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility
BPD Plant
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility
Uncontrolled
lead emissions
(kg/yr)
1562.8
-__b
51.0
634.9
833.3
43.6
6277.5
26,5
204.0
2539.5
3333.0
174,5
20401.9
86.1
663.0
8253.4
10832.3
567.1
Baseline
emissions8
(kg/yr)
952.2
,.b
51.0
63.5
833.3
4.4
3835.0
26.5
204.0
254.0
3333.0
17.5
12463.4
86.1
663.0
825.3
10832.3
56.7
Allowable lead emissions (kg/yr)
Proposed
standards
66.1
_.b --
0.4
8.1
56.6
1.0
215.9
13.3
1.4
21,5
175.9
3.8
661.6
43.1
4.6
55,4
546.1
12.4
Promulgated
standards
70.0
--b
3.2
8.1
56.6
21
.1
230.2
13.3
10.9
21.5
175.9
8f-
,o
709.1
43.1
36.6
55.4
546.1
ft-J rt
27.9
aNo additional regulatory action.
blt is assumed that plants in the 500 bpd size range have no lead oxide manufacturing facilities.
-------
TABLE l-3b. ESTIMATED IMPACTS OF PROPOSED AND PROMULGATED STANDARDS
ON ATMOSPHERIC EMISSIONS
(English units)
bUt)
2000
6500
117™
BPD Plant
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility
BPD Plant
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility -
BPD Plant
Lead oxide production facility
Grid casting facility
Paste mixing facility
Three-process operation facility
Lead reclamation facility
Uncontrolled
lead emissions
Ob/yr)
3445.3
_b
112.4
1399.7
1837.1
96,1
13839.2
58.4
449.7
5598.5
7347.9
384.7
44977.6
189,8
1461,6
18195,3
23880,7
1250.2
Baseline
emissions
Ob/yr)
2099.1
__b
112.4
140.0
1837.1
9.6
8454 4
58.4
449.7
559,9
7347.9
38.5
20476 6
189.8
1461,6
1819.5
23880.7
125.0
Allowable lead
Proposed
standards
145.8
b
0 9
17.9
124.8
2.2
47fi 0
29 3
3 1
47 4
187.8
8.4
1458 4
95.0
10 1
122.1
1203.9
27.3
emissions (Ib/yr)
Promulgated
standards
154.4
b
7 t
17.9
124.8
4.6
CA7 C
?9 -3"
?d n
a? d
187.8
19.0
ICC*} •)
95.0
7
122.1
1203.9
61.5
It is assumed that plants in the 500 bpd size range have no lead oxide manufacturing facilities.
-------
model plant sizes. As shown in this table, the changes in the standards for
grid casting and lead reclamation will have only a slight impact on the
emission reduction attributable to the NSPS. The promulgated standards are
expected to reduce total lead air emissions from facilities coming on-line
during.the next five years to about 3.1 Mg (3.4 tons) in the fifth year,
while the proposed standards were expected to reduce emissions from these
facilities to 2.8 Mg/yr (3.1 tons/yr). Both of these figures represent a
decrease in lead emissions of about 97 percent from the lead emissions which
would be allowed under current State Implementation Plan (SIP) limits for
particulate matter.
Table 1-4 compares the estimated ambient air lead concentration impact
of the promulgated action with that of the proposed standards. As shown in
the table, the changes in the standards for grid casting and lead reclamation
are not expected to have a significant impact on ambient lead concentrations
in the vicinities of battery plants. The results of dispersion modelling
calculations indicate that the maximum annual ambient impact of lead emissions
from a 6500 bpd plant complying with the promulgated regulation would be
less than the national ambient air quality standard of 1.5 yg/m3 (averaged
over a calender quarter).
1.2.2.2 Water pollution impact
The estimated wastewater impact of the promulgated action is compared
with that of the proposed standards in Table 1-5. As noted in Section 1,2.1
of this chapter, the water pollution impact analysis for the proposed
standards has been revised based on the estimated effluents for venturi
scrubbers which would meet the proposed standards for grid casting and lead
reclamation.
The promulgated action is expected to result in an increase in the lead
content of wastewater of about 0.6 percent, for a typical lead-acid battery
plant. It is anticipated that, in early 1981, EPA's Office of Water and
Waste Management will propose a regulation which would require zero lead
wastewater discharge from grid casting and lead reclamation. Zero discharge
from scrubbers controlling these facilities could be accomplished by clarifying
and recycling the" scrubber effluent. The cost of this treatment is estimated
1-8
-------
..-
TABLE 1-4. COMPARISON:W;SillfefeA!l?CONCENTRAT!ON IMPACTS OF
PROPOSED AND PROMULGATED REGULATIONS
500 BPO Plant
Baseline8
Proposed standards
Promulgated standards
6500 BPD Plant
Baseline3
Proposed standards
Promulgated standards
'
" '. "enftssicjjis'-"' l«.J;
'(g/sec)" "
y. "*
''0.13
• ,^I0,'OQ3&jM;>f?t! 'i;
^'W'°f*fflt:;
, A'
.0.58 •
0.011
40. 01 3. ./v •*,
[, ' Maximum ambient lead
.•'-•: concentration impacts (yq/m*)
' -'/Hour
average
34
•t'Ai 1
y^";1
'.'• ' 88
2
. • « 2
24-hour
average
19
<•(
<]
41
1
1
Annual
average
4
<:]
<]
8
<]
<]
No additional regulatory action.
-------
I
I—1
o
TABLE l-5a. COMPARISON OF WATER POLLUTION IMPACTS OF
PROMULGATED AND PROPOSED STANDARDS
(Metric units)
Total
scrubber
blowdown
Basel1neh
500 bpd plant
2000 bpd plant
6500 bpd plant
Proposed standards —
(original estimated
500 bpd plant
2000 bpd plant
6500 bpd plant
proposed standards -a
(revised estimate!
500 bpd plant
2000 bpd plant
6500 bpd plant
Promulgated standards
500 bpd plant
2000 bpd plant
6500 bpd plant
Volume
, (kl/day)
0.5
2.0
7.0
0
0
0
14.6
50.8
170.0
2.0
7.8
27.4
Lead
content
(kg/yr)
3.9
15.7
51.4
0
0
0
9.4
37,5
121.8
8.9
35.5
115.2
Increase
above
Volume
(kl/day)
0
0
0
14.1
48.8
163.0
1.5
5.8
20.4
baseline
Lead
content
(kg/yr)
.
0
0
o •;«-.
5.5
21.8
70.4
5,0
19.8
63.8
Increase 1n total
plant
Volume
(percent)
0
0
0
11.2
9,7
10.0
. 1.3
1.3
1.3
effluent3
Lead
content
(percent)
0
0
0
0.7
0.7
0.7
0.6
0.6
0.6
Based on a total process effluent of about 250 liters per battery, containing about 25 ppm lead by weight.
Emission control technology required to meet typical SIP particulate emissions
C8ased on fabric filter control "of all affected facilities.
on venturl scrubber control of grid casting and lead reclamation facilities.
-------
TABLE l-5b. COMPARISON OF WATER POLLUTION IMPACTS OF
PROMULGATED AND PROPOSED STANDARDS
(English units)
Total' scrubber
bl owdown
Volume
(10s gal/day)
Basel ineb
500 bpd plant
2000 bpd plant
6500 bpd plant
Proposed standards
(original estimate)
500 bpd plant
2000 bpd plant
6500 bpd plant
Proposed standards .
(revised estimate)
500 bpd plant
2000 bpd plant
6500 bpd plant
Promulgated standards
500 bpd plant
2000 bpd plant
6500 bpd plant
0.07
0.27
0.93
0
0
0
1.93
6.73
22.53
0.26
1.04
3.63
aBased on a total process effluent of
Emission control technology required
Lead
content
(Ib/yr)
9
35
112
0
0
0
21
82
269
19
75
243
about 250 liters
to meet typical
Increase
above baseline
Volume
(10s gal/day)
0
0
0
1.86
6.46
21.40
6.19
0.77
2.70
Lead
content
Ob/yr)
0
0
0
12
47
157
10
40
131
per battery, containing about
SIP participate emissions.
Increase in total
. plant effluent3
Volume
(percent)
0
0
0
11.2
9.7
10.0
1.3
1.3
1.3
25 ppm lead
Lead
content
(percent)
0
0
0
0.7
0.7
0.7
0.6
0.6
0.6
by weight.
3ased on fabric filter control of all affected facilities.
Based on venturi scrubber control of grid casting and lead reclamation facilities.
-------
to be less than one percent of the costs which would be allocable to the
recommended NSPS for a completely modified or reconstructed 2000 battery per
day plant.
1.2.3 Energy and Economic Impacts__of,_.Promulgated,Action
1.2.3.1 Energy impacts
The energy impacts of the proposed regulation and the regulatory alternatives
considered for lead-acid battery manufacture are estimated in Chapter 7 of
Volume I of the BID. The estimated impacts of the proposed standards were
based on the application of fabric filters to all affected facilities. As
noted in Section 1.2.1 of this Chapter, the energy impacts for the proposed
regulation have been recalculated based on application of high energy venturi
scrubbers rather than fabric filters to grid casting and lead reclamation
exhausts. The major portion of the energy required to operate an air emission
control system for a lead-acid battery manufacturing facility is electrical
energy required to operate the fan which overcomes the pressure drop through
the system. Based on particle size data and scrubber efficiency data, it is
estimated that high energy venturi scrubbers with pressure drops of about
7.5 kPa (30 in. W.G.) would be needed to meet the emissions limitations for
grid casting and lead reclamation in the proposed regulation (Chapter 2,
Section 2.2).
In contrast, the promulgated emission standards for grid casting and
lead reclamation are based on levels demonstrated to be achievable by
impingement scrubbing with a scrubber pressure drop of about 1.25 kPa
(5 in. W.G.). Also, the emissions limitations for paste mixing, three-process
operation, and other lead emitting facilities in both the proposed and
promulgated standards are based on the application of fabric filters with
pressure drops of about 1.25 kPa (5 in. W.G.).
The incremental electricity requirements attributable to the promulgated
regulation (Alternative III) and the proposed regulation (Alternative I) are
compared in Table 1-6. For the proposed regulation, both the original and
revised estimates of the electrical energy requirement are presented.
1-12
-------
1
TABLE 1-6. ELECTRICITY REQUIREMENTS FOR PROPOSED AND
PROMULGATED STANDARDS
Electricity requirements
attributable to NSPS fMWh/vr)
Plant
size
500 BPD
2000 BPD
6500 BPD
Proposed
Original estimate3
28
80
252
regulation
Revised estimate1*
51
154
500
Promulgated
regulation
28
80.
252
Based on fabric filter control of all affected facilities.
Based on venturi scrubber control of grid casting and lead reclamation facilities,
1-13
-------
In addition' to these electricity requirements, heat energy is expected
to be required to raise exhaust gases from paste mixing above their dewpoint
and thus prevent baghouse blinding due to excess moisture (Chapter 2, Section 2.2),
This requirement would be the same for the promulgated and proposed actions.
Total energy requirements for the proposed and promulgated regulations are
compared with plant energy requirements in Table 1-7. For the proposed
action, the original and revised estimates of total energy requirements are
presented. Process energy demands are based on reported total process
energy requirements for various plant sizes (Volume I, Chapter 7). Exhaust
energy requirements represent requirements for venting facilities to prevent
employee exposure. Baseline control energy requirements represent energy
needs for controlling emissions to the degree required under a typical SIP
particulate regulation. All electrical energy requirements in Table 1-7
are expressed in terms of the amount of heat which would be required to
generate the needed electricity (assuming an average power plant efficiency
of 34 percent).
The energy required at a new plant to operate emission control devices
installed to meet the promulgated regulation will be about 2.7 percent of
the total plant energy requirement. The total.nationwide increase in
electrical energy demand attributable to the promulgated action will be
about 2.8-GWh of electricity in the fifth year after promulgation. The
fifth year nationwide energy demand increase resulting from action will be
approximately 50 PJ/hr (48 x 109 BTU/yr), or the equivalent of about
8.1 thousand barrels of oil per year.
1.2.3.2 Economic impact
The economic impacts of the proposed regulation and the regulatory
alternatives are discussed in Chapter 8 of Volume I of the BID. As noted
above, the proposed regulation corresponded to Alternative I. The estimated
economic impact for the proposed action was based on the application of
fabric filters to all affected facilities. However, it has been determined
that the proposed emission limits for grid casting and lead reclamation
cannot be based on fabric filtration and that high energy (7.5 kPa or
30 in. W.G, pressure drop) venturi scrubbers would be required to achieve
1-14
-------
TABLE 1-7. TOTAL ENERGY REQUIREMENTS FOR PROPOSED AND PROMULGATED STANDARDS
(Metric units)
Plant
size
500 BPD
2000 BPD
§500 BPO
Manufacturing
process
requirements
(TJ/yr)
35 _
55
116
Process and
plant exhaust
requirements
ETJ/yr)
0.26
0.80
2.43
Baseline
control
requi rements
(TJ/yr)
0.14
0.34
0.82
NSPS control
requirements" (TJ/yr)
Proposal— •
original
estimate^
0.25
0.84
2.64
Proposal —
revised Promulgated
estimate*'*6 regulation6
0.80
2.34
7.09
0.56
1.54
4.46
(English units)
Plant
size
500 BPO
2000 BPD
6500 BPD
Hanufacturing
process
requi rements
(10* BTU/yr)
33
52
no
Process and
plant exhaust
requirements
(10' BTU/yr)
0.25
0.76
2.30
Basel 1nea
control
requirements
(10' BTU/yr)
0,13
0.32
0.78
MSPS control
requi rementsb (10*
Proposal-
original
estimate*-
0.24
0.80
2.50
Proposal--
revised
estimate" «e
0.76
2.22
6.72
BTU/yr)
Promulgated
regulation6
0.53
1.46
4.23
aControl techniques required to meet typical SIP particulate regulations.
In excess of energy requirements for baseline controls.
cSased on fabric filter control of all affected facilities.
Based on venturi scrubber control of grid casting and lead reclamation facilities.
Includes heat energy requirements for paste mixing exhausts.
-------
these limits. Therefore, the economic impacts for the proposed action have
been recalculated based on the costs of venturi scrubbers for the grid
casting and lead reclamation facilities.
. The. costs of compliance with the promulgated regulation for new and
t .
existing plants are compared with the revised costs for the proposed standards
in Table 1-8. For the proposed regulation, the original and revised estimates
of economic impacts are presented. The predicted annualized costs of the
promulgated action range from 8 percent lower, for existing 6500 bpd plants,
to 28 percent lower, for new 500 bpd plants, than the annualized costs which
would have resulted for the proposed standards] Also, the projected capital
costs for plants complying with the promulgated standards are much lower (18
to 40 percent) than those which would have resulted from the proposed
standards. ;
The cost per battery at a plant where all facilities are affected by
the promulgation is expected to range from 23 cents per battery, for a new
6500 bpd plant, to 54 cents per battery, for a completely reconstructed or
-modified 500 bpd plant. The average incremental cost associated with the
promulgated regulation will be about 29 cents per battery, which amounts to
about 1.6 percent of the wholesale price of a battery. The total nationwide
capital cost of the installed emission control equipment necessary to meet
the promulgated regulation for all new, modified, or reconstructed facilities
coming on-line over the next five years will be about $8.2 million. The
total annualized cost of operating this equipment in the fifth year after
promulgation will be about $3.9 million.
1.2.4 Other Environmental Concerns
1.2.4.1 Irreversible and irretrievablecommitment of resources
The extent to which the proposed standards for lead-acid battery
manufacture would have involved a tradeoff between lead air pollution
reduction arid energy losses is discussed in Section 7.6.1 of Chapter 7 of
the BID for the proposed standards. There are no significant changes to the
impacts discussed in this section.
1-16
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TABLE 1-8. ECONOMIC IMPACTS OF PROPOSED AND PROMULGATED STANDARDS'
Costs allocable to NSPS Costs allocable to NSPS
for proposed action — for proposed action —
original estimate'5 revised estimate
Capita!
cost
($1000)
Annual tzea
cost
(SlOOO/yr)
Capital
Cost per . cost
battery ($}d (STOOD)
Annualized
cost
($1000/yr)
Cost per ,
battery ($)a
Costs allocable to NSPS
for promulgated action
Capital
cost
($1000)
Annuali zed
cost
($1000/yr)
Cost per .
battery ($)d
New Plants
500 bpd
2000 bpd
6500 bpd
125
211
453
47.5
108
284
0.48
0.2?
0.22
200
278
517
66.8
129
323
0.67
0.32
0.25
120
200
423
47.6
107
277
0.48
0.26
0.21
Existing Plants
500 bpd 150 53.6 0,54 235 69.7 0.69 144 53.4 0.54
2000 bpd 253 118 0.30 329 133 0.33 240 117 0.29
6500 bpd 544 305 0.23 615 327 0.25 508 297 0.23
a!977 dollars.
Based on fabric filter control of all affected facilities.
Based on venturi scrubber control of grid casting and "lead reclamation facilities.
Based on production at 80 percent of capacity.
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1.2.4.2 Environmental Impact of delayed standards
' "" ----- - - * - ,._-, I, „„ M «::;mt=,=,^^
The impacts of a delay in setting new source performance standards for
lead-acid battery manufacture are discussed in Section 7.6.2 of Chapter 7 of
Volume I. There has been no significant change to this impact.
1.2.4.3 Environmental impactof no standard
The environmental impacts of not setting new source performance standards
for lead-acid battery manufacture are discussed in Chapter 7» Section 7.6.3
of Volume I of the BID. These impacts have not changed significantly since
proposal.
1-18
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1
1.3 REFERENCES FOR CHAPTER 1
1. Memo from Battye, W,, GCA/Technology Division to Vatavuk, W , EPA
Economic Analysis Branch. October 13, 1980. Revised control costs for
grid casting and lead reclamation facilities. (Docket No. IV-B-11)
1-19
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2. SUMMARY OF PUgLIC COMMENTS
A list of conmenters, their affiliations, and the EPA docket number
assigned to each comnent is shown in Table 2-1. Twenty-one letters commenting
on the proposed standards and the Background Information Document for the
proposed standards were received. The comments have been combined
I into the following nine categories;
1. . General
| 2. Emission Control Technology
3. Modification and Reconstruction
4, Economic Impact
5. Environmental Impact
•t .6- Legal Considerations
7. Test Methods and Monitoring
8. Reporting and Recordkeeping
9, Miscellaneous
The comments and issues are discussed, and responses are presented in
the following sections of this chapter. A summary of the changes to the
regulation is presented in Section 1,2 of Chapter 1.
2.1 GENERAL
Comment: The proposed standards exempted facilities at any plant with
a production capacity of less than 500 bpd. Some commenters felt that the
number of batteries which can be produced at a plant was riot the appropriate
» ' criterion on which to base the size cutoff. It was pointed out that lead-acid
batteries are produced in a variety of sizes, and that emissions from battery
production are probably related more to the amount of lead used to produce
| batteries than to the number of batteries produced.
Response: These are considered to be reasonable comments. Economic
impacts of standards as well as emissions are expected to be related to the
amount of lead used in a particular battery production operation rather than
2-1
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF PERFORMANCE
FOR LEAD-ACID BATTERY MANUFACTURE
Docket number Commenter and affjjiation
IV-D-1 Mr. James H. Hazelwood
Georgia Marble Company
2575 Cumberland Parkway, Northwest
Atlanta, Georgia 30339
IV-D-2 Mr. James K. Hambright, Director
Department of Environmental Resources
Bureau of Air Quality
P.O. ,Box 2063
Harrisburg, Pennsylvania 17120
IV-D-3 Mr. Thomas Hatterscheide
Gould, Incorporated
P.O. Box 43140
St. Paul, Minnesota 55164
IV-D-4 Mr. Richard A. Lei by
Assistant Safety Director
East Penn Manufacturing Company, Inc.
Main Office
Lyon Station, Pennsylvania 19536
IV-D-5 Mr. John A. Bitler
Vice President, Environmental Resources
General Battery Corporation
Box 1262
Reading, Pennsylvania 19603
IV-D-6 Mr. William V. Skidmore
Acting Deputy General Counsel
U.S. Department of Commerce
Washington, D.C. 20230
IV-D-7 Mr. Edwin H. Seeger
Prather, Seeger, Doolittle and Farmer
1101 Sixteenth Street, Northwest
Washington, D.C. 20036
IV-D-8 Mr. W. R. Johnson
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
aThe identification code for the lead-acid battery manufacture docket is OAQPS-79-1.
2-2
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Table 2-1. (continued)
Docket number3 Commenter and affiliation
IV-D-9 Mr. Robert L. Grunwell, President
The Hydrate Battery Corporation
3220 Odd Fellows Road
Lynchburg, Virginia 24506
IV-D-10 Mr. Richard A. Valentinetti
Chief, Air and Solid Waste Programs
Agency of Environmental Conservation
State Office Building
Montpelier, Vermont 05602
IV-D-11 Mr. Sudhir Jagirdar, P.E.
Senior Sanitary Engineer
State of New York
Department of Environmental Conservation
202 Mamaroneck Avenue
White Plains, New York 10601
IV-D-12 Mr. Harry H. Hovey, Jr.
Director, Division of Air
State of New York
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
IV-D-13 Mr. Jack Boys
Prestolite Battery Division
C 511 Hamilton Street
Toledo, Ohio 43694
IV-D-14 Mr. James F. McAvoy, Director
Environmental Protection Agency
State of Ohio
Box 1049
Columbus, Ohio 43216
IV-D-15 Mr. Charles C. Miller
Director, Air and Land Quality Division
Iowa Department of Environmental Quality
900 East Grand Avenue
Des Moines, Iowa 50310
IV-D-16 Mr. W. M. Rallies
Manager, Health and Safety
Exide Corporation
P.O. Box 336
Yardley, Pennslyvam'a 19067
2-3
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Table 2-1. (continued)
Docket number Commenter and affiliation
IV-D-17 Mr. J. M. Beaudoin, Manager
Health, Safety, and Environmental Control
Globe-Union Incorporated
5757 North Green Bay Avenue
Milwaukee, Wisconsin 53201
IV-D-18 Mr. John M. Daniel
State Air Pollution Control Board
Room 1106
Ninth Street Office Building
Richmond, Virginia 23219
IV-D-19 Mr, Roger Winslow, President
Voltmaster Company, Incorporated
P.O. Box 388
Corydon, Iowa 50060
IV-D-20 Mr. Ray Donnelly, Director
Office of Legislation and Interagency Programs
U.S. Department of Labor
Occupation Safety and Health Administration <
Washington, D.C. 20210
IV-D-25 Mr. Carl C. Mattia
Manager, Environmental Activities
The PQ Corporation
P.O. Box 840
Valley Forge, Pennsylvania 19482
The identification code for the lead-acid battery manufacuture docket
is OAQPS-79-1.
2-4
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to the number of batteries produced. At the timejof proposal, it was
estimated that odd-size lead-acid batteries represent a very small share of
the lead-acid battery market; however the comments received on the proposed
standards indicate that a significant number of odd-sized batteries are
produced. Industrial batteries, which can be as much as 50 times larger
than automobile batteries, are estimated to represent about 7 percent of
total U.S. lead-acid battery production.1
The small size cutoff for the promulgated regulation is expressed in
terms of lead throughput. The promulgated standards will affect new,
modified, and reconstructed facilities at any plant with the capacity to
i produce in one day batteries which would contain, in total, an amount of
lead greater than or equal to 5.9 Mg (6.5 tons). This cutoff is equivalent
. to the 500 bpd cutoff for plants producing typical automobile batteries.
1 The level is based on an average battery lead content, of 11.8 kg (26 lb) of
lead per battery.
I
! Cpmaiervt: Ore commenter questioned whether plant capacity is to be
determined based on the maximum demonstrated production rate or the estimated
maximum production rate, for the purposes of the small size cutoff,
Response: For the purposes of the small size cutoff, the parameter to
be used to determine the production capacity of a plant is the design
capacity. The design capacity is the maximum production capability of the
plant and can be determined using the design specifications of the plant's
component facilities, taking into account process bottlenecks. The design
capacity of a plant can be confirmed by checking production records. The
figure cited as a plant's production capacity should not be less than the
maximum production rate in the plant's records.
Comment: Several commenters felt that the 500 bpd cutoff should be
raised to 2000 bpd. This contention was based on the fact that Federal
I , regulations which set minimum standards for State implementation plans
i (SIPs) for the lead NAAQS do not require ambient air quality monitoring or
! atmospheric dispersion analyses for plants smaller than 2000 bpd (40 CFR 51.80(a)(l)
i and 51.84(a)}. The commenters considered these cutoffs to be indicative of
decision by EPA that battery plants smaller than 2000 bpd are not material
i contributors to lead air pollution.
2-5
-------
Response: It should be noted that the Federal regulations to which the
commenters referred only set minimum standards for a lead SIP. Also, as
discussed in Section 2.6 of this chapter, the regulatory approach for NAAQS
regulations promulgated under Section 109 of the Clean Air Act differs from
that for standards of performance promulgated under Section 111 of the Act.
The small size cutoff for the standards of performance for lead-acid battery
manufacture is-, based on a thorough analysis of the economic impacts of these
standards. The analysis indicated that the economic impact of standards on
plants smaller than about 250 bpd could be severe, but showed that the
economic impact would be reasonable for plants with capacities greater than
or equal to 500 bpd. None of the conmenters submitted information indicating
that the economic impact of standards might be severe for plants in the 500
to 2000 bpd size range. Therefore, although the small size cutoff is now
expressed in terms of lead throughput rather than battery production, the
level of the cutoff remains at the lead throughput capacity which corresponds
to a production capacity of 500 bpd.
Comment: One commenter stated that the choice of a size cutoff of
500 bpd appears to be arbitrary.
Response: As noted above, the size cutoff of 500 bpd (5.9 Mg/day or
6.5 tons/day of lead) is based on a thorough economic impact analysis of the
new source performance standards.
Comment: One commenter stated that, as the regulation is written, the
standards of performance would not apply to facilities at plants producing
only lead-acid battery components, such as grids.
Response: Standards of performance for lead-acid battery manufacture
have been developed as a result of determination made by the Administrator
.that lead-acid battery manufacturing plants contribute significantly to air
pollution, which may reasonably be anticipated to endanger public health or
welfare. No such determination has been made for plants producing only
certain battery components. In fact, it is not expected that such plants
will be constructed, because of the high cost of transporting lead
components from plant to plant, EPA will review this regulation four years
2-6
-------
after the date of promulgation. If battery component plants become prevalent,
consideration will be given at that time to applying this regulation to such
plants.
Comment: Another commenter felt that the stack gas concentration
standards for grid casting, paste mixing, three-process operation, lead
reclamation, and other lead-emitting facilities do not allow for differences
in the quantity of emissions between small plants and large plants. This
commenter recommended that the emissions limits for these facilities be
expressed in terms of allowable lead emissions per lead throughput, rather
than in terms of exhaust gas lead concentration.
Response: The airflow rate from a particular type of facility increases
with the production capacity of the facility. Because the standards for
grid casting, paste mixing, three-process operation, lead reclamation, and
other lead-emitting facilities limit lead concentration in airstreams, the
allowable lead emissions from these facilities increase as the airflow rates
increase. Thus, the exhaust gas concentration standards mentioned by the
commenter allow for emissions differences between large and small plants.
Comment: Several commenters contended that the 0 percent opacity
standard is impractical. These commenters were concerned that emissions
from facilities which emit fine particles would exceed 0 percent opacity.
Also, some were concerned that emissions from facilities controlled by
fabric filters would exceed 0 percent opacity during fabric filter cleaning.
However, one commenter stated that the 0 percent opacity standard appears to
be achievable for all affected facilities.
Response: The 0 percent opacity standard for lead oxide manufacturing,
grid casting, paste mixing, three-process operation and "other lead emitting"
facilities is considered reasonable. Lead oxide manufacturing, grid casting,
paste mixing, and three-process operation facilities were observed by EPA to
have emissions with 0 percent opacity for periods of 3 hours a.nd 19 minutes,
7 hours and 16 minutes, 1 hour and 30 minutes, and 3 hours and 51 minutes,
respectively. For grid casting, the observations were made at a facility
controlled by an impingement scrubber. For lead oxide production and
three-process operation facilities, the observation periods included fabric
2-7
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filter cleaning phases. Also, under the promulgated standards, compliance
with the opacity standard is to be determined by taking the average opacity
*
over a 6-minute period, according to EPA Test Method 9, and rounding the
average to the nearest whole percentage. The rounding procedure is specified .
in order to allow occasional brief emissions with opacities greater than
0 percent, which may occur during fabric filter cleaning,
A standard of 0 percent opacity was also proposed for lead reclamation
facilities. Emissions with opacities greater than 0 percent were observed
from the lead reclamation facility tested by EPA, which was controlled by an
impingement scrubber. However, because the proposed emission limit for lead
reclamation was based on transfer of fabric filtration technology, the
0 percent opacity standard was considered reasonable. As noted in Section 2.2
of this chapter, the final emission limit for lead reclamation is based on
the demonstrated emission reduction capabilities of the impingement scrubber
system tested by EPA. Therefore, the opacity standard for lead reclamation
has.also been changed. The final opacity standard is 5 percent, based on
observations at the facility tested by EPA. Emissions from this facility
were observed for 3 hours and 22 minutes, and, during this period, emissions
ranging from 5 to 20 percent opacity were observed for a total of about
11 minutes. The highest 6-minute average opacity during the 3 hour and
22 minute observation period was 4,0 percent. Therefore, the 5 percent
opacity standard for lead reclamation is considered reasonable.
Under the general provisions applicable to all new source performance
standards (40 CFR 60.11), an operator of an affected facility may request
the Administrator to determine the opacity of emissions from the affected
facility during the initial performance test. If the Administrator finds
that ah affected facility is in compliance with the applicable standards for
which performance tests are conducted, but fails to meet an applicable
opacity standard, the operator of the facility may petition the Administrator
to make an appropriate adjustment to the opacity standard for the facility.
Comment: Some commenters stated that EPA should established a
relationship between opacity and emissions before setting opacity standards.
2-8
-------
f?
Response: Opacity limits are being promulgated in addition to mass
emission limits because the Administrator believes that opacity limits
provide the only effective and practical method for determining whether emission
control equipment, necessary for a source to meet the mass emission limits,
is continuously maintained and operated properly. It has not been the
Administrator's position that a single, constantly invariant and precise
correlation between opacity and mass emissions must be identified for each
source under all conditions of operation. Such a correlation is unnecessary
to the opacity standard, because the opacity standard is set at a level such
that if the opacity standard is exceeded for a^particular facility, one
would expect that the applicable emission limitation will also be exceeded.
Furthermore, as noted above, a mechanism is provided in the general provisions
whereby the operator of a facility can request that a separate opacity
standard be set for that facility if, during the initial performance test,
the Administrator finds that the facility is in compliance with all applicable
performance standards but fails to meet an applicable opacity standard,
Comment: Some commenters felt that additional testing should be conducted
before standards are promulgated. Several felt that the Administrator
should conduct tests of emissions from Barton lead oxide manufacturing
process, rather than base a standard for this process on tests of a ball
mill lead oxide process. This comment is discussed in Section 2.2 of this
chapter. One commenter contended that the EPA data base is narrow, and that
tests should be conducted to determine the variability of the efficiency of
emission control systems.
Response: The Administrator has determined that the data base developed
by EPA provides adequate support for the promulgated new source performance
standards. Standards promulgated under Section lll(b) of the Clean Air Act
are intended to require the best demonstrated control technology, considering
cost, nonair quality health and environmental impact, and energy impacts.
Thus, the promulgated standards are based on tests of facilities which have
been determined by EPA to be well controlled and typical of facilities used
in the industry. As noted by some commenters, EPA has not tested emissions
from facilities producing maintenance-free or low-maintenance batteries or
Barton lead oxide production facilities. Differences between such facilities
2-9
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and the facilities tested by EPA are discussed in detail below and in
Section 2,1 of this chapter. These differences are not expected to have a
significant effect on the controlled lead concentrations achievable using
the emission control techniques tested by EPA, Commenters did not refer to
nor is EPA aware of any other specific process variations which might influence
emissions. In order to allow for variations which may occur between emission
concentrations from a particular type of facility, the promulgated lead
emissions limits are set above the levels shown to be achievable in EPA
tests.
Comment: Some commenters stated that changes have occurred in the
lead-acid battery manufacturing industry, which may influence emissions,
since the EPA tests were conducted. The changes cited by the commenters
were the production of maintenance-free and low-maintenance batteries, and.
the increasing of volumes of air ventilated from facilities in order to meet
more stringent OSHA standards regulating in-plant lead levels.
The commenters briefly described the difference between maintenance-free
or low-maintenance batteries and normal-maintenance batteries. The only
substantial difference is that a calcium-lead alloy is used to make low-maintenance
and maintenance-free batteries, while standard batteries are made using an
antimonial lead alloy. This difference influences the grid casting and lead
reclamation facilities, where molten lead is processed. The major change is
in the makeup of the dross which must be removed from molten lead in these
facilities. For grid casting, the calcium alloy also requires the use of
soot as a mold release agent. For the antimonial lead alloy used in standard
batteries, either soot or sodium silicate can be used.
The commenters stated that exhaust volumes for lead-acid battery facilities
have been increased a a result of the revised OSHA standards. One commenter
contended that this change will increase the concentration of uncontrolled
emissions.
Response: The different makeup of dross in grid casting and lead
reclamation facilities producing maintenance-free and low maintenance batteries
is not expected by EPA to cause noticeable differences in lead emissions
between these facilities and facilities producing standard lead-acid batteries.
2-10
-------
The commenters did not give reasons why this difference might be expected to
affect emissions. Dross consists of contaminants in the molten lead alloy
which float to the surface and must periodically be removed. The presence
of a dross layer has an impact on emissions, in that the dross layer serves
to reduce fuming from the molten lead. However, this will occur regardless
of the composition of the dross layer. Also, because the dross layer is
made up chiefly of contaminants from the lead, the entrainment of dross
particles in air exhausted from grid casting or lead reclamation facilities
will not significantly affect lead emissions. Thus, the effect of the dross
layer composition on emissions is expected to be much less than the effects
of process operation parameters, such as the frequency of dross removal and
the temperature of the molten lead alloy.
The use of soot rather than sodium silicate as a mold release agent in
grid casting will not affect uncontrolled lead emissions from this facility.
However, the presence of entrained soot in uncontrolled grid casting emissions
may require the use of scrubbers rather than fabric filters to control these
emissions. This problem is discussed in detail in Section 2.2 of this
chapter.
It is acknowledged that the exhaust volumes at the facilities tested by
EPA may not have been sufficient for the attainment of the 50 yg/m3 OHSA
in-plant lead concentration standard. At the time of the tests conducted by
EPA the OSHA standard was 200 yg/m3. However, higher exhaust volumes would
cause a decrease in the concentration of uncontrolled emissions rather than
an increase. Also, the additional lead particles captured as a result of
the higher exhaust volumes will consist mainly of large particles which are
readily captured by control systems.
Comment: One commenter stated that there is a trend in the lead-acid
battery manufacturing industry to the use of finer lead oxide in battery
pastes in order to increase battery efficiency. The commenter also contended
that this particle size change will influence the collection efficiency
attainable with fabric filters.
2-11
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Response: Lead emissions from lead-acid battery manufacture are generated
by two mechanisms. Lead oxide fumes are produced in welding, casting, and
reclaiming operations, and to a certain extent in lead oxide production.
Agglomerates of lead and lead oxide particles are emitted from operations
involving the handling of lead oxide, lead oxide paste, and lead grids. The
particles which are most difficult to capture are the fume particles. The
emission rate and characteristics of these fume particles are not dependent
on the size of the lead oxide particles used in battery pastes, but on the
temperature of the lead during the operations from which they are emitted.
For these reasons, trends in the industry to the use of smaller lead oxide
particles are not expected to change the particle size distributions of
emissions in such a way that collector performance will be affected.
2.2 EMISSION CONTROL TECHNOLOGY
Comment: Several commonters thought that the proposed standards would
have required the use of fabric filtration to control emissions.
Response: The proposed standards would not have required that specific
control technology be used for any affected facility, nor will the promulgated
standards require specific control techniques. Rather, the standards set
emission limits which have been demonstrated to be achievable by the use of
the .best control systems considering costs, energy impacts and nonair quality
environmental impact. The standards do not preclude the use of alternative
control techniques, as long as the emission limits are achieved.
Comment: The selection of fabric filtration as the best system of
emission reduction for grid casting and lead reclamation facilities was
criticized by a number of commenters. These facilities are normally uncontrolled
or controlled by impingement scrubbers. The commenters pointed out that
only one grid casting facility in the United States is controlled by a
fabric filtration system and that this system has been plagued by fires.
They explained that the surfaces of exhaust ducts for grid casting and lead
reclamation operations become coated with hydrocarbons and other flammable
materials. For grid casting, these include bits of cork from the molds,
oils used-for lubrication, and soot, which is often used as a mold release
agent. For lead reclamation, hydrocarbons from plastic and other contaminants
2-12
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charged with lead scrap become entrained in exhaust gases and deposit on-the
walls of exhaust ducts. These materials are readily ignited by sparks
which, the commenters contended, are unavoidable. The commenters stated
that fires started in the exhaust ducts will generally propagate to the
• control system. One commenter indicated that problems caused by such fires
are not generally severe for scrubbers, but fires would cause serious damage
and emissions excursions if fabric filters were used. The commenters stated
that spark arresters would not solve the fire problem, because they too
would become coated with flammable materials which would be ignited by
v< sparks.
j Apart from the problem of fires, commenters contended that contaminants
present in the exhaust gases from grid casting and lead reclamation would
i cause frequent bag blinding if fabric filters were applied to these facilities.
.In addition to the materials listed above, sodium silicate, which is often
used as a mold release agent for grid casting, was cited,by the commenters
as an extremely hygroscopic compound which would cause bag blinding,
Commenters also felt that the EPA particle size and emissions test data
did not support the contention made by EPA that a fabric filter could achieve
99 percent emission reduction for emissions from grid casting and lead
reclamation.
Response: Based on the information available when standards for lead-acid
battery manufacture were proposed, EPA had concluded that fabric filtration
could be used to control emissions from grid casting and lead reclamation,
1 and that 99 percent collection efficiency could be attained. The problem of
bag blinding could be avoided by keeping the exhaust gases from these facilities
at temperatures above their dewpoints. Also, it was thought that exhaust
duct fires could be prevented by the use of spark arresters. Therefore, the
1 j proposed standards for grid casting and lead reclamation were based on tests
I t of uncontrolled emissions from these facilities, and on fabric filter
; efficiencies demonstrated for the three-process operations for facility and
, for industries with emissions of similar character to those from lead-acid
battery manufacture. In light of the point made by commenters that spark
arresters would not prevent fires, EPA has concluded that the standards for
; grid casting and lead reclamation facilities should not be based on fabric
1 filters.
2-13
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The proposed emission limitations for grid casting and lead reclamation
could probably be achieved using a high energy scrubber such as a venturi;
however, because of the particle size of emissions from these facilities, a
scrubber pressure drop of about 7.5 kPa (30 in. W.G.) would be required.2"5
The energy requirement to overcome this pressure drop is not considered
reasonable fur these facilities. The emission limits for paste mixing,
three-process operation, and other lead-emitting facilities are based on the
application of fabric filters with average pressure drops of about 1.25 kPa
(5 in. W.G.). Thus, the electricity requirement per unit volume of exhaust
gas to operate venturi scrubbers for the grid casting and lead reclamation
facilities would be roughly six times the electricity requirement per unit
volume to control other plant exhausts.
The Administrator has determined that, for the lead-acid battery
manufacturing industry, impingement scrubbers operating at a pressure drop
of about 1,25 kPa (5 in. W.G.) represent the best system of emission
reduction considering costs, nonair quality health and environmental impact
and energy requirements for grid casting and lead reclamation. Therefore,
in the promulgated standards, the emission limitations for grid casting and
lead reclamation have been raised to levels which have been shown to be
achievable in tests of scrubbers controlling these facilities. This change
represents a change from the regulatory alternative chosen from the proposed
standards. The environmental, economic, and energy impacts of the alternative
which has been chosen for the promulgated standards are discussed in Chapter 8
of Volumes I. It is estimated that standards based on the application of
impingement scrubbers to grid casting and lead reclamation facilities will
result in a 50 percent decrease in NSPS electricity requirements from standards
requiring venturi scrubbers for these facilities, while having only a slight
impact on the emission reduction attributable to the NSPS. (Chapter 1,
Tables 1-3, 1-4, and 1-6).
EPA measured lead emissions from two grid casting facilities (Volume I,
Chapter 4 and Appendix C). One of these facilities was uncontrolled, and
the other was controlled by an impingement scrubber. The average lead
concentration in the exhaust from the uncontrolled facility was 4.37 mg/dscm
2-14
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(19.1 x 10" gr/dscf). Average uncontrolled and controlled lead emissions
from the scrubber controlled facility were 2.65 tng/dscm (11.6 x 10" gr/dscf)
and 0,32 mg/dscm (1.4 x 10~ gr/dscf}» respectively. The promulgated
standard for grid casting, 0.4 mg/dscm (1.76 x 10~ gr/dscf}, is based on
the controlled lead emission rate for this facility. The facility is considered
typical of grid casting facilities used in the lead-acid battery manufacturing
industry. EPA is not aware of any process variations which would result in
a significant increase in the emission concentration achievable using a
scrubber control system. However, in order to allow for variations in grid
casting emissions, the promulgated lead emission limit has been set above
the level shown to be achievable in the EPA test.
Grid casting test results were also submitted by two commenters. Data
submitted by one commenter for a grid casting facility show average
uncontrolled lead emissions of about 2 mg/dscm (9 x 10" gr/dscf).6 The
test method used to collect these data is similar to Method 12. Data submitted
by the other commenter showed average uncontrolled lead emissions of about
1.1 mg/dscm (4.7 x 10" gr/dscf}; however, the test method used to gather
these .data is not known.7
Lead reclamation emissions were measured by EPA for a facility controlled
by an impingement scrubber (Volume I, Chapter 4 and Appendix C). Average
lead concentrations in the inlet and outlet streams from the scrubber were
227 mg/dscm (990 x 10~4 gr/dscf} and 3.7 mg/dscm (16 x 10~4 gr/dscf). The
standard for lead reclamation, 4.5 mg/dscm (19.8 x 10~ gr/dscf), is based
on the controlled emission rate measured for this facility. This facility
is considered typical of lead reclamation facilities used in the lead-acid
battery manufacturing industry. EPA is not aware of any process variations
which would result in a, significant increase in the emission concentration
achievable using a scrubber control system. In order to allow for variation
in lead reclamation emissions, the promulgated lead emission standard has
been set above the emission level shown to be achievable in the EPA test.
Comment;: Several commenters criticized the choice of fabric filtration
as the best system of emission reduction for the entire paste mixing cycle.
The paste mixing operation is a batch operation consisting of two phases:
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charging and mixing. The paste mixing facility is generally controlled by
impingement scrubbing, although fabric filtration is often used to control
exhaust from the charging phase. The commenters felt that if fabric
filtration were to be used for the entire cycle, the moisture present in the
exhaust during the mixing phase would cause bag blinding. Therefore, they
requested that the emission limit for paste mixing be raised to a level
achievable using impingement scrubbers.
Response: If fabric filters are used to meet the emission limit, bag
blinding can be prevented by keeping paste mixer exhausts at temperatures
above their dew points. . The energy which would be required to heat the
exhaust gases and the costs for providing insulation for ducts and fabric
filters applied to paste mixing facilities were taken into consideration in
the energy and economic analyses for the new source performance standards.
These costs and energy requirements are considered reasonable. In addition,
data submitted by one commenter show that the standard for paste mixing is
achievable using scrubbers. Tests were conducted of emissions from two
scrubber controlled paste mixing facilities, using methods similar to
Method 12, These tests indicated average controlled lead emissions of
0.04 mg/dscm (0.19 x 10"4 gr/dscf) and 0.07 mg/dscm (0.30 x 10"4 gr/dscf)
for the two facilities.8,9 Both of these average concentrations are well
below the 1 mg/dscm (4.4 x 10" gr/dscf) standard for paste mixing.
Comment: Some commenters contended that EPA test data did not
adequately support the statement that 99 percent collection efficiency could
be achieved for paste mixing emissions. The commenters felt that the
standard for paste mixing should be relaxed.
Response: The standard for paste mixing is considered achievable.
Emissions from a paste mixing facility controlled by an impingement scrubber
were tested by EPA. The average uncontrolled lead concentration from this
facility was 77.4 mg/dscm (338 x 10 gr/dscf). Thus, the promulgated
regulation is expected to require about 98.7 percent control of lead
emissions from paste mixing. EPA tests of a fabric filtration system
controlling a three-process .operation showed an average lead collection
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efficiency of 99.3 percent. This fabric filtration system underwent bag
cleaning during testing. Also, EPA tests and statements made by several
eommenters indicate that the particle size distribution for paste mixing
emissions is similar to that for three-process operation emissions.
Emissions from paste mixing are made up of lead oxide agglomerates, while
emissions from three-process operation facilities are made up mainly of
agglomerates with some fumes and some other large particles. The above data
clearly show that efficiencies greater than 98.7 percent can be achieved for
paste mixing emissions.
In addition, EPA tests of a controlled paste mixing facility indicate ,
that the 1 mg/dscm standard for paste mixing is achievable. EPA conducted
tests at a plant where paste mixing emissions were controlled by two separate
systems. At this plant, paste mixing required a total of 21 to 24 minutes
per batch. During the first 14 to 16 minutes of a cycle (the charging
phase), exhaust from the paste mixer was ducted to a fabric filter which
also controlled emissions from the grid slitting (separating) operation.
During the remainder of the cycle (mixing), paste mixer exhaust was ducted
to an impingement scrubber which also controlled emissions from the grid
casting operation. Uncontrolled or controlled emissions for the paste mixer
alone were not tested. The average concentration of lead in emissions from
the fabric filtration system used to control charging emissions was 1.3 mg/dscm
(5.5 x 10" gr/dscf). The average lead content of exhaust from the scrubber
used to control mixing emissions was 0.25 mg/dscm (1.1 x 10 gr/dscf). The
average lead concentration in controlled emissions from this facility was >
about 0.95 mg/dscm (4.2 x 10" gr/dscf) which is slightly below the emission
limit of 1 mg/dscm (4.4 x 10" gr/dscf). A lower average emission concentration
could be achieved by using fabric filtration to control emissions from all
phases of paste mixing.
Also, as noted above, one commenter submitted data showing that the
standard for paste mixing is achievable using impingement scrubbing to
control emissions from the entire cycle.
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Comment: Several commenters criticized the fact that the standard for
lead oxide production is based on tests conducted at a ball mill lead oxide
production facility, but will apply to Barton lead oxide production
facilities as well as ball mill facilities. Some commenters stated that the
particle size of lead oxide to be collected depends on the type of oxide
produced. One cornmenter stated that Barton facilities are more commonly
used to produce lead oxide than ball mill facilities.
Response: However, in both the ball mill process and the Barton
process, all of the lead oxide product must be removed from an air stream.
In the ball mill process, lead pigs or balls are tumbled in a mill, and the
frictional heat generated by the tumbling action causes the formation of
lead oxide. The lead oxide is removed from the.mill by an air stream. In
the Barton process, molten lead is atomized to form small droplets in an air
stream. These droplets are then oxidized by the air round them.
EPA tests on a Barton process indicated that Barton and ball mill
processes have similar air flow rates per unit production rate (Appendix C
of the BIO, Volume I). Because these air streams carry all of the lead
oxide produced, the concentrations of lead oxide in the two streams must
also be similar.
Data submitted by one commenter indicate that the percentage of fine
particles in lead oxide produced by the Barton process is similar to the
percentage of fine particles in lead oxide produced by the ball mill. 10
These data were obtained by placing samples of captured ball mill and Barton
oxides in a Coulter particle counter. The size distributions measured by
this technique are representative of the size of the product oxide, rather
than the airborne oxide entering the collector. However, the similarity of
the percentages of small particles for ball mill and Barton oxides suggest a
similarity in the percentages of small particles in the feed streams to the
collectors for these two processes.
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The similarities between the concentrations and particle size distributions
of the oxide bearing air streams in the Barton and ball mill processes
support EPA's contention that a similar level of emission control could be
achieved for a Barton process as has been demonstrated for the ball mill
process. Also, no test data were submitted by the commenters to show that
the standard for lead oxide production cannot be achieved by a well controlled
Barton process. It should be noted that, to allow for variations in lead
oxide manufacturing emissions, the promulgated standard has been set above
the emission rate shown to be achievable in the EPA ball mill facility test.
Comment: Several cornmenters felt that the standard for lead oxide
production was too stringent. These commenters stated that engineering
calculations using typical fabric filter and cyclone efficiencies indicate
that the standard for lead oxide production would not be met by a facility
controlled by a cyclone and a fabric filter in series.
Response: The emission limit for lead oxide production of 5 milligrams
of lead per kilogram of lead processed is considered reasonable. The limit
is based on results of tests of emissions from a ball mill lead oxide production
facility with a fabric filter control system. The test showed an average
controlled emission rate of 4.2 mg/Kg (8.4 Ib/ton) for this facility. The
emission limit for lead oxide production of 5 milligrams of lead per kilogram
of lead processed is considered reasonable. The limit is based on results.
of tests of emissions from a ball mill lead oxide, production facility with a
fabric filter control system. The test showed an average controlled emission
rate of 4.2 mg/kg (8.4 Ib/ton) for this facility. In estimating the emission
reduction which could be achieved for a lead oxide production facility, the
commenters used typical fabric filter and cyclone efficiencies. It should
be noted that uncontrolled dust streams from lead oxide production are
extremely concentrated. At such concentrations, fabric filter and cyclone
reduction capabilities are higher than under typical conditions.
Comment: Several commenters stated that the emission limit for the
three-process operation was. not supported by the BID for the proposed standards.
However, one commenter stated that the emission limit appears achievable.
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Response: The limit for the three-process operation is based on the
results of EPA tests conducted at four plants where fabric filtration was
used to control three-process operation emissions. Each of the sets of
tests conducted by EPA showed average controlled lead concentrations below
the proposed limit. The standard for the three-process operation has been
set well above the average emission concentration detected in an of the EPA
tests, .Therefore, the lead emission limit for the three-process operation
facility is considered reasonable.
2.3 .MODIFICATION AND RECONSTRUCTION
Comment: One commenter questioned whether the standards would apply to
modified or recontructed facilities at a plant where production capacity is
increased from below the small size cutoff to above the cutoff as a result
of the modification or reconstruction.
Response: Circumstances under which an "existing facility" may become
an affected facility (a facility which must be in compliance with applicable
standards) are described in the modification and reconstruction provisions
for new source performance standards (40 CFR 60.14, 60.15). For the purposes
of these provisions, an existing facility is defined as "any apparatus of a
type for which a standard is promulgated {§60.2(aa)).!l A lead-emitting
operation at a lead-acid battery plant which is smaller than the size cutoff
(5.9 Mg/day or 6.5 tons/day of lead throughput) is of a type for which a
standard is promulgated and is, therefore, an existing facility. Upon
undergoing "modification" or "reconstruction" (defined in §60.14 and §60.15),
such a facility would be considered as an affected facility if, during its
modification or reconstruction, the production capacity of the plant
containing the facility is increased above the small size cutoff.
2.4 ECONOMIC IMPACT
Comment^: One commenter contended that new source performance standards
would impose a substantial and burdensome cost of the lead-acid battery
manufacturing industry. Another stated that battery sales have fallen by
25 percent in recent years.
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•ResP°nse: The economic impacts of new source performance standards on
the lead-acid battery manufacturing industry are analyzed and described in
detail in Volumes I and II of the BID. These impacts are summarized in
Chapter 1. The projected economic impacts are considered reasonable. The
expected annualized cost of compliance with the promulgated standards at a
typical affected plant is expected to be only about 1.6 percent of the
wholesale price of a battery; and the economic impact analysis indicates
that this cost could be passed on with little effect on sales.
The market for lead-acid batteries is tied to the automobile market for
both original equipment and replacement batteries. The 25 percent drop in
sales cited by the second commenter results from the recent decline in the
demand for domestic automobiles. This decline is not expected to continue
and the .sales of the domestic automobile industry are expected to increase
in the near future.
Comment: Several commenters contended that the cost of compliance with
OSHA standards was not adequately addressed in Volume I of the BID. The
commenters also felt that the OSHA standards would require higher ventilation
rates than are currently needed, and would thus cause the costs of compliance
with new source performance standards to be higher than the estimates made
by EPA.
Response: The OSHA compliance costs presented in Volume I are based on
the capital and operating control costs which were expected to be required
to meet the employee exposure standards of 200 pg/m3 originally proposed by
OSHA in 1975. The controls include employee care, general plant maintenance,
and local ventilation of iri-plant lead emission sources. On November 14, 1978,
OSHA promulgated an employee exposure standard of 50 yg/m3. However, the
controls necessary to comply with this standard are expected to be similar
to those which would have been necessary for the originally proposed 200 vg/m^
standard.", 12 In addition, the economic impact projected for the OSHA
standards in Volume I may be higher than the actual economic impact, because,
in a number of cases, work practices can be used to achieve the OSHA standard
in place of technological controls.
In Volume I of the BID, the statement is made that a change in the OSHA
standards could cause the control costs for the new source performance
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standards to increase substantially. However, the facility exhaust rates
used to estimate the costs of achieving the NSPS were set at levels which
would provide good ventilation for the facilities under consideration. The
exhaust rates were chosen to achieve a face velocity of 250-300 ft/min for
13 14
hoods, and 300-350 ft/min for slot-type vents. * One industry representa-
tive stated that face velocities have been increased from 150-200 ft/min to
350-500 ft/min in order to reduce lead levels in the working zone to below
50yg/m3. Thus, although the ventilation rates used in the industry to
comply with the current OSHA standards may be much higher than those which
have been used in the past, they are not much higher than the ventilation
rates used to calculate the economic impacts of the promulgated new source
performance standards. Thus, it is not expected that the change in the OSHA
standards would have a significant impact on the results of the economic
impact analysis for the NSPS.
Comment: One commenter stated that the new source performance standards
would indirectly require the installation of stacks which would meet the
criteria specified by EPA Reference Method 1 for sampling and gas velocity
measurements. The commenter stated that the impacts of this requirement
were not addressed.
Response: The costs of stacks which meet EPA Method 1 criteria are not
considered attributable to new source performance standards. Under SIP
regulations, most States require an initial performance test for any new
source. Therefore, in the absence of the promulgated standards, most new
facilities would nonetheless be required to have stacks.
2.5 ENVIRONMENTAL IMPACT
Comment: A number of commenters stated that lead-acid battery manufacture
accounts for a small percentage of total nationwide lead emissions and
contended, for this reason, that new source performance standards for lead-acid
battery manufacture should not be set. One commenter cited data which
indicate that lead emissions from lead-acid battery manufacture accounted
for only about 0.32 percent of industrial lead emissions or about 0.014 percent
of total nationwide lead emissions in 1975.
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•.Response.; It is acknowledged that lead-acid battery plants account for
a relatively small share of total nationwide atmospheric lead emissions. In
1975, about 95 percent of U.S. lead emissions resulted from the production
of alkyl lead gasoline additive, the burning of leaded gasoline, and the
disposal of crankcase oil from vehicles which burn leaded gasoline. These
emissions will be reduced substantially as the use of alkyl lead gasoline
additives is curtailed. Another 1 percent of nationwide lead emissions is
from mining and smelting operations, which are generally located in remote
areas. Because lead-acid battery plants are generally located in urban
areas — near the markets for their batteries -- lead emissions from lead-acid
battery manufacture may reasonably be anticipated to endanger public health ^
or welfare. Therefore, the Administrator considers the development of new
source performance standards for lead-acid battery manufacture to be justified.
Comment: Several commenters recommended that the grid casting facility
be removed from the list of affected facilities. According to EPA estimates,
grid casting accounts for about 3.2 percent of overall uncontrolled battery
'plant lead emissions. The commenters stated that it is unreasonable to
require sources to control facilities generating such a small percentage of
total plant emissions.
Rg_sp_onse_: Although grid casting is small source of emissions relative
to other facilities, it is not an insignificant source. Lead emissions from
this facility are controlled at a number of existing plants. Also, if other
facilities at a plant were controlled to the extent required under the new
source performance standards, but grid casting facilities were left
uncontrolled, emissions from grid casting would amount to about 50 percent «
of the total plant lead emissions. Therefore, the standard for grid casting
is considered environmentally beneficial. Also, the costs and energy
requirements of controls for this facility have been included in the energy
and economic impact analyses of the new source performance standards and are
considered reasonable.
2.6 LEGAL CONSIDERATIONS
Comment: One comment which involved legal considerations was that, if
fabric filtration is considered the best available control technology for a
facility, then an equipment standard requiring fabric filtration should be set for
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that facility rather than a performance standard. The commenter pointed out
that, under Section lll(h) of the Clean Air Act, the Administrator is empowered
to promulgate a design, equipment, work practice, or operational standards,
or combination thereof.
Response^: Section lll(h) states that an equipment standard may be
promulgated only if the Administrator determines that it is not feasible to
prescribe or enforce a standard of performance. Thus, because performance
standards are feasible for the lead-acid battery manufacture source category,
the Administrator has no reason to promulgate equipment standards for this
source category.
Comment: Another comment which involved legal considerations was that,
because a National Ambient Air Quality Standard for lead has been established,
new source performance standards regulating lead emissions would be redundant
and unnecssary.
Response: It should be noted that the purposes of standards of performance
for new sources promulgated under Section 111 of the Clean Air Act differ
from the purposes of national ambient air quality standards, which are
promulgated under Section 109 of the Act. National ambient air quality
standards are established to protect the public health or welfare. Under
Section 109 of the Clean Air Act, national ambient air quality standards are
to be set at levels such that the attainment and maintenance of the standards
are requisite to protect the public health or welfare.
New source performance standards promulgated under Section 111 of the
Clean Air Act are not designed to achieve any specific air quality levels,
but are instead established to enhance air quality. Under Section 111,
such standards are to reflect the degree of emission limitation achievable
through application of the best demonstrated technological system of
emission reduction considering cost, any nonair cuality health and environ-
mental impact, and energy requirements.
Congress expressed several reasons for requiring the setting of new
source performance standards reflecting the degree of emission reduction
achievable through application of the best demonstrated control technology,13
First, national standards are needed to avoid situations where some States
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may attract industries by relaxing standards relative to other States.
Second, because the national ambient air quality standards create air quality
ceilings which are not to be exceeded, stringent standards for new sources
enhance the potential for long term growth. Third, stringent standards may
help achieve long-term cost savings by avoiding the need for expensive
retrofitting when pollution ceilings may be reduced in the future. Fourth,
the standard-setting process should create incentives for improved technology.
2.7 TEST METHODS AND MONITORING
2.7.1, Reference Method 12
Comment: A number of conroenters felt that Reference Method 12 was
cumbersome and recommended the development of a simpler screening'method.
The coramenters stated that a battery plant may have as many as two dozen
stacks and that, at an average cost of $6000 per stack test, the cost of
testing an entire plant could be extremely high.
Respons_e: Because controlled emission levels are expected to be near
the emission limits for facilities affected by the regulation, a screening
method less accurate than Method 12 would not be suitable for determining
compliance with the lead-acid battery manufacture regulation. Also, the per
plant costs of conducting performance tests using Method 12 are not expected
to be as high as the coramenters expected. Although existing plants often
have a large number of stacks, it is expected that, for newly constructed,
modified, or reconstructed plants or facilities, emissions will be ducted to
a small number of stacks. In addition, the estimate of $6000 per stack for
a compliance test applies only for plants where one or two stacks are to be
tested. For plants with a large number of stacks, the cost per stack should
decrease considerably.
Comment: One commenter reconmended that the minimum sampling time for
Method 12 be extended. Others stated that the minimum sampling time for
grid casting in the proposed regulation was too long.
Response: For tests with Method 12, the minimum amount of lead needed
for good sample recovery and analysis is 100 tig. The minimum sampling rates
and times ensure that enough lead will be collected. For grid casting, the
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minimum sampling time has been changed from 180 minutes, in the proposed
regulation, to 60 minutes, in the promulgated action. The change reflects
the alteration in the standard for grid casting.
2.7.2 Reference Method 9
Comment: Two conmenters expressed concern that Method 9 is not accurate
enough to be used to enforce a standard of 0 percent opacity. One commenter
stated that it is difficult to discern the difference between 0 percent
opacity and 1 percent opacity for a given reading.
Response: No single reading is made to the nearest percent, rather,
readings are to-be recorded in increments of 5 percent opacity and averaged
over a period of 6 minutes (24 readings). For the regulation for lead-acid
battery manufacture, the 6 minute average opacity figure is to be rounded to
the nearest whole number. The opacity standard for lead-acid battery manu-
facture is based on opacity data taken for operating facilities, and these
data have shown that this standard'can be met (Section 2.1 of this chapter).
2.8 REPORTING AND RECORDKEEPING
Comment: A number of commenters contended that the proposed pressure
drop monitoring and recording requirement for control systems would not
serve to insure proper operation and maintenance of fabric filters. The
commenters pointed out that a leak in a fabric filter would not result in a
measurable difference in the pressure drop across the filter. One commenter
suggested that the pressure drop monitoring requirement be replaced by an
opacity monitoring requirement. Another commenter suggested that the pressure
drop requirement be replaced by a requirement of visible inspection of bags
for leaks.
Response^; Based on the arguments presented by these commenters, it is
agreed that proposed pressure monitoring requirement for fabric filters
would not serve its intended purpose. Therefore, this requirement has been
eliminated. However, pressure drop is considered to be a good indicator of
proper operation and maintenance for scrubbers. Therefore, the pressure
drop monitoring and recording requirement for scrubbers has been retained.
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The pressure drop monitoring requirement for fabric filters has not
been replaced by another monitoring requirement. The cost of opacity^ ,
monitoring equipment may in some cases be comparable to the cost of emission \
control systems for lead-acid battery manufacturing facilities.17 This cost I
is considered unreasonable. Although periodic visual inspection of bags ,
would provide an indication of bag integrity, visual records would not be '
useful to EPA in the enforcement of the promulgated standards.
Comment: A number of commenters stated that while pressure drop
monitoring is useful for scrubbers, continuous recording of pressure drop
would be unnecessary and expensive. Some commenters questioned whether a
device which cyclically monitors the pressure drop across several emission
control systems would be considered a continuous recorder for the systems.
These commenters also asked how often such a recorder would have to monitor
the pressure drop across a particular control device to be considered a
continuous recorder for that device. One cotwnenter suggested the substitution
of. periodic manual recording of pressure drop for the continuous pressure
drop recording requirement. Another commenter questioned the purpose of
requiring pressure drop monitoring and recording without a requirement that
action be taken at certain pressure drop levels.
Response_: The purpose of pressure drop recording requirements is to
allow the verification by EPA regional enforcement personnel that emission
control systems are properly operated and maintained. The costs of pressure
drop recording devices were analyzed and are considered reasonable. T.he
point of what sort of device would satisfy the recording requirement has
been clarified in the promulgated standards. It has been determined that
for the purposes of this regulation a device which records pressure drop at
least every 15 minutes would accomplish the same purposes as a continuous
pressure drop recorder. Manual pressure drop recording would not ensure
proper operation and maintenance of a control system.
2.9 MISCELLANEOUS _ ';'
Comment: A number of commenters recommended that the definition of the
paste mixing facility be expanded to include operations ancillary to paste
mixing, such as lead oxide storage, conveying, weighing, and metering operations;'
i
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paste handling and cooling operations; and plate pasting, takeoff, cooling,
and drying operations. The commenters stated that paste mixing and operations
ancillary to the paste mixing operation are generally interdependent, in
that one operation is not run without the others. Also, emissions from
paste mixing and ancillary operations are often ducted to the same control
device. The commenters were concerned that a minor change made to a paste
mixing machine could cause the machine to be affected by the promulgated
standards under the reconstruction provisions applicable to all new source
performance standards. They stated that the .recommended change would avoid
this possibility.
Response: These comments are considered reasonable. The operations
ancillary to paste mixing were not intended to be considered separate
facilities, and the definition recommended by the commenters for the paste
mixing facility is considered an appropriate definition. Therefore, this
recommendation has been adopted in the promulgated regulation. Because the
standard which was proposed for paste mixing is identical to that which was
proposed for operations ancillary to paste mixing (other lead-emitting
operations), this change will not affect the environmental impacts of the
standards.
Comment: One commenter recommended that the operations comprising the
three-process operation facility be treated separately. The commenter
stated that emissions concentrations may differ for the three operations.
Response: In the development of the new source performance standards,
it was found that the operations which make up the "three-process operation"
are generally ducted to a common control device.
Comment: One commenter stated that the standards for lead-acid battery
manufacture should also cover battery reclaiming operations.
Response: New, modified, and reconstructed lead battery reclaiming
operations are covered by new source performance standards for secondary lead
smelters, which were promulgated March 8, 1974, ind regulate particulate
emissions. Because most lead emissions from secondary lead smelters are in
the form of particulate matter, the particulate standards serve to regulate
lead emissions as well. The possibility of revising the standards to regulate
sulfur oxide emissions is currently being studied by EPA.
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Cgnrcmeirt; Another commenter recommended that precautions be taken to
prevent fugitive emissions resulting from the handling of material collected
by fabric, filters. The commenter cited as an example a plant at which the
fabric filter catch is conveyed to storage containers using flexible canvas
ducts. These allow the reentrainment into the atmosphere of dust collected
by the fabric filter.
Response: Lead emissions from the handling of captured particulate
matter are not expected to be significant .in comparison with process
emissions. Also, the means of handling captured particulate matter would
vary from plant to plant. Thus, the Administrator did not consider the
development of national standards for such emissions to be justified.
Comment; A revised version of the CRSTER dispersion model was used to
assess the ambient air impact of standards of performance for lead-acid
battery manufacture. One commenter stated that the CRSTER model, as documented
by its users manual (EPA-480/2-77-013), does not address a number of important
factors, including aerodynamic building and stack tip downwash, transitional
plume rise, spatial, separation of emission points, and the fact that most
battery plant exhaust gases are discharged at ambient or near ambient temperatures.
The commenter also stated that EPA new source review guidelines provide for
the use of meteorological data for five years; while for the model lead-acid
battery plants, the model was run using data for only one year.
Response: The revised CRSTER model used in the development of the new
source performance standards was not fully described in Volume ! of the BID.
In fact, all of the factors mentioned by the commenter are addressed in the
revised model which is described in the docket for the proposed standards
(see docket item no. II-B-24). Since the modeling was performed for a hypothetical
plant, there was no requirement to use multiple years of meteorological
data. As was pointed out, direct extrapolation of the results to an actual
plant should not be attempted. If an actual plant were to be modeled,
multiple years of meteorological data would be required.
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Comment; in the preamble to the proposed standards, the public was
specifically invited to submit comments with supporting data on acid mist
control. Only one comment was received regarding the acid mist issue. The
commenter did not refer specifically to acid mist emissions from lead-acid
battery manufacturing, but made the general statement that EPA should devote
more attention to all sulfuric acid emissions and effluents.
Response: Since no evidence was submitted which indicated that
sulfuric acid mist emissions from lead-acid battery manufacture may
reasonably be anticipated to contribute significantly to air pollution,
there is no basis for regulation of sulfuric acid mist emissions from this
industry at this time.
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2.10 REFERENCES. FOR CHAPTER 2 ,
1. Economic Impact Statement--Inorganic Lead. Prepared by D.B. Associates
for the Occupational Safety and Health Administration. Washington, D.C.
February 1977. p. 5-42.
2. Letter and attachments from Hatterscheide, I.E., Gould, Inc. to Central
Docket Section, EPA. March 6, 1980. p. 15. Public comment. (Docket
No. IV-D-3)
3. N Letter and attachments from Beaudoin, J.M., Globe-Union, Inc. to Central
Docket Section, EPA, March 13, 1980. Figure 2. Public comment.
(Docket No, IV-D-17)
4. Lead-Acid Battery Manufacture — Background Information for Proposed
Standards. U.S. Environmental Protection Agency. EPA-45Q/3-79-028a.
November 1979.
5, Memo from Battye, W., GCA/Teehnology Division to Fitzsimons, J.G., EPA.
April 18, 1980. 7p. Pressure drop requirements to achieve 99 percent
control of grid casting and lead reclamation emissions. (Docket No. IV-B-6)
6. Letter and attachments from St. Louis, R,s Pennsylvania Department of
Environmental Resources. June 9, 1976. 27p, Report of Emissions
Testing. (Docket No. IV-D-27)
7. Reference 2. pp. 7,8.
8. Letter and attachments from Hambright, J.K. Pennsylvania Department of
Environmental Resources to central Docket Section, EPA. March 6, 1980.
Enclosure 5. Public .comment, (Docket No. IV-D-2)
9. Report of Emission Testing Performed December 10, 1975 on Entoleter
Scrubber, Prestolite Battery Division, Eltra Corp. Temple, Pennsylvania.
Spotts, Stevens, and McCoy, Inc. January 15, 1976. 24p. (Docket No. IV-D-27)
10. Reference 2. pp. 13, 14.
11. Occupational Safety and Health Administration, Department of Labor.
Occupational Exposure to Lead — Attachments to the Preamble for the
Final Standard. Federal Register. Washington, D.C. 43_( 225): 45585-54488,
54503-54506. November 1978,
12. National Institute for Occupational Safety and Health. The Industrial
Environment ™ its Evaluation and Control. Washington, D.C. U.S.
Government Printing Office, 1973. p. 597-608.'
13. Ferris, W. Battery Plant Ventilation Study. Prepared by AB Machine
and Equipment Co., inc., Memphis, Tennessee for PEDCo Environmental,
Cincinnati, Ohio. October 27, 1980. (Docket No. II-A-1)
•v
2-31
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References (continued)
14. Telephone conversation between Battye, W., CCA/Technology.Division and
Ferris, W., Battery Equipment Service Co., Bradenton, Florida. July 3, 1980.
(Docket No. IV-E-8)
15. Telephone conversation between Battye, W., GCA/Technology Division and
Hatterscheide, T.E., Gould, Inc. April 7, 1980, {Docket No. IV-E-5)
4
16. Committee on Interstate and Foreign Commerce, House of Representatives.
Clean Air Act Amendments of 1977, Report No. 95-294. Washington, D.C.
U.S. Government Printing Office, 1977, pp. 184-186.
17. Memo from Battye, W., GCA/Technology Division to Fitzsimons, J.G., EPA.
August 15, 1980. Cost of opacity monitors for lead-acid battery manufacturing
facilities. (Docket No. 1V-D-8)
2-32
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TECHNICAL REPORT DATA
(Please rfnd Instructions on the reverse before completing)
1. REPORT NO,
EPA-450/3-79-028b
2.
3, RECIPIENT'S ACCESSION NO.
4, TITLE AND SUBTITLE
Lead-Acid Battery Manufacture
for. Promulgated Standards
- Background Information
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
5. REPORT DATE
November 1980
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3057
1-2. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise and Radiation
U.S. Environmental Protection Aaency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES voiyme j discussed the proposed standards and the resulting environ-
mental and economic effects. Volume II contains a summary of public comments, EPA re-
sponses and discussion of the differences between the proposed and promulgated standard
16. ABSTRACT
Standards of performance for the control of emissions from lead-acid battery
manufacturing plants are being promulgated under the authority of Section 111 of the
Clean Air Act. These standards would apply to new, modified, or reconstructed
facilities at any lead-acid battery manufacturing plant with the capacity to produce
in one day batteries which would contain in total an amount of lead greater than or
equal to 5.9 Mg (6.5 tons). This document contains information on the public comments
made after proposal, EPA responses and differences between the proposed and
promulgated standards.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b,IDENTIFIERS/OPEN ENDED TERMS C. COSATI I-'ield/Group
Air pollution
Pollution control
Standards of performance
Lead-acid battery manufacturing plants
Lead
Air Pollution Control
13B
18. D-'STRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS {This Report/
Unclassified
21. NO. OF PAGES
56
20. SECURITY CLASS (Thispage)
Unclassified
22, PRICE
EPA Form 2220-1 (Re¥. 4-77! PREVIOUS EDITION is OBSOLETE
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United States
Environmental Protection
Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park NC 27711
Official Business
Penally for Private Use
S300
Publication No. EPA-450/3-79-O28b
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