ENVIRONMENTAL PROTECTION AGENCY
40 CFR PART 63
[AD-FRL- ]
National Emission Standards for Hazardous Air Pollutants
(NESHAP)
(Secondary Lead Smelters)
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of proposed rule; notice of public hearing.
SUMMARY: This action proposes standards that would limit
emissions of hazardous air pollutants (HAP's) from new and
existing secondary lead smelters. The proposed standards
partially implement section 112(d) of the Clean Air Act (the
Act) as amended in November 1990, which requires the
Administrator to regulate categories of major and area
sources of HAP's listed in section 112(b) of the Act. The
intent of the standards is to reduce HAP emissions from
secondary lead smelters to the maximum degree achievable
through the application of maximum achievable control
technology (MACT). The EPA is also proposing to add
secondary lead smelters that are area sources to the list of
source categories that will be subject to MACT standards.
DATES: Comments. Comments must be received on or before
[insert date 60 days after publication in the Federal
Register].
Public Hearing. If a request to speak at a public
hearing is received, the hearing will be held on [insert
date 30 days after publication in the Federal Register]
beginning at 10:00 a.m. Requests to speak at a public
hearing must be received by the EPA by [insert date 3 weeks
after proposal].
ADDRESSES: Comments. Comments should be submitted (in
duplicate, if possible) to: Air and Radiation Docket and
Information Center (6102), Attention Docket No. A-92-43,
U. S. Environmental Protection Agency, 401 M Street, SW.,
Washington, D.C. 20460. The Agency requests that a
separate copy also be sent to the contact person listed
below.
Public Hearing. If a public hearing is requested, it
will be held at the EPA Office of Administration auditorium
in Research Triangle Park, North Carolina. Persons
interested in attending the hearing or wishing to present
oral testimony should contact Mary Hinson, Industrial
Studies Branch (MD-13), U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina 27711,
telephone number (919) 541-5601.
Background Information Document. The Background
Information Document (BID) for the proposed standard may be
obtained from the docket or from the U. S. EPA Library
(MD-35), Research Triangle Park, North Carolina 27711,
telephone number (919) 541-2777. Please refer to "Secondary
Lead Smelting--Background Information Document for Proposed
Emissions Standards," EPA No. EPA-450/R-94-024.
Docket. Docket No. A-92-43 contains supporting
information used in developing the proposed standards. The
docket is located at the U. S. Environmental Protection
Agency, 401 M Street, S.W., Washington, D.C. 20460 in room
M-1500, Waterside Mall (ground floor), and may be inspected
from 8:30 a.m. to 12:00 p.m. and 1:00 to 3:00 p.m., Monday
through Friday. The proposed regulatory text and other
materials related to this rule making are available for
review in the docket or copies may be mailed on request from
the Air Docket by calling (202) 260-7548. A reasonable fee
may be charged for copying docket materials.
FOR FURTHER INFORMATION CONTACT: For information concerning
the proposed standards and technical aspects of secondary
lead smelting emissions and control, contact
Mr. George Streit at (919) 541-2364, Industrial Studies
Branch, Emission Standards Division (MD-13), U. S.
Environmental Protection Agency, Research Triangle Park,
North Carolina 27711. For information concerning the area
source listing of secondary lead smelters, contact Ms.
Dianne Byrne at (919) 541-5342, Pollutant Assessment Branch,
Emission Standards Division (MD-13) at the above address.
SUPPLEMENTARY INFORMATION: The regulatory text of the
proposed rule is not included in this Federal Register
notice, but is available in Docket No. A-92-43 or by request
from the Air Docket (see ADDRESSES). If necessary, a
limited number of copies is available from the EPA contact
persons designated earlier in this notice. This Notice with
the proposed regulatory language is also available on the
Technology Transfer Network (TTN), one of EPA's electronic
bulletin boards. TTN provides information and technology
exchange in various areas of air pollution control. The
service is free, except for the cost of a phone call. Dial
(919) 541-5742 for up to a 14,400 bps modem. If more
information on TTN is needed, call the HELP line at
(919) 541-5384.
The information presented in this preamble is organized
as follows:
I. INITIAL LIST OF CATEGORIES OF MAJOR AND AREA
SOURCES
II. BACKGROUND
A. Regulatory History
B. Description of Source Category
C. Emissions and Factors Affecting Emissions
D. Adverse Health Effects Finding for Area Sources
III. NESHAP DECISION PROCESS
A. Source of Authority for NESHAP Development
B. Criteria for Development of NESHAP
C. Determining the MACT Floor
IV. SUMMARY OF THE PROPOSED STANDARDS
A. Sources to be Regulated
B. Proposed Emission Limits for Process Sources
C. Proposed Standards for Process Fugitive Sources
D. Proposed Standards for Fugitive Dust Sources
E. Compliance Dates
F. Compliance Test Methods
G. Enhanced Monitoring Requirements
H. Notification Requirements
I. Recordkeeping and Reporting Requirements
V. SUMMARY OF ENVIRONMENTAL, ENERGY, AND ECONOMIC
IMPACTS
A. Facilities Affected by This NESHAP
B. Air Quality Impacts
C. Water Quality Impacts
D. Solid Waste Impacts
E. Energy Impacts
F. Cost Impacts
G. Economic Impacts
VI. RATIONALE FOR SELECTING THE PROPOSED STANDARDS
A. Selection of Pollutants and Source Category
B. Selection of Affected Sources
C. Selection of Basis and Level for the Proposed
Standards for New and Existing Sources
D. Selection of the Format for the Proposed Standards
for New and Existing Sources
E. Selection of Emission Limits and Equipment and Work
Practice Standards
F. Reconstruction Considerations
G. Selection of Compliance Dates
H. Selection of Emission Test Methods and Schedule
I. Selection of Proposed Enhanced Monitoring
Requirements
J. Selection of Notification Requirements
K. Selection of Recordkeeping and Reporting
Requirements
L. Operating Permit Program
M. Whether to Also Regulate Air Emissions Under RCRA
N. Solicitation of Comments
VII. ADMINISTRATIVE REQUIREMENTS
A. Public Hearing
B. Docket
C. Executive Order 12866
D. Paperwork Reduction Act
E. Regulatory Flexibility Act
F. Pollution Prevention Considerations
G. Miscellaneous
VIII. STATUTORY AUTHORITY
I. Initial List of Categories of Major and Area
Sources
Section 112 of the Act requires that the EPA promulgate
regulations requiring the control of HAP emissions from
major and area sources. The control of HAP's is achieved
through promulgation of emission standards under
sections 112(d) and (f) and work practice standards under
section 112(h) for categories of sources that emit HAP's.
An initial list of categories of major and area sources
of HAP's selected for regulation in accordance with
section 112(c) of the Act was published in the Federal
Register on July 16, 1992 (57 FR 31576). Secondary lead
smelters is one of the 174 categories of sources listed.
The category consists of smelters that recycle lead-bearing
scrap materials, primarily lead-acid batteries, into lead
metal. The listing was based on the Administrator's
determination that secondary lead smelters may reasonably be
anticipated to emit several of the 189 listed HAP's in
quantities sufficient to designate them as major sources.
Information subsequently collected by the EPA as part of
this rulemaking confirms that two-thirds of operating
secondary lead smelters have the potential to emit greater
than 9.1 megagrams per year (Mg/yr) [10 tons per year (tpy)]
of a single HAP or greater than 22.7 Mg/yr (25 tpy) of a
combination of HAP's and, therefore, are major sources.
Section 112(c)(3) directs the Administrator to list
each category of area sources that the Administrator finds
presents a threat of adverse effects to human health or the
environment warranting regulation. The EPA performed an
assessment of the remaining one-third of the secondary lead
smelters not qualifying as major sources to determine
whether the listing of these area sources for regulation
under section 112(c)(3) was justified. Based on a detailed
assessment of emissions, population exposure, and known and
suspected health effects, the Administrator proposes finding
that the threat of adverse effects to human health from area
sources in the secondary lead smelter category is sufficient
to support regulation. Smelters designated as area sources
would, under the proposed regulation, be subject to the same
standards as smelters qualifying as major sources. The
rationale for this area source listing is presented in more
detail in section II.D of this preamble.
The secondary lead smelters category was originally in
the group of categories for which final regulations are
scheduled for promulgation by November 15, 1994. Final
regulations are now scheduled for promulgation by May 31,
1995 (58 FR 63952-63953) in accordance with a consent decree
entered in Sierra Club v. Browner, Case Number 93-0124 (and
related cases) (D.D.C. 1993).
II. Background
A. Regulatory History
The EPA promulgated new source performance standards
(NSPS) for secondary lead smelters on March 8, 1974 (40 CFR
part 60, subpart L). The NSPS limit emissions of
particulate matter (PM) from blast and reverberatory
furnaces (including rotary furnaces) to a concentration of
50 milligrams per dry standard cubic meter (mg/dscm)
[0.022 grains per dry standard cubic foot (gr/dscf)] and
emissions from refining kettles (pot furnaces) to 10 percent
opacity. Secondary lead smelters are also subject to state
regulations enacted to prevent violations of the National
Ambient Air Quality Standards (NAAQS) for lead. In
addition, about one-half of smelters are subject to permit
conditions developed under the Prevention of Significant
Deterioration provisions of the Act.
Secondary lead smelters must also obtain hazardous
waste storage permits pursuant to the Resource Conservation
and Recovery Act (RCRA) to store spent lead-acid batteries
before smelting them [40 CFR 266.80(b)]. Air emissions from
smelting activities; however, are not presently regulated
under the hazardous waste rules [40 CFR 266.100(c)].
On July 16, 1992, the EPA published an initial list of
categories of major and area sources selected for regulation
in accordance with section 112(c) of the Act (57 FR 31476).
Secondary lead smelters were among the listed categories.
On December 3, 1993, the EPA published a schedule for the
promulgation of standards for the sources selected for
regulation under section 112(c). According to this
schedule, regulations for secondary lead smelters must be
promulgated no later than May 31, 1995 (58 FR 63941).
Today, the EPA is issuing a notice of proposed rulemaking
for secondary lead smelters and is soliciting comments on
the proposed rule.
Air emissions from secondary lead smelters may also
potentially be subject to regulation under the rules
implementing RCRA. This is because the principal feed
material to these devices, scrap lead-acid batteries, is a
spent material being reclaimed, and hence is defined as a
solid and (by virtue of the lead content) hazardous waste
[40 CFR 261.2(a)(2)(i), (c)(3), and Ilco v. EPA, 996 F. 2d
1126 (11th Cir. 1993)]. In 1991, the EPA decided to defer
RCRA standards for the air emissions from these devices, in
large part because the forthcoming Clean Air Act MACT
standards might make further RCRA controls unnecessary
[56 FR 7142 (Feb. 21, 1991)] [40 CFR 266.100(c)]. In
proposing this rule, EPA believes that this rule also
satisfies the goals and objectives of RCRA so that any
further RCRA regulation of air emissions would be
unnecessary. The EPA is specifically soliciting comments on
this decision.
B. Description of Source Category
Secondary lead smelters are recycling facilities that
use blast, rotary, reverberatory, and/or electric furnaces
to recover lead metal from lead-bearing scrap materials,
primarily lead-acid batteries. The secondary lead smelters
source category does not include remelters and refiners or
primary lead smelters.
There are 23 secondary lead smelters in the United
States, although only 16 of them were operating as of
December 1993. Smelters often close temporarily when the
price of lead is low. A current trend in the industry is
toward fewer but larger smelters, although overall industry
capacity has been relatively constant.
Lead-acid batteries represent about 90 percent of the
lead-bearing raw materials at a typical secondary lead
smelter. The majority of these batteries are automotive-
type batteries and the remainder are industrial and
uninterruptable power supply batteries. The other
10 percent of lead-bearing materials are battery plant
scrap, defective batteries, drosses from refining
operations, and other scrap such as lead pipes and roof
flashing.
About 98 percent of all lead-acid batteries are
recycled at secondary lead smelters. The remaining
2 percent are either stored indefinitely in residential
basements and garages, disposed of as municipal solid waste,
or dumped illegally. Secondary lead smelters, however,
represent the only acceptable disposal option for used
batteries, and these smelters also recover or treat the
plastic case material and sulfuric acid from automotive-type
batteries.
The secondary lead smelting process consists of:
(1) Breaking lead-acid batteries and separating the lead-
bearing materials from the other materials, including the
plastic case material and acid electrolyte, (2) melting lead
metal and reducing lead compounds to lead metal in the
smelting furnace, and (3) refining and alloying the lead to
customer specifications.
Battery breaking is accomplished using hammermills to
crush whole batteries. Saws are used at some blast furnace
smelters to cut open batteries so that the lead grids from
inside the battery can be removed intact as whole units.
The empty cases are then sent to a hammermill for crushing.
Following battery breaking, a sink/float separator is used
to separate the lead-bearing materials from the
polypropylene plastic from the battery cases, which is sold
for recycling.
The lead-bearing components are then sent directly to a
materials storage and handling area or are chemically
treated to remove the sulfur in the lead paste attached to
the battery grids. The desulfurization step is performed to
reduce sulfur emissions from the smelting furnace and to
improve furnace efficiency.
Lead-bearing materials are typically stored in bins or
enclosures before being charged to the smelting furnaces.
If the storage area is not totally enclosed, the storage
piles and the roadways between them are usually kept wet to
prevent the formation of dust that may cause fugitive
emissions. Materials are handled within the smelter by
front-end loaders, enclosed screw conveyors, and belt- or
pan-type conveyors.
Broken battery components are charged to the smelting
furnaces along with lead-bearing slag, dross, flue dust
recycled from the air pollution control devices, fluxing
agents (including iron, silica sand, and limestone or soda
ash), and coke. Fluxing agents are added to blast and
rotary furnaces to promote the conversion of lead compounds
to lead metal. Coke is added to blast furnaces as a fuel
and to rotary and reverberatory furnaces as a fluxing agent.
A dryer may be used prior to charging a reverberatory
furnace to remove moisture from the charge materials. A
dryer is typically a large, rotating chamber heated to about
200 oC (400 oF) by a gas-fired burner. The exhaust from the
dryer is drawn directly into the reverberatory furnace.
Smelting is performed in reverberatory, blast, rotary,
or electric smelting furnaces. Reverberatory and blast
furnaces are the most common types of smelting furnaces.
Reverberatory furnaces are always operated in conjunction
with a blast furnace or an electric furnace. Blast and
rotary furnaces may be operated independently of other
furnace types. All smelting furnaces operate at a
temperature of about 980 to 1,200 oC (1,800 to 2,200 oF).
Blast furnaces are vertical shaft furnaces that use
coke as a fuel source. The combustion zone of the furnace
is at the bottom of the vertical shaft, where combustion air
is injected through tuyeres. The combustion gases then pass
through a thick column of charge material before being
vented to a control device. Exhaust temperatures are
relatively cool, typically about 420 to 480 oC (800 to
900 oF).
Rotary furnaces consist of a rotating, refractory-lined
cylinder and are fired in the same way as reverberatory
furnaces. Unlike other smelting furnaces, which are
operated on a continuous basis, rotary furnaces are operated
on a batch cycle consisting of charging, smelting, and
tapping of lead and slag.
Blast and rotary furnaces produce hard and semi-soft
lead, respectively, by adding soda ash (Na2CO3) or limestone
(CaCO3) to the charge materials as fluxing agents. These
fluxing agents promote the reaction of lead sulfate (PbSO4)
and carbon (from coke) to reduce the PbSO4 to elemental
lead. The fluxing agents, however, also promote the
reduction of oxides of alloying metals to their elemental
forms. These metals are tapped from the furnace with the
lead in the form of a hard or semi-soft lead alloy.
Reverberatory furnaces are rectangular, refractory-
lined furnaces that use natural gas- or propane-fired jets
to heat the walls and roof of the furnace and the charge
materials. Reverberatory furnaces are used to produce soft
(nearly pure) or semi-soft lead by reducing lead compounds
to metallic form, but at the same time oxidizing the
alloying elements so that they are removed in the slag.
Therefore, soda ash and limestone fluxing agents are added
to reverberatory furnaces in much smaller quantities than to
blast or rotary furnaces.
Reverberatory furnace slag has a much higher lead
content than blast or rotary furnace slag because of the
lower reducing conditions of the furnace. This slag must be
processed in a blast or electric furnace to recover the
remaining lead fraction. For this reason, reverberatory
furnaces are always operated in conjunction with a blast or
electric furnace.
There is only one electric furnace in use in the U. S.
secondary lead industry. It is collocated with a
reverberatory furnace at one of three smelters owned by the
same company. The electric furnace is only used to process
reverberatory furnace slag from the furnace with which it is
collocated and slag shipped in from the company's other two
smelters. The charge materials in the furnace are heated by
passing an electric current through them. The electric
furnace produces a hard lead similar to that from a blast
furnace.
Blast, rotary, and electric furnaces produce a final
slag that cannot be recycled and that must be disposed of as
a solid waste. This slag, however, may qualify as a
hazardous waste and must be disposed of in an approved
landfill.
The lead tapped from smelting furnaces is refined and
alloyed in open-top refining kettles that are heated from
underneath by a gas-fired burner. Impurities are removed
from the molten lead as drosses that float on the surface of
the lead. Drosses often have a high lead content and are
therefore recycled to the smelting furnace. After refining,
lead is pumped from the refining kettle into a machine for
casting into ingots. These ingots are stored at the smelter
before being shipped to a customer or transferred to a
collocated battery manufacturing facility.
Flue dust collected from baghouses at secondary lead
smelters is recycled to the smelting furnaces for recovery
of the lead content. At smelters that operate blast
furnaces, an agglomerating furnace is used to heat and melt
the flue dust so that it can be cast into molds before being
recycled to the furnace. This is done to facilitate
handling of the dust and to prevent the dust from clogging
the blast furnace charge column.
C. Emissions and Factors Affecting Emissions
Hazardous air pollutants are emitted from secondary
lead smelters as (1) process emissions contained in the
primary exhaust of smelting furnaces, (2) process fugitive
emissions associated with charging and tapping of smelting
furnaces and lead refining kettles, and (3) fugitive dust
emissions from wind or mechanically induced entrainment of
dust from stockpiles and plant yards and roadways.
1. Process Emissions
Smelting furnaces are sources of all three classes of
HAP's: metal, organic, and acid gas [chlorine (Cl2) and
hydrochloric acid (Hcl)]. The mix and relative quantities
of potential emissions are highly dependent on furnace type
and use. Metal HAP emissions from process sources are
produced through the volatilization of the metals contained
in the feed materials by the elevated smelting temperatures
or by the entrainment of metal-containing PM in the furnace
exhaust. All smelting furnace types emit substantial
quantities of metal compounds, ranging from 40 to 100 Mg/yr
(uncontrolled). About 70 percent of metal HAP emissions are
lead compounds, with lesser amounts of antimony, arsenic,
and other metal compounds. Controlled emissions, however,
are typically less than 1 Mg/yr.
Organic HAP emissions from smelting furnaces result
from incomplete combustion of organic-containing materials
(coke, plastic separators, and hard rubber battery case
material) in the furnace charge, as well as coke and other
fuels used for combustion. The emissions potential for
organic HAP's is highly variable. Blast furnaces typically
emit larger amounts of organic HAP's than other furnace
types. A typical uncontrolled blast furnace can emit over
100 Mg/yr of a mixture of about 30 organic HAP's. The most
predominant HAP's are benzene, carbon disulfide,
1-3-butadiene, methyl chloride, and styrene. Also found in
blast furnace emissions are trace amounts of dioxins/furans.
Emissions of 2,3,7,8-tetrachlorodibenzo-p-dioxin
(2,3,7,8-TCDD), which is a HAP, are about 0.07 grams per
year from a typical blast furnace. Emissions of total
dioxins/furans, expressed as 2,3,7,8-TCDD toxic equivalents
are about 0.3 grams per year.
Reverberatory and rotary furnaces have comparatively
low organic HAP emissions. Uncontrolled emissions from a
typical furnace are less than 4 Mg/yr of a mixture of about
25 or 30 organic HAP's. The most predominant are benzene,
1-3-butadiene, formaldehyde, and styrene. Reverberatory and
rotary furnaces are operated at much higher flue gas
temperatures [about 980 to 1,200 oC (1,800 to 2,200 oF)] and
turbulence and achieve more complete combustion than blast
furnaces. As a result, reverberatory and rotary furnaces
tend to have much lower organic HAP emissions. Emissions of
dioxins/furans from these furnaces are near or below
detection limits.
The one electric furnace now in operation processes
only slag (which contains little, if any, organic material)
and uses no coke or other fossil fuel. Therefore, organic
HAP emissions are presumed to be very low. This presumption
is confirmed by CO emissions of only 1.1 kilograms per hour
(kg/hr) [2.5 pounds per hour (lb/hr)] and a CO concentration
of 26 parts per million by volume (ppmv), according to the
results of a test conducted by the smelter operator (Docket
A-92-43, Item No. II-B-8).
For reverberatory/blast furnace configurations, a
substantially lower level of organic HAP emissions is
possible than for blast furnaces alone. Commingling
(blending) the blast furnace exhaust (temperature about
500 oC) and the much hotter reverberatory furnace exhaust
(about 1,000 oC) contributes significantly to the
destruction of the organic HAP compounds in the blast
furnace exhaust. Organic HAP emissions from such a
commingled configuration are also about 4 Mg/yr.
All smelting furnaces that process broken batteries are
potential sources of Hcl and Cl2 emissions. Many used lead-
acid batteries contain polyvinyl chloride (PVC) plastic
separators between the battery grids, although the use of
PVC plastic as a separator material has been discontinued by
most battery manufacturers. These separators are typically
not removed from the lead-bearing parts of the battery
during the battery breaking and separation process. When
the PVC plastic is burned in the smelting furnace, the
chlorides are released as HCl, Cl2, and chlorinated
hydrocarbons.
In blast furnaces and rotary furnaces, soda ash or
limestone are used as fluxing agents to increase the
reduction of lead compounds to elemental lead. These
fluxing agents also combine with the chlorine in the charge
materials to form sodium chloride (NaCl) and calcium
chloride (CaCl2) salts, which are removed with the slag. As
a result, these furnaces have low HCl and Cl2 emissions,
typically less than 1 Mg/yr total.
In reverberatory furnaces, however, much less fluxing
agent is added to the charge material than in blast or
rotary furnaces in order to produce a soft lead product.
Less of the chlorine is removed in the slag and, therefore,
reverberatory furnaces have higher HCl and Cl2 emissions
than blast or rotary furnaces, about 100 Mg/yr of HCl and
4 Mg/yr of Cl2.
The one electric furnace in use is not a source of HCl
or Cl2 emissions because it processes only slag from a
reverberatory furnace to which fluxing agents are added.
Any chlorine present in the slag should be in the form of
CaCl2 or NaCl and cannot be emitted as HCl or Cl2.
2. Process Fugitive Emissions
Process fugitive emissions result from furnace
charging, lead and slag tapping, lead refining and casting,
dust agglomerating, and battery breaking. Process fugitive
emissions contain metal HAP's and, in some cases, organic
HAP's. Total uncontrolled metal HAP emissions from all
process fugitive sources at a typical smelter range from 10
to 80 Mg/yr, depending on smelter capacity. Metal HAP
emissions are independent of furnace configuration.
Controlled metal HAP process fugitive emissions are
typically less than 1 Mg/yr.
Depending on charging method, hood design, and
ventilation rate, organic HAP's may be found in the process
fugitive emission stream from blast furnace charging. An
improper balance between the ventilation rate of the hood
over the furnace charging chute and the primary exhaust gas
off-take can result in process emissions being drawn into
the process fugitive control system. The escaping organic
HAP emissions may be as high as 50 Mg/yr, based on
measurements made at one facility at which this problem was
detected. Organic HAP emissions from a properly balanced
system should be less than 0.5 Mg/yr.
3. Fugitive Dust Emissions
Fugitive dust emissions result from the entrainment of
dust due to material handling, vehicle traffic, and wind
erosion from storage piles. Fugitive dust emissions contain
only metal HAP's. The quantity of fugitive dust emissions
is dependent on the size of the facility and the fugitive
dust controls and practices in place. These emissions
cannot be measured and can only be roughly estimated using
emission factors and facility-specific data. Estimates of
fugitive dust emissions from all smelters range from 1 to
19 Mg/yr.
D. Adverse Health Effects Finding for Area Sources
As stated previously, the EPA today is proposing to add
secondary lead smelters that are area sources to the list of
source categories that will be subject to emission
standards. In order to list categories of area sources, the
EPA must find a threat of adverse health or environmental
effects warranting regulation under section 112.
Section 112(a) contains no accompanying definition of
adverse health effect. The area source provisions of
section 112(k) directing regulation of area sources in urban
areas, however, are closely linked to section 112(c) and
state that health effects considered under this program
shall include, but not be limited to, carcinogenicity,
mutagenicity, teratogenicity, neurotoxicity, reproductive
dysfunction, and other acute and chronic effects
[section 112(k)(2)]. The term "adverse environmental
effect" is defined in section 112(a) as "any significant and
widespread adverse effect, which may reasonably be
anticipated, to wildlife, aquatic life, or other natural
resources, including adverse impacts on populations of
endangered or threatened species or significant degradation
of environmental quality over broad areas."
In the finding for secondary lead area sources,
quantitative assessments of risk are an important
consideration in assessing significant threats of adverse
health effects. Quantitative risk assessment, in this
context, means the estimation of a mathematical probability
of an individual or population being subject to some adverse
health effect, such as cancer. The EPA has historically
developed assessments of potential cancer risks, both to
maximally exposed individuals and populations, as part of
its regulatory actions under the previous version of
section 112. Population risks are expressed in terms of the
total number of cancer cases (i.e., cancer incidence) that
could be expected to occur in a given time within a
prescribed area, considering the exposure of the population
within the area to modeled ambient concentrations of toxic
air pollutants. In this finding, nationwide cancer
incidence is expressed in cases per year. In contrast, a
maximum individual "lifetime" risk is expressed as the risk
of contracting cancer associated with the highest
individual's exposure to the modeled, maximum, long-term
concentration of the listed HAP's for an assumed life-span
of 70 years. Typically, both these cancer risk estimates
are based on upper-bound estimates of cancer potency and
exposure. The EPA also considers, where possible, the
probability of non-cancer effects.
The finding proposed in today's notice is based only on
health effects from inhalation exposures. The EPA did not
consider other adverse environmental effects. Future
findings for other source categories may be based on
environmental effects as well as human health effects as the
appropriate information becomes available.
Section 112(c) does not offer a "bright line" test for
the EPA to use in making an area source finding. Instead,
considering the language cited above, the EPA believes it
has discretion to consider a range of health effect
endpoints and exposure criteria in making a finding of a
threat of adverse effects. In the finding, the EPA
considers factors such as the number of sources in a
category, the quantity of emissions, the toxicity of the
HAP's, the potential for individual and population exposures
and risks, the geographical distribution of the sources, and
the reasonableness of control measures. Thus, both
qualitative and quantitative factors are considered in
making a finding.
The EPA recognizes uncertainties in current estimates
of risk based on modeled concentrations and the use of
several upper-bound risk assumptions. The EPA acknowledges
that current cancer risk estimates do not reflect the true
risk, but often represent a conservative risk level that may
be an upper bound that is unlikely to be exceeded. The EPA
intends to improve its risk estimation procedures in
accordance with internal guidance and through the risk
assessment studies required under sections 112(f), 112(o),
and 303 of title III of the Act.
Today's finding is based on six smelters that the EPA
believes fit the definition of an area source plus one other
that is borderline between major and area. The smelters are
located in six states and approximately 17.6 million people
reside within 50 kilometers (about 30 miles) of the seven
facilities. These people are considered by the EPA to be
exposed to HAP emissions from the smelters.
Secondary lead smelters emit a large number of
pollutants. Of these, EPA has performed scientific
assessments that provide estimates of the associated health
risks of fourteen. Ten of the compounds have unit risk
estimates (URE or cancer potency estimates), three
(ethylbenzene, n-hexane, and toluene) have inhalation
reference concentrations (RfC), and one has a NAAQS (lead).
In this finding, elemental lead is being used as a surrogate
for all lead compounds. The reason for this is discussed
below.
The health effects caused by increased blood lead
levels are the same, regardless of the lead compounds
causing the exposure. However, there are considerable
differences in the bioavailability between lead compounds.
Unfortunately, there is little available literature on this
subject (Docket No. A-92-43, Item Nos. II-I-18 and II-I-29).
The literature that is available, however, does indicate
that lead oxide, which accounts for a substantial portion of
the lead compounds emitted from secondary lead smelters, is
bioavailable. This indicates that using lead as a surrogate
for estimating health effects from the lead compounds from
this source category should be appropriate.
Lead is also a B2 carcinogen. However, a cancer risk
factor has not been developed for lead, so cancer rates
associated with its exposure can not be estimated.
Four of the ten potential carcinogens with quantitative
assessments are known human carcinogens and have URE's based
on epidemiological data. These are arsenic, benzene, and
some chromium and nickel compounds. The other potentially
carcinogenic compounds have URE's based on animal studies
and are classified as either probable or possible human
carcinogens. These include acetaldehyde, 1,3-butadiene,
cadmium, formaldehyde, naphthalene, and 2,3,7,8-TCDD.
A URE is HAP-specific and equals the risk of cancer per
unit of lifetime pollutant exposure. It represents the
probability of developing cancer in a hypothetical
individual, continuously exposed throughout his/her life to
1 microgram per cubic meter (ęg/m3) of the potential
carcinogen in the air. An RfC is also HAP-specific and is
an estimate of the daily exposure to the human population,
including sensitive subpopulations, that is likely to be
without deleterious effects during a lifetime. The
uncertainty of the estimate can span an order of magnitude
or more.
The estimated annual cancer incidence for the seven
sources modeled is low, approximately 0.1 incidence of
cancer per year. However, the EPA estimates that the upper-
bound maximum individual lifetime cancer risk associated
with any one of the smelters ranges from 4 in 10,000 to 1 in
1,000. Furthermore, about 500 persons living in proximity
to these smelters are estimated to be subject to lifetime
individual risks possibly in excess of 1 in 10,000; over
40,000 are possibly subject to lifetime individual risks
above 1 in 100,000; and about 560,000 are possibly subject
to individual lifetime risks above 1 in 1 million. The
risks calculated are due to a mixture of pollutants, with
arsenic and 1,3-butadiene posing the highest risks.
In addition to cancer risk, the EPA has examined the
public health risks associated with elevated blood lead
levels. Little controversy exists that high blood lead
levels are associated with adverse health effects, but there
is also substantial concern regarding health effects
associated with lower blood lead levels as well:
(1) Alterations in the heme synthetic pathway may affect
multiple organ system and physiological functions,
(2) children's IQ's may be lowered, (3) impaired auditory
function in children may affect language acquisition and
learning, and (4) animal experiments and human data have
shown that lead accumulates and is retained in the brain and
other soft tissues and can be remobilized from bone stores,
resulting in a continuing risk of lead toxicity even if
exposure to lead is stopped.
Children may be particularly at risk as atmospheric
lead deposits on soils, crops, and street and playground
surfaces. Soil lead, which serves as a continuous source of
outdoor and indoor (household) dusts as well as a direct
exposure route for young children, is relatively insoluble
and immobile and can continue to accumulate indefinitely.
Approximately 250 people are expected to be exposed to
lead concentrations that are above the current lead NAAQS of
1.5 ęg/m3, calendar quarter average. Because the level of
the lead NAAQS has not been revised since it was established
in 1978, the EPA also determined potential exposure levels
below the NAAQS. At 1.0 ęg/m3, the number of people
potentially exposed is about 300, rising to 1500 at
0.5 ęg/m3.
As stated above, the EPA did not evaluate environmental
risks or health risks associated with non-inhalation
exposures because of a lack of site-specific data and, in
some cases, effects data. There is some potential for
increased risks due to exposure from metal compounds and
dioxins through routes of exposure such as ingestion of
contaminated soil, ingestion of food and water, and dermal
contact. In addition, the health effects from non-
inhalation routes of exposure are not well known for many
air pollutants, and data on environmental effects are even
more scarce.
The EPA is proposing to regulate secondary lead
smelters as area sources, subject to consideration of public
comment, because emissions associated with these sources may
present a threat of adverse health effects. The upper-
bound, maximum lifetime individual risks resulting from
exposure to arsenic and 1,3-butadiene are of particular
concern. The EPA, therefore, requests comments on the
proposal to regulate these sources as area sources and the
appropriate criteria to be used in making these decisions.
In particular, the EPA requests comment on whether the
number of sources, the quantity of emissions, the toxicity
of the HAP's, the potential for individual and population
exposures and risks, the geographical distribution of the
sources, and the reasonableness of control measures justify
a decision to regulate area sources within this category.
The EPA notes that the exposures, the cancer incidence,
and the maximum individual risk associated with these area
sources are all below levels that have prompted the
Administrator to designate other categories of area sources
for regulation. However, the relatively low costs
associated with regulation and the small number of area
sources in this category appear to warrant such regulation.
The EPA requests comment on whether regulation of these
areas sources is warranted.
III. NESHAP Decision Process
A. Source of Authority for NESHAP Development
Section 112 specifically directs the EPA to develop a
list of all categories of all major and such area sources as
appropriate emitting one or more of the 189 HAP's listed in
section 112(b) [section 112(c)]. Section 112 of the Act
replaces the previous system of pollutant-by-pollutant
health-based regulation that proved ineffective at
controlling the high volumes and concentrations of HAP's in
air emissions. The provision directs that this deficiency
be redressed by imposing technology-based controls on
sources emitting HAP's, and that these technology-based
standards may later be reduced further to address residual
risk that may remain even after imposition of technology-
based controls. A major source is any source that emits or
has the potential to emit 10 tons of any one HAP or 25 tons
of any combination of HAP's. The EPA published an initial
list of source categories on July 16, 1992 (57 FR 31,586),
and may amend the list at any time. (The EPA is proposing
to add secondary lead smelters to the list of area sources
as part of this rulemaking, for example.)
B. Criteria for Development of NESHAP
The NESHAP are to be developed to control HAP emissions
from both new and existing sources according to the
statutory directives set out in section 112, as amended.
The statute requires the standard to reflect the maximum
degree of reduction of HAP emissions that is achievable
taking into consideration the cost of achieving the emission
reduction, any nonair quality health and environmental
impacts, and energy requirements.
Emission reductions may be accomplished through
application of measures, processes, methods, systems, or
techniques, including, but not limited to: (1) Reducing the
volume of, or eliminating emissions of, such pollutants
through process changes, substitution of materials, or other
modifications, (2) enclosing systems or processes to
eliminate emissions, (3) collecting, capturing, or treating
such pollutants when released from a process, stack,
storage, or fugitive emissions point, (4) design, equipment,
work practice, or operational standards (including
requirements for operator training or certification) as
provided in subsection (h), or (5) a combination of the
above [section 112(d)(2)].
To develop a NESHAP, the EPA collects information about
the industry, including information on emission source
characteristics, control technologies, data from HAP
emissions tests at well-controlled facilities, and
information on the costs and other energy and environmental
impacts of emission control techniques. The EPA uses this
information to analyze possible regulatory approaches.
Although NESHAP are normally structured in terms of
numerical emission limits, alternative approaches are
sometimes necessary. In some cases, for example, physically
measuring emissions from a source may be impossible, or at
least impractical, because of technological and economic
limitations. Section 112(h) authorizes the Administrator to
promulgate a design, equipment, work practice, or
operational standard, or a combination thereof, in those
cases where it is not feasible to prescribe or enforce an
emissions standard.
If sources in the source category are major sources,
then a MACT standard is required for those major sources.
The regulation of the area sources in a source category is
discretionary. If there is a finding of a threat of adverse
effects on human health or the environment, then the source
category can be added to the list of area sources to be
regulated. Based on the area source finding described in
section II.D of this preamble, the EPA proposes to regulate
secondary lead smelters as area sources.
C. Determining the MACT Floor
After the EPA has identified the specific source
categories or subcategories of major sources to regulate
under section 112, it must set MACT standards for each
category or subcategory. Section 112 limits the EPA's
discretion by establishing a minimum baseline or "floor" for
standards. For new sources, the standards for a source
category or subcategory cannot be less stringent than the
emission control that is achieved in practice by the best-
controlled similar source, as determined by the
Administrator [section 112(d)(3)].
The standards for existing sources can be less
stringent than standards for new sources, but they cannot be
less stringent than the average emission limitation achieved
by the best-performing 12 percent of existing sources
(excluding certain sources) for categories and subcategories
with 30 or more sources, or the best-performing 5 sources
for categories or subcategories with fewer than 30 sources
[section 112(d)(3)]. There are fewer than 30 secondary lead
smelters, so the standards for existing sources will be
based on the best-performing five sources.
In developing the proposal, the EPA has interpreted the
term "average" to be equivalent to "median" and the MACT
floor has been selected to represent the median of the five
best-controlled sources. The median of the five best-
controlled sources was selected as the MACT floor on the
basis of control technology because insufficient emissions
data were available for determining an average emission
limitation. An emission source testing program was then
conducted in order to determine an appropriate limitation
based on the MACT floor technology.
After the floor has been determined for a new or
existing source in a source category or subcategory, the
Administrator must set MACT standards that are no less
stringent than the floor. Such standards must then be met
by all sources within the category or subcategory.
Section 112(d)(2) specifies that the EPA shall
establish standards that require
the maximum degree of reduction in emissions of
hazardous air pollutants. . . that the
Administrator, taking into consideration the cost
of achieving such emission reduction, and any non-
air quality health and environmental impacts and
energy requirements, determines is achievable. . .
In establishing standards, the Administrator may
distinguish among classes, types, and sizes of sources
within a category or subcategory [section 112(d)(1)]. For
example, the Administrator could establish two classes of
sources within a category or subcategory based on size and
establish a different emissions standard for each class,
provided both standards are at least as stringent as the
MACT floor for that class of sources.
In addition, the Act provides the Administrator further
flexibility to regulate area sources. Area sources can be
regulated by MACT. However, section 112(d)(5) allows the
Administrator to promulgate standards for area sources that
provide for the use of "generally available control
technologies (GACT) or management practices." Area source
standards promulgated under this authority (GACT standards)
would not be subject to the MACT floors described above.
Moreover, for source categories subject to standards
promulgated under section 112(d)(5), the EPA is not required
to conduct a residual risk analysis under section 112(f).
At the end of the data gathering and analysis, the EPA
must decide whether it is more appropriate to follow the
MACT or the GACT approach for regulating an area source
category. (As stated previously, MACT is required for major
sources.) If all or some portion of the sources emit less
than 9.1 Mg/yr (10 tpy) of any one HAP or less than
22.7 Mg/yr (25 tpy) of total HAP's, then it may be
appropriate to define subcategories within the source
category and apply a combination MACT/GACT approach: MACT
for major sources and GACT for area sources in a source
category. In the case of this proposed rulemaking for
secondary lead smelters, the EPA has decided to regulate
both major and area sources by applying MACT. The EPA knows
of no technological or economic reasons why secondary lead
smelters that are area sources cannot achieve the same level
of control as those that are major sources.
The next step in establishing MACT standards is the
investigation of regulatory alternatives. With MACT
standards, only alternatives at least as stringent as the
floor may be selected. Information about the industry is
analyzed to develop model plant populations for projecting
national impacts, including HAP emission reduction levels,
costs, energy, and secondary impacts. Several regulatory
alternative levels (which may be different levels of
emissions control or different levels of applicability or
both) are then evaluated to select the regulatory
alternative that best reflects the appropriate MACT level.
The selected alternative may be more stringent than the
MACT floor, but the control level selected must be
technically achievable. In selecting a regulatory
alternative that represents MACT, the EPA considers the
achievable emission reductions of HAP's (and possibly other
pollutants that are co-controlled), cost and economic
impacts, energy impacts, and other environmental impacts.
The objective is to achieve the maximum degree of emissions
reduction without unreasonable economic or other impacts
[section 112(d)(2)]. The regulatory alternatives selected
for new and existing sources may be different because of
different MACT floors, and separate regulatory decisions may
be made for new and existing sources.
The selected regulatory alternative is then translated
into a proposed regulation. The regulation implementing the
MACT decision typically includes sections on applicability,
standards, test methods and compliance demonstration,
monitoring, reporting, and recordkeeping. The preamble to
the proposed regulation provides an explanation of the
rationale for the decision. The public is invited to
comment on the proposed regulation during the public comment
period. Based on an evaluation of these comments, the EPA
reaches a final decision and promulgates the standard.
IV. Summary of the Proposed Standards
A. Sources to be Regulated
Standards are being proposed to limit HAP emissions
from: (1) Process sources, (2) process fugitive sources,
and (3) fugitive dust sources at secondary lead smelters.
Process source emissions are discharged as the main
exhaust of a smelting furnace through a chimney, flue, or
ductwork. For the purpose of establishing numerical limits
for process source emissions, smelting furnaces have been
grouped into the following source types: (1) Collocated
reverberatory and blast furnaces (reverberatory/blast),
(2) reverberatory or rotary furnaces not collocated with a
blast furnace, (3) blast furnaces not collocated with a
reverberatory furnace, and (4) electric furnaces.
Process fugitive emission sources that would be
regulated are smelting furnace charging, smelting furnace
lead and slag tapping, flue dust agglomerating furnace
operation, and refining kettles.
Fugitive dust emission sources that would be regulated
are plant yards and roadways subject to wind and vehicle
traffic, materials handling and storage areas, battery
breaking areas, and smelting and refining areas.
B. Proposed Emission Limits for Process Sources
Emission limits are being proposed for lead compounds,
total hydrocarbons (THC), and HCl and Cl2 emissions and
opacity from reverberatory, blast, reverberatory/blast
furnace combination, rotary, and electric furnaces. Limits
are being proposed for lead compounds and THC as surrogates
for metal HAP's and organic HAP's, respectively.
Lead compound emissions from all smelting furnace
configurations (both new and existing) would be limited to a
concentration of 2.0 mg/dscm (0.00087 gr/dscf). Total
hydrocarbon emissions from both new and existing
reverberatory/blast furnace configurations would be limited
to 20 ppmv [expressed as propane at 4 percent carbon dioxide
(CO2) to correct for dilution]. Total hydrocarbon emissions
from existing blast furnaces would be limited to 360 ppmv
(as propane) at 4 percent CO2. Total hydrocarbon emissions
from new blast furnaces would be limited to 70 ppmv (as
propane) at 4 percent CO2. There is no proposed standard
for THC emissions from reverberatory, rotary, or electric
furnaces.
Total HCl and Cl2 emissions from both new and existing
reverberatory/blast, blast, reverberatory, and rotary
smelting furnace configurations would be limited to
15 mg/dscm (0.0065 gr/dscf) at 4 percent CO2 to correct for
dilution. There is no proposed standard for HCl or Cl2
emissions from new and existing electric smelting furnaces.
The proposed numerical emission limits for process
sources are summarized in table 1. C. Proposed Standards for Process Fugitive Sources
The proposed standards for process fugitive sources are
in the form of equipment and operating standards. The
standards apply to both new and existing sources. All
secondary lead smelters would be required to control process
fugitive emission sources with capture hoods equivalent in
design and performance to those specified in the
Occupational Safety and Health Administration's "Cooperative
Assessment Program Manual for the Secondary Lead Industry"
(Docket No. A-92-43, Item No. II-I-16).
The standards would require the following process
fugitive sources to be partially enclosed with a hood and
ventilated: smelting furnace and dryer charging hoppers and
chutes, lead and slag tapping operations, refining kettles,
dryer transition pieces, and flue dust agglomerating
furnaces. All hoods, except those on refining kettles,
would be required to be designed and operated to achieve a
face velocity of at least 110 meters per minute (m/min)
[350 feet per minute (fpm)] at all openings. Refining
kettle hoods would be required to be designed and operated
to achieve a face velocity of at least 75 m/min (250 fpm)
and a volumetric flow rate of at least 60 actual cubic
meters per minute per square meter [200 actual cubic feet
per minute per square foot (acfm/ft2)] of kettle surface
area. All hoods would be required to be ventilated to a
control device with an outlet lead compound concentration
not to exceed 2.0 mg/dscm (0.00087 gr/dscf).
D. Proposed Standards for Fugitive Dust Sources
The proposed standards for fugitive dust sources are in
the form of work practice and operating standards. Again,
the standards apply to both new and existing fugitive dust
sources. Each secondary lead smelter would be required to
develop a Standard Operating Procedures (SOP) manual that
details procedures to limit fugitive dust emissions. Each
smelter's SOP manual would be reviewed and subject to
approval by the Administrator.
The SOP manual would describe how each smelter would
implement the types of work practices and operating
standards which EPA has determined represent MACT controls
for fugitive dust emissions. These controls are specified
in the proposed regulation and include cleaning of paved
areas through vacuuming or power-washing, use of water or
chemical dust suppression in materials storage and handling
areas, use of partial or total enclosures to prevent wind
erosion of storage piles, and use of measures to prevent
crossdrafts from upsetting process fugitive control hoods.
The SOP manual would also indicate the frequencies with
which pavement cleaning and dust suppression are to be
performed, and which areas are partially and totally
enclosed and which are paved. The MACT controls specified
in the proposed regulation would serve as the criteria by
which the Administrator would decide whether or not to
approve a smelter's SOP.
E. Compliance Dates
Compliance with the standards would be achieved within
24 months of promulgation for existing secondary lead
smelters, and upon startup for new and reconstructed
smelters.
F. Compliance Test Methods
Testing of lead compound emissions from process and
process fugitive emission control devices would be conducted
according to EPA reference method 12 (40 CFR part 60,
appendix A). Testing of THC emissions from process sources
for reverberatory/blast and blast furnace configurations
would be conducted according to EPA reference method 25A
(40 CFR part 60, appendix A), and the results reported as a
concentration in ppmv, as propane, corrected to 4 percent
CO2 for dilution. Testing of HCl and Cl2 emissions would be
conducted according to EPA reference method 26A (59 FR
19306-19323), and the results reported as HCl equivalents,
in mg/dscm, corrected to 4 percent CO2 for dilution. An
average of three runs would be used to determine compliance
for lead compounds, THC, and total HCl and Cl2.
Sampling locations for all compliance tests would be
determined by EPA reference method 1. Stack gas velocity
and volumetric flow rate would be determined by EPA
reference method 2. Gas analysis would be conducted
according to EPA reference method 3 for CO2, oxygen, excess
air, and molecular weight on a dry basis. The Single Point
Integrated Sampling and Analytical Procedure of EPA
reference method 3B would be used to measure the CO2 content
of the stack gas during the THC and HCl/Cl2 compliance tests
for correcting to 4 percent CO2.
G. Enhanced Monitoring Requirements
Continuous opacity monitors (COM's) would be used on
all process control stacks to monitor compliance with the
lead compound emission limit. Opacity (based on a 6-minute
average) greater than the maximum opacity recorded during
the initial lead compliance test (plus 2 percent opacity to
allow for normal instrument drift) would be a violation of
the standard. Process fugitive and building ventilation
baghouse performance would be monitored through inspections
of the baghouses. Pressure drop and water flow rate would
be monitored for PM scrubbers used to control process
fugitive sources.
Compliance with the THC standard would require either
continuous monitoring of incineration or afterburner
temperature or continuous THC monitoring for
reverberatory/blast and blast furnace configurations. The
temperature would be maintained above a minimum established
during the initial THC compliance test. Operating at a
lower temperature (based on a 3-hour average) would
constitute a violation of the emissions standard.
Alternatively, a facility could monitor THC concentration
directly with a THC continuous emissions monitor (CEM) if
desired.
Compliance with the HCl/Cl2 standard would require
monitoring of either: (1) The addition of soda ash and
limestone to furnace charge materials, (2) scrubber
parameters (media pH and injection rate), (3) sulfur dioxide
(SO2) concentration, or (4) HCl concentration. The quantity
of soda ash and limestone, the scrubber parameters, or the
SO2 concentration would be maintained within allowable
ranges established during the initial HCl/Cl2 compliance
test. Failure to maintain these variables within the
allowable ranges would constitute a violation of the
standard. An operator wishing to establish new allowable
ranges would have to demonstrate that compliance with the
HCl/Cl2 standard is still achieved. Alternatively, the
operator could monitor HCl concentration using an HCl CEM.
All COM's would be required to comply with Performance
Specification 1 in appendix B of 40 CFR part 60. If an
owner or operator chose to monitor SO2, the SO2 CEM would be
required to comply with Performance Specification 2 in
appendix B of 40 CFR part 60. All CEM's would be required
to comply with the Quality Assurance Procedures found in
appendix F of 40 CFR part 60.
H. Notification Requirements
The owner or operator of a secondary lead smelter would
be required to submit the notifications described in the
General Provisions to part 63, (40 CFR part 63, subpart A).
These would include the initial notification, notifications
of performance tests and continuous monitoring system
(including COM and CEM) performance evaluations, and the
notification of compliance status. In addition, each owner
or operator would be required to submit the SOP manual and a
notification to the Administrator requesting review and
approval of the smelter's fugitive dust control SOP manual.
I. Recordkeeping and Reporting Requirements
The owner or operator of a secondary lead smelter would
be required to retain for 5 years records of: (1) The
results of initial and subsequent compliance tests, (2) the
recorded values for the parameters that must be monitored to
demonstrate continuous compliance, and (3) records
demonstrating implementation of the fugitive dust controls
contained in the smelter's SOP manual.
The owner or operator would be required to submit the
quarterly excess emissions and continuous monitoring
performance reports, including the results of annual and
other compliance tests, as prescribed in the General
Provisions.
V. Summary of Environmental, Energy, and Economic
Impacts
A. Facilities Affected by This NESHAP
The proposed standards would apply to all secondary
lead smelters in the United States, regardless of whether
they are classified as a major source or an area source
under section 112(c). The EPA estimates that 18 smelters
would have to upgrade controls to reduce emissions. All
23 existing smelters would be required to perform monitoring
and meet the requirements for recordkeeping and reporting.
It is not anticipated that any new smelters will be built
over the next 5 years because of the depressed price of lead
and the excess capacity in the industry.
B. Air Quality Impacts
Under the proposed standards, organic HAP emissions
would be reduced by approximately 1,200 Mg/yr (1,300 tpy).
This represents an approximately 70-percent reduction from
estimated baseline emissions. Metal HAP emissions would be
reduced by 53 Mg/yr (58 tpy) through the reduction of
process fugitive emissions [29 Mg/yr (32 tpy)] and fugitive
dust emissions [24 Mg/yr (26 tpy)]. This represents a
20-percent reduction from baseline metal HAP emissions.
There would be no reductions in metal HAP emissions from
process sources. Hydrochloric acid and Cl2 emissions would
be reduced 720 Mg/yr (790 tpy). This represents a
98-percent reduction from baseline emissions.
In addition to HAP reductions, criteria pollutant
emissions would also be reduced. Emissions of SO2 would be
reduced by 7,400 Mg/yr (8,100 tpy) if wet scrubbers were
installed to control HCl/Cl2 emissions. Emissions of CO
would be reduced by approximately 83,000 Mg/yr (91,000 tpy)
and THC emissions (including 1,200 Mg/yr of organic HAP's)
would be reduced by approximately 6,400 Mg/yr (7,000 tpy).
Controlling metal HAP emissions would also reduce PM
emissions (including 53 Mg/yr of metal HAP's) by 140 Mg/yr
(150 tpy).
C. Water Quality Impacts
Direct water quality impacts from the proposed
standards will vary depending on which control option
smelters choose in order to comply with the proposed HCl/Cl2
emission limits. There would be no wastewater impact if all
smelters chose to eliminate HCl/Cl2 emissions through the
addition of fluxing agents to the furnace feed material and
the removal of chlorides through slagging, which is the
least-cost option.
If wet scrubbers are installed to control HCl/Cl2
emissions, about 27 million gallons of wastewater from
scrubber blowdown would be generated. This wastewater would
require neutralization and settling before being discharged
to a publicly owned treatment works. Evaporation of water
from these scrubbers would be about 430 million gallons per
year. The evaporated water would require no treatment.
Because EPA does not believe smelters would adopt wet
scrubbers as a means of compliance, it is not soliciting
comment as to whether the existing effluent limitation
guidelines for the secondary lead industry should be amended
to account for this source of wastewater.
Use of water for wet suppression and pavement cleaning
to control fugitive dust emissions could increase the amount
of water runoff that must be treated on site. This
incremental increase in runoff would represent less than
1 percent of the volume of water currently treated at
secondary lead smelters.
Several of the facilities which would be affected by
this rule are located in States adjacent to the Great Lakes.
Because these facilities would reduce their emissions of
metals and organic HAP's, the indirect water quality impacts
of this rule are expected to be positive, albeit difficult
to quantify.
D. Solid Waste Impacts
The addition of fluxing agents to smelting furnaces to
eliminate HCl/Cl2 emissions through slagging would result in
a slight increase in the amount of slag that must be
disposed of as solid waste. This increase would represent
only about 5 percent of the slag currently generated by each
of the six smelters that would be impacted.
If a smelter chose to install a scrubber to control HCl
and Cl2, a solid waste stream that would require disposal
could be generated if the smelter also elected to control
SO2 emissions. Scrubbers installed to control only HCl and
Cl2 do not produce solid waste. If two smelters that do not
currently perform paste desulfurization installed scrubbers
to control SO2 emissions in addition to HCl/Cl2 emissions,
these scrubbers would generate as much as 21,000 Mg/yr of
solid waste as scrubber sludge.
Because secondary lead smelters typically process
hazardous waste that exhibits the toxicity characteristics
for lead (40 CFR 261.24), all of the residue generated from
these facilities would have to satisfy the standards for
treatment prescribed in 40 CFR part 268 for D008 (lead-
bearing hazardous waste) before any residue can be land-
disposed. (Chemical Waste Management v. EPA, 976 F. 2d 2
(D.C. Cir. 1992).
Flue dust and sludge generated at secondary lead
smelters are listed as hazardous waste KO69 under 40 CFR
261.32, Hazardous Wastes from Specific Sources. Flue dust
collected by baghouses is recycled on site to the smelting
furnace at all smelters and is not disposed of as a solid
waste. Furthermore, the EPA has issued a limited
administrative stay so that the KO69 listing does not apply
to sludges generated from acid gas scrubber systems located
at secondary lead smelters (56 FR 19951, May 1, 1991).
E. Energy Impacts
No significant increases in electricity consumption are
expected as a result of the proposed standards. Natural gas
consumption is expected to increase at six of the smelters
with blast furnace configurations as a result of installing
afterburners or increasing afterburner temperatures. The
total increase in natural gas consumption at these smelters
is expected to be about 3.7 million cubic meters
(130 million cubic feet) per year.
F. Cost Impacts
The estimated nationwide capital and annualized costs
of the proposed standards would be $2,700,000 and
$2,600,000, respectively. These costs were estimated for
all 23 smelters, including those that are currently shut
down, and include costs for monitoring, recordkeeping, and
reporting.
The estimated capital costs of reducing organic HAP
emissions under the proposed standards would be $1,100,000.
Estimated annualized costs would be $620,000. Ten smelters
would be impacted. For the blast-furnace-only
configuration, costs incurred would be for the installation
and operation of new afterburners at four smelters and
increased natural gas consumption at two smelters. For the
collocated reverberatory/blast furnace configuration, costs
incurred would be for the retrofit of additional ductwork to
achieve gas stream blending at four smelters.
The estimated capital and annualized costs of reducing
metal HAP emissions would be $240,000 and $110,000,
respectively. These costs would be distributed over an
estimated 14 smelters. The capital costs would be for
1 smelter to upgrade its process fugitive emission controls,
and for that smelter and 13 others to upgrade their fugitive
dust emission controls. Upgrades would be in the form of
improved housekeeping, including the purchase of vacuum
sweepers by four smelters. Because all smelters currently
operate at the level of the proposed standard for metal
HAP's, no anticipated reductions or costs are associated
with the control of metal HAP's from process sources.
No capital costs to reduce HCl/Cl2 emissions would be
incurred under the proposed standards if all smelters chose
to control HCl/Cl2 emissions through fluxing. The estimated
annualized cost would be $160,000, distributed over six
smelters, for the purchase of additional fluxing agents. If
a smelter chose to install a scrubber to control HCl/Cl2
emissions, the approximate capital cost would be $1,700,000
and the annualized cost would be $850,000 for a
reverberatory furnace with a production capacity of
50,000 Mg/yr.
Enhanced monitoring and recordkeeping and reporting
costs would be incurred by all 23 smelters. These costs are
estimated to be $73,000 per smelter per year and the total
national cost is estimated to be $1,700,000 per year. The
only capital costs would be for COM's, for which the total
national cost is estimated to be $1,400,000. The
recordkeeping and monitoring cost estimate includes the
costs for the emission tests needed to demonstrate
compliance. Only the tests for lead emissions from process
fugitive sources and building ventilation systems are annual
tests, so testing costs would be lower after the initial
compliance demonstration.
G. Economic Impacts
The Economic Impact Analysis evaluated: (1) The
ability of facilities to absorb annual control costs and
obtain financing for capital control costs, and (2) the
market response to the regulation - specifically, impacts on
industry-wide output, employment, and revenue. The analysis
was performed on all 23 facilities in the industry,
including facilities that have shut down operations
indefinitely but have not closed permanently.
Because lead is an internationally traded commodity
whose price is determined by international market factors,
secondary lead producers have little influence on price.
Therefore, the economic analysis assumed that no price
increase would occur and control costs would have to be
absorbed by affected facilities. Based on discussions with
industry experts, EPA formulated guidelines for estimating
when a facility would be significantly impacted. A facility
would be significantly impacted if either: (1) Total
annualized control costs result in more than a 1-percent
increase over baseline cost of production, or (2) capital
control costs exceed 5-percent of baseline total assets
(company-wide) and post-regulation total liabilities exceed
two-thirds of baseline total assets if the capital control
costs are financed with debt.
The analysis indicates that up to 11 facilities would
be significantly impacted, depending on the level of the
standards and the amount of continuous monitoring required.
Almost all of the significantly impacted facilities are
owned by small businesses because of economies of scale and
limited access to capital resources.
Implementation of emission controls equal to the MACT
floor, the basis for the proposed rule, results in
significant impacts to two facilities that are currently in
operation. Three other facilities that are currently shut
down would also be impacted significantly. If control
levels are imposed at levels above the MACT floor,
seven facilities are significantly impacted. Of the seven
facilities, four sources are currently in operation and
three are shut down. When continuous opacity monitoring is
required in addition to the MACT floor, one additional
source that is currently shut down is significantly
impacted.
If the MACT floor is considered with continuous opacity
and THC monitoring, nine facilities are significantly
impacted. Of the nine facilities, three sources are
currently in operation and six are shut down. If continuous
monitoring for HCl is added, 11 facilities would be
significantly impacted. Of the 11 facilities, four sources
are currently in operation and seven are shut down.
Under any of the regulatory alternatives considered,
industry employment and output is reduced by less than
1-percent. At current market conditions (December 1993), no
closures are expected as a consequence of the regulation.
If the price of lead decreases to levels observed over the
past year, the possibility of closure increases for two
currently operating major sources. Under any of the
regulatory alternatives, all smelters currently shut down
have additional incentive to not reopen.
VI. Rationale for Selecting the Proposed Standards
This section describes the rationale for the decisions
made by the Administrator in selecting the proposed
standards.
A. Selection of Pollutants and Source Category
Secondary lead smelters emit several of the 189 HAP's
listed in section 112(b) of the Act. Organic HAP's emitted
by secondary lead smelters include carbon disulfide,
1,3-butadiene, methyl chloride, benzene, styrene, toluene,
formaldehyde, and naphthalene. Metal HAP's emitted include
primarily compounds of lead, antimony, and arsenic, with
lesser quantities of compounds of chromium, nickel,
manganese, mercury, and cadmium. In addition, secondary
lead smelters emit the HAP's HCl and Cl2. Criteria
pollutants emitted include lead, PM, SO2, CO, and
hydrocarbons.
Approximately two-thirds of the secondary lead smelters
in the United States are major sources of HAP's, based on
potential-to-emit estimates that take into account air
pollution control measures currently in place at each
smelter. Furthermore, as described in section II.D of this
preamble, the Administrator has initially determined that
secondary lead smelters that are area sources of HAP's
present a threat of adverse effects to human health
sufficient to support adding secondary lead smelters to the
list of area source categories subject to regulation under
section 112(c)(3) of the Act. Consequently, the standards
being proposed would apply to all new and existing secondary
lead smelters regardless of source (major or area)
designation.
The emission, equipment, and work practice standards
being proposed today would substantially limit emissions of
metal HAP's, organic HAP's, HCl, and Cl2 from secondary lead
smelters. The standards being proposed to address metal and
organic HAP emissions establish limits for surrogates rather
than for individual compounds.
Establishing emission limits for each of the numerous
metal and organic HAP compounds emitted from secondary lead
smelters is considered impractical because measuring each
compound would be too costly and would pose unreasonable
compliance and monitoring costs and would achieve little, if
any, emission reduction above the surrogate pollutant
approach. On the other hand, strong correlations exist
between emissions of the selected surrogate pollutants and
emissions of the pollutant classes they represent. In
addition, the technologies identified for the control of
HAP's have equivalent performance on the selected
surrogates. Therefore, emissions standards requiring good
control of the selected surrogates will also achieve good
control of HAP's.
Candidate surrogates for the mix of metal HAP's
present, including lead compounds, are PM and lead, both of
which are criteria pollutants. The selected surrogate is
lead. Compounds of lead are the most prevalent metal HAP
contained in secondary lead smelter emissions. In addition,
lead is concentrated, along with metal HAP's, in the smaller
size fractions of PM, which are the most difficult to
control. Therefore, controlling lead will also control
metal HAP's. Available data on the performance of baghouses
used to control particulate emissions at secondary lead
smelters indicate a much stronger correlation of metal HAP's
with lead emissions than with total PM (Docket No. A-92-43,
Item Nos. II-A-1, II-A-2, II-A-3, II-I-1, and II-I-9).
Therefore, lead is a better surrogate than PM. Lastly,
there is a validated test method (EPA reference method 12)
for the determination of inorganic lead emissions from
stationary sources.
The surrogate pollutant chosen for organic HAP's is
THC. There are much data to demonstrate that the
destruction of THC through incineration is strongly
correlated with the destruction of organic HAP compounds
(Docket No. A-92-43, Item No. II-I-27, 56 FR 7155-56
[February 21, 1991]). In addition, THC is easily measured
and can be monitored. Carbon monoxide, another indicator of
destruction efficiency for organic compounds, was considered
but dismissed. It does not correlate as well as THC with
destruction of organic HAP compounds. No surrogates are
needed for HCl and Cl2 because they can be measured
directly.
The proposed regulation does not establish explicit
limits for dioxin/furan emissions from secondary lead
smelters for several reasons. First, secondary lead
smelters emit very small quantities of dioxin. Cumulative
annual emissions for the entire industry are estimated to be
only 1.6 grams of dioxin/furan, expressed in toxic
equivalents (Docket No. A-92-43, Item No. II-B-35).
Emission rates from the other two smelters (a
reverberatory/blast smelter and a rotary smelter) were an
order of magnitude lower (Docket No. A-92-43, Item
Nos. II-A-1 and II-A-3). Second, the Agency believes that
the emission controls necessary to achieve the emission
limitations associated with this proposed standard would
reduce dioxin/furan emissions, particularly from blast
furnaces. Finally, any risks associated with dioxin will be
addressed in the residual risk evaluation required within
eight years of promulgation of the standard pursuant to
section 112(f) of the Act.
The Agency currently is in the process of revising its
assessment of the risks associated with the exposure to
dioxin. The EPA requests comment whether additional action
is necessary to reduce dioxin emissions from secondary lead
smelters.
Facilities that solely melt scrap or refined lead for
use in specific molded or fabricated products would not be
covered by the proposed rule because they do not operate
blast, reverberatory, rotary, or electric smelting furnaces
and, therefore, have substantially different and lower
emissions potential than do secondary lead smelters.
Lead-acid battery manufacturing operations that may be
collocated with a secondary lead smelter and primary lead
smelters that produce refined lead from ore concentrate
would not be covered by the proposed rule because they are
listed as separate categories in the list of major sources
to be regulated by MACT standards (57 FR 31576) in separate
rulemakings.
B. Selection of Affected Sources
The proposed standards apply to three types of emission
sources at secondary lead smelters: (1) Process sources,
(2) process fugitive sources, and (3) fugitive dust sources.
1. Process Sources
Affected process sources include all furnaces (blast,
reverberatory, rotary, or electric) used for smelting lead-
bearing scrap or slag. All smelting furnaces are equipped
with chimneys, flues, or ductwork that convey exhaust gases
from the furnace. These exhaust gases contain varying
amounts of organic HAP's, metal HAP's, HCl, and Cl2.
Blast furnaces and collocated reverberatory and blast
furnaces have potentially large organic HAP emissions.
Therefore, standards are being proposed to limit organic HAP
emissions from these furnace configurations. Rotary
furnaces, electric furnaces, and reverberatory furnaces not
collocated with blast furnaces have relatively low
potentials for organic HAP emissions and no standards are
being proposed to limit organic HAP emissions from these
furnace configurations. The MACT floor for these
configurations does not include add-on controls and the EPA
does not believe that there is any justification to be more
stringent than the MACT floor because of the small amounts
of organic HAP emissions associated with these sources.
Collocated reverberatory and blast furnaces are being
regulated as a single source type because a greater level of
control is achievable when reverberatory and blast furnaces
are collocated than when they are not. Other furnace
combinations have not been observed in this industry.
All smelting furnaces have high uncontrolled emissions
of metal HAP's. Therefore, emission standards to limit lead
emissions (as a surrogate for metal HAP's) that would apply
to all smelting furnace types and configurations are being
proposed.
All smelting furnaces that process lead-acid batteries
are also potential sources of HCl and Cl2 emissions because
of the presence of PVC plastic separators in the furnace
feed. The amount of HCl and Cl2 emitted will vary
substantially depending on the quantity of PVC in the feed
and whether fluxing agents are added to promote the
elimination of chlorides through slagging. However, because
all furnace types (except electric furnaces) are potential
sources, emission standards are being proposed to limit HCl
and Cl2 emissions from all but electric smelting furnaces.
Electric furnaces are not sources of HCl or Cl2
emissions because the chlorine present in the feed material
is in the form of NaCl or CaCl2 and cannot be released
during smelting. However, the proposed regulation defines
electric smelting furnaces to include only those that
process reverberatory furnace slag as the lead-bearing
material charged to the furnace. No electric furnaces that
process other lead-bearing materials are currently in use.
2. Process Fugitive Sources
The following process fugitive sources were selected
for regulation: (1) Smelting furnace and dryer charging
hoppers and chutes (the furnace and dryer openings into
which materials are charged), (2) lead taps and molds,
(3) slag taps and molds, (4) refining and alloying kettles,
(5) dryer transition pieces, and (6) flue dust agglomerating
furnace taps and molds. All process fugitive sources are
potential emission points of metal HAP's. Blast furnace
charging emissions may also contain organic HAP's if there
is leakage of primary exhaust gases into the ventilation
hood over the charging chute.
The EPA is not proposing standards for battery breaking
equipment (e.g., rotary hammermills, saws, and shears) or
lead casting machines. Many smelters do not have add-on
controls for metal HAP's for these sources so that the MACT
floor is no control. The EPA does not believe there is any
justification for controls more stringent than the floor.
Battery breakers are small sources of metal HAP emissions
[about 18 kilograms (40 pounds) per year per battery
breaker] compared to other sources, and they emit relatively
large particles that settle out quickly from the air in the
battery breaking area. The proposed NESHAP would require
fugitive dust controls in the battery breaking area that
would control potential emissions from these settled
particles. Casting machines that are used to cast refined
lead into ingots are also small sources of metal HAP
emissions because the molten lead in the molds is below the
fuming temperature of lead. Therefore, casting machines are
not included in the proposed regulation.
3. Fugitive Dust Sources
Fugitive dust sources selected for regulation are the
following: (1) The battery breaking area, (2) the materials
storage and handling area (including, but not limited to,
areas in which slag and flue dust are stored), (3) the
smelting furnace area, (4) the refining and casting area,
and (5) plant yards and roadways. Fugitive dust sources are
potential emission sources of metal HAP's, but not organic
HAP's or HCl and Cl2. Therefore, the five listed sources
will be covered by the proposed regulation.
C. Selection of Basis and Level for the Proposed
Standards for New and Existing Sources
Section 112(d)(3)(B) of the Act requires that the EPA
set standards no less stringent than "the average emission
limitation achieved by the best performing 5 sources" for
categories with fewer than 30 sources. Floor levels of
control were determined for each of the affected source
types under consideration for regulation. Source types are
process sources, process fugitive sources, and fugitive dust
sources. For process fugitive sources and fugitive dust
sources, which are similar in character and emissions
potential across all secondary lead smelters, the entire
population of secondary lead smelters was considered in
determining MACT floor levels of control. For process
sources, specifically smelting furnaces, smelters were
differentiated and divided into configurations based on the
smelting furnace types used at individual smelters. This
was done because smelting furnaces differ substantially,
based on configuration, in both emissions potential (mix and
amounts) and achievable control levels for organic HAP's.
Section 112(d)(1) of the Act gives the Administrator the
authority to distinguish among classes, types, and sizes of
sources within a category when establishing standards.
Because the secondary lead smelter category comprises
fewer than 30 sources, the floor level of control selected
for existing sources is based on the median level of control
achieved by the best-performing five sources. That is, the
floor level of control reflects the control technology in
use by the source positioned third (the median) among the
best-performing five. The median was selected as the MACT
floor, rather than the mean, because the MACT floor is based
on the control technology used and the mean cannot be
determined. The floor for new sources reflects the control
technology in use by the best-controlled source in the
category. Emission limits were then selected based on the
performance continuously achievable by the proposed MACT
technology.
1. Selection of MACT for Process Sources
Separate MACT floors were determined for the following
smelting furnace configurations: (1) Collocated
reverberatory and blast furnaces, (2) blast furnaces not
collocated with a reverberatory furnace, (3) reverberatory
or rotary furnaces not collocated with a blast furnace, and
(4) electric furnaces. Only smelters with a similar furnace
configuration were used to establish the MACT floor level of
control for new and existing furnaces within each
configuration. The four configurations were selected based
on differences in potential emissions and control options
among the configurations.
With one exception--the blast-furnace-only
configuration--the MACT floor level of control was the only
option considered because no options more stringent than the
MACT floor are known. For the blast-furnace-only
configuration, two options--the floor and one more stringent
than the floor--were considered.
The emission reductions and cost impacts of the
proposed MACT floor and more stringent options are presented
in more detail in chapters 5 and 6 of the BID, respectively.
a. Reverberatory/Blast Furnace Configuration.
Control measures currently in use to control furnace
emissions at collocated reverberatory/blast furnace
facilities are combinations of afterburners, gas stream
blending, baghouses, wet scrubbers, and fluxing additions.
Afterburners used to control only blast furnace emissions
are capable of achieving about 90-percent control of organic
HAP's, THC, and CO. Gas stream blending consists of mixing
blast furnace gases with hotter and larger volume
reverberatory furnace gases in a chamber for incineration.
Gas stream blending provides more cost-effective control of
organic HAP's than do afterburners by utilizing the large
volume of hot (greater than 1,000 oC) exhaust produced by
the reverberatory furnace. Greater than 99-percent control
of THC (the surrogate for organic HAP's) and 98-percent
control of CO have been demonstrated (Docket No. A-92-43,
Item No. II-A-3).
Baghouses are used to control PM and lead. Properly
operated and maintained, baghouses are capable of achieving
greater than 99-percent control of PM and about 98-percent
control of lead and other metal HAP compounds (Docket
No. A-92-43, Items II-A-1, II-A-2, II-A-3). Wet scrubbers,
primarily in place to control SO2, are capable of providing
99-percent control of HCl/Cl2 (Docket No. A-92-43, Item No.
II-A-3). The addition of soda ash or limestone fluxing
agents to the furnace feed to enhance the removal of
chlorides through slagging can achieve HCl/Cl2 control
equivalent to that of wet scrubbing (Docket No. A-92-43,
Items II-A-1, II-A-2).
Nine smelters operate reverberatory/blast
configurations. The best-controlled source and best-
performing five sources all blend gas streams to control
organic HAP emissions, use baghouses to control metal HAP
emissions, and either scrub or flux to control HCl/Cl2
emissions. Consequently, the combination of these controls
constitutes MACT floors for both new sources and existing
sources.
Because there are no control options available for
consideration more stringent than the MACT floor controls
for new or existing sources, the technological basis
selected for the proposed standards for collocated
reverberatory/blast furnaces is gas stream blending to
control organic HAP's, a baghouse to control metal HAP's,
and a scrubber or flux addition to control HCl/Cl2.
Under this selection of MACT for existing sources, six
smelters would have to upgrade their air pollution controls
to some degree to meet the proposed MACT. Physical upgrades
would include the retrofit of additional ductwork at five
smelters to blend the blast and reverberatory furnace gas
stream to achieve incineration of organic HAP's in the blast
furnace emissions. Other upgrades required at four smelters
include the addition of fluxing agents to the reverberatory
furnace feed for HCl/Cl2 control.
Total estimated capital costs for upgrades at the
smelters requiring additional ductwork would be about
$330,000. The costs for purchasing additional fluxing
agents were included as annual costs rather than capital
costs. Total annualized costs for all six impacted smelters
would be about $120,000 -- $40,000 for capital recovery and
about $80,000 for the purchase of fluxing agents (soda ash
or limestone) at four smelters that do not have SO2
scrubbers.
Installing the proposed MACT floor controls at smelters
with reverberatory/blast furnaces would reduce organic HAP
emissions by 640 Mg/yr (700 tpy) and HCl/Cl2 emissions by
360 Mg/yr (400 tpy). Emissions of THC and CO would also be
reduced by about 2,500 Mg/yr (2,800 tpy) and 47,000 Mg/yr
(52,000 tpy), respectively. All of these smelters currently
have baghouses, so there would be no reduction in metal HAP
emissions from process sources and no associated cost
impacts.
b. Blast Furnace Configuration. Control measures
currently in use to control furnace emissions at blast
furnace-only facilities include afterburners, baghouses, wet
scrubbers, and fluxing. Although installed primarily for
the combustion of CO, afterburners also provide varying
degrees of control for organic HAP's. The most important
variable in afterburner performance, that is, the ability to
combust and destroy organics, is temperature, although
residence time and turbulence are also important.
Temperature, however, is the most important variable, with
higher levels of destruction achieved at higher
temperatures.
The operating temperature of the best-performing
afterburner in this furnace configuration is 870 oC
(1,600 oF) (Docket No. A-92-43, Item No. II-D-4), which
represents an estimated 98-percent organic HAP control
(Docket No. A-92-43, Item II-B-31). The average temperature
of the five best-performing afterburners operating at the
highest temperatures is 700 oC (1,300 oF), which represents
an estimated 84-percent organic HAP control. Baghouses, wet
scrubbers, and fluxing provide the same levels of control
for metal HAP's (98 percent) and HCl/Cl2 (99 percent) for
blast furnaces as for collocated reverberatory/blast
furnaces.
The blast furnace-only configuration encompasses
13 blast furnaces at 8 smelters. The best-controlled blast
furnace is controlled by an afterburner at 870 oC (1,600 oF)
to control organic HAP's and a baghouse to control metal
HAP's, and performs fluxing with soda ash or limestone or
operates an SO2 scrubber to control HCl/Cl2 emissions. The
combination of these controls constitutes the proposed MACT
for new sources.
Seven blast furnaces are controlled by an afterburner
to control organic HAP's and a baghouse to control metal
HAP's, and perform fluxing or use a scrubber to control
HCl/Cl2. The average temperature of the five afterburners
operated at the highest temperatures is 700 oC (1,300 oF).
The proposed MACT floor for existing sources is, therefore,
an afterburner operated at 700 oC (1,300 oF), a baghouse,
and fluxing.
To comply with a standard based on the MACT floor for
existing sources, five smelters would have to upgrade their
air pollution controls. Physical upgrades would include the
installation of afterburners at three smelters. Other
upgrades required at four smelters would be increased
afterburner temperature, which would require an increase in
natural gas consumption. Total estimated capital costs for
upgrades at the smelters requiring new afterburners would be
about $810,000. Total annualized costs would be $590,000 --
$120,000 for capital recovery and $470,000 for increased
fuel costs and other operating expenses to operate all
afterburners at 700 oC (1,300 oF).
Installing the proposed MACT floor controls at all
existing blast furnace facilities would reduce organic HAP
emissions by 580 Mg/yr (640 tpy). All blast furnace
facilities currently have baghouses and perform fluxing, so
there would be no reductions in metal HAP or HCl/Cl2
emissions and no associated cost impacts. Emissions of THC
and CO would also be reduced by about 2,700 Mg/yr
(3,000 tpy) and 32,000 Mg/yr (35,000 tpy), respectively.
There is one control option more stringent than the
controls in the floor for existing sources. That option is
to raise the afterburner temperature from 700 to 870 oC
(1,300 to 1,600 oF) -- effectively adopting the same
controls for existing sources as the new source MACT. The
EPA evaluated the incremental impacts of selecting an
afterburner at 870 oC (1,600 oF) as the technological basis
for controlling existing sources. Physical upgrades would
include the installation of new afterburners at seven
smelters, and other upgrades would include increased natural
gas consumption at all but one smelter.
Total capital and annualized costs for upgrades at
blast furnace smelters would nearly triple under the more
stringent option. Estimated total capital costs would
increase by $1,700,000 to $2,300,000 (at 870 oC) relative to
the floor level of control, and annualized costs would
increase by $1,100,000 to $1,700,000. The increased costs
would lead to an increase in adverse economic impacts.
Under the more stringent option, 7 blast furnace smelters
would be significantly impacted, compared to 5 smelters
under the MACT floor option. The two additional smelters
that are significantly impacted are operating smelters.
Under the more stringent option, organic HAP emissions
at blast furnace smelters would decrease an additional
110 Mg/yr (120 tpy), compared to an emissions reduction of
580 Mg/yr (640 tpy) under a standard based on the floor.
Emissions of THC and CO would decrease by an additional
500 Mg/yr (550 tpy) and 21,000 Mg/yr (23,000 tpy),
respectively, compared to initial reductions of 2,700 Mg/yr
and 32,000 Mg/yr under a standard based on the floor. The
incremental cost-effectiveness of organic HAP reductions
would be $10,000/Mg ($9,100/ton) under the more stringent
option.
In light of the cost and economic impacts and the HAP
reductions achievable, the EPA has concluded (subject to
comment) that adoption of this more stringent (above the
MACT floor) option as the basis for standards for existing
blast furnace smelters is unreasonable. Therefore, the
technological basis for the proposed standards for existing
blast furnaces is an afterburner at 700 oC (1,300 oF), a
baghouse, and fluxing or a scrubber.
The EPA is aware, however, that this proposal permits
organic HAP emissions at the eight facilities with blast
furnace-only configurations to remain significantly higher
than the organic HAP emissions resulting from other
configurations. Further, the EPA recognizes that additional
reductions are technically feasible at these locations if
the afterburner temperatures are raised. The EPA requests
comment on how consideration of the differential impacts and
environmental justice should be incorporated in the final
MACT determination. The EPA specifically requests comment
on the decision to establish proposed standards at the MACT
floor for the blast furnace-only smelting configuration.
c. Rotary and Reverberatory Furnace Configurations.
Control measures currently in use to control furnace
emissions at rotary furnace and reverberatory furnace
facilities are baghouses, wet scrubbers, and the addition of
fluxing agents. Baghouses and wet scrubbers provide the
same levels of control for metal HAP's (98 percent) and
HCl/Cl2 (99 percent), respectively, as with other furnace
configurations. Soda ash and limestone are added to all
rotary furnaces and some reverberatory furnaces as fluxing
agents, providing HCl/Cl2 control equivalent to that of
scrubbing.
The high exhaust temperature maintained in rotary and
reverberatory furnaces (greater than 1,000 oC) ensures
nearly complete destruction of any organic HAP's present.
Consequently, no additional control for organic HAP's is
necessary.
Six smelters operate either rotary or reverberatory
furnace configurations. The best-controlled furnace and
best-performing five furnaces use a baghouse to control
metal HAP's and a scrubber or fluxing to control HCl/Cl2.
Consequently, the combination of these controls constitutes
the MACT floors for both new source and existing source.
Because there are no control options available for
consideration more stringent than the controls in the floors
for new or existing sources, the technological basis
selected for the proposed standards for rotary and
reverberatory furnaces is a baghouse for controlling metal
HAP's and a scrubber or flux addition for controlling
HCl/Cl2.
Under this selection of MACT for new and existing
sources, two smelters would have to upgrade their air
pollution controls to some degree by increasing the amount
of fluxing agents added to their furnaces. No capital costs
would be incurred; total annualized costs would be $76,000
for the additional fluxing agents at the two smelters.
Hydrochloric acid and Cl2 emissions would be reduced by
about 350 Mg/yr (390 tpy). There would be no reduction in
metal HAP or organic HAP emissions and no associated cost
impacts. All six smelters operating this configuration
currently have baghouses for PM, lead, and other metals
control. Add-on controls for organic HAP emissions are
unnecessary because neither furnace type emits organic
HAP's.
d. Electric Furnace Configuration. There is currently
only one electric furnace in use in the secondary lead
smelting source category. It is used to process slag
generated at three reverberatory furnace-only smelters. The
furnace is equipped with a baghouse to control PM and lead
emissions. Neither organic HAP's nor HCl/Cl2 are emitted
from this furnace because it processes only slag that is
relatively free of organic matter and available chlorine.
Consequently, a baghouse constitutes the floor for both new
source and existing source MACT for controlling metal HAP's.
Because there are no available control options more
stringent than a baghouse, the proposed MACT for new and
existing sources is a baghouse. Because this furnace
already has a baghouse, no upgrades in air pollution
controls are needed and there would be no emission
reductions or cost impacts associated with the proposed
standard.
2. Selection of MACT for Process Fugitive Sources
Process fugitive sources are similar in emissions
characteristics and control technology across all secondary
lead smelters, regardless of smelting furnace configuration.
Therefore, there was no need to distinguish among process
furnace configurations when developing the standards for
process fugitive sources. The entire population of
secondary lead smelters was used in determining MACT floor
levels of control for new and existing sources.
The four types of process fugitive sources being
regulated are smelting furnace charging and tapping
locations, flue dust agglomerating furnaces, refining
kettles, and dryers. All of these are sources of metal
HAP's and are typically controlled by hoods ventilated to
baghouses.
The proposed equipment specifications for the design
and operation of capture hooding and ventilation for process
fugitive sources are adapted from the Occupational Safety
and Health Administration's (OSHA's) "Cooperative Assessment
Program Manual for the Secondary Lead Smelter Industry"
(Docket No. A-92-43, Item No. II-I-16). The OSHA manual
specifies that process fugitive sources should be controlled
by an enclosure-type hood that is ventilated so that a
minimum face velocity is achieved. Face velocity is the
velocity at which air is drawn into a hood and, along with
hood type, is a primary factor in hood capture efficiency.
The minimum recommended face velocity varies by source type,
but is generally about 110 m/min (350 fpm). These controls
represent state-of-the-art ventilation practices to protect
workers by promoting effective capture and ventilation of
process fugitive emissions.
The OSHA manual was developed in 1983 through a
cooperative effort by government, industry, and labor in
response to the occupational health standard for lead
(29 CFR 1910.1025), which requires that employers in the
secondary lead smelting industry implement controls to
reduce employee exposure to lead. The manual was prepared
to assist employers and employees in identifying and
implementing the best controls that were recognized as
technologically feasible.
Based on observations at operating secondary lead
smelters, the EPA believes that the capture and ventilation
systems installed and operated at secondary lead smelters
are designed and operated in accordance with the
specifications contained in the OSHA cooperative assessment
program manual. These controls consequently establish the
MACT floor. Therefore, the EPA is proposing to incorporate
these specifications into the proposed MACT for new and
existing process fugitive sources.
a. Smelting Furnace Charging and Tapping. Smelting
furnace charging and tapping are sources of metal HAP's.
Blast furnace charging can also be a source of organic
HAP's. With one exception, all furnace charging and lead
tapping and slag tapping locations on 44 smelting furnaces
are enclosed in a hood and captured emissions are ventilated
to a baghouse for the control of metal HAP's. One blast
furnace has no hooding or ventilation on the charging chute.
Consequently, the MACT floor for existing sources is hooding
and ventilation to a baghouse for the control of metal
HAP's. There are no control options above the MACT floor,
so the floor is the proposed MACT for both existing and new
sources. The OSHA manual recommends an enclosure-type hood
with a minimum face velocity of 110 m/min (350 fpm) for
these emission points. The manual also recommends a similar
hood for the transition piece on rotary furnaces.
The proposed MACT to control organic HAP emissions from
blast furnace charging is a hood over the charging chute
with a ventilation flow rate that is properly balanced
against the primary exhaust flow rate from the furnace. The
two flow rates are balanced to minimize the escape of
primary exhausts and organic HAP's to the furnace charging
hood.
b. Agglomerating Furnaces. Agglomerating furnaces
are sources of metal HAP's. They are used at nine smelters
and all are hooded and ventilated to a baghouse. Therefore,
the MACT floor for existing sources is a hood with
ventilation to a baghouse. There are no control options
above the MACT floor, so the MACT floor is the basis for the
proposed MACT for both new and existing sources. The OSHA
manual recommends an enclosure-type hood with a minimum face
velocity of 110 m/min (350 fpm).
c. Refining Kettles. Refining kettles are sources of
metal HAP's. There are about 170 refining kettles and they
are hooded and ventilated to baghouses at all but three
smelters; three smelters use wet scrubbers instead of
baghouses. Baghouses typically offer greater control of
metal HAP's than wet scrubbers. Therefore, the MACT floor
for existing sources is a hood and ventilation to a
baghouse. There are no control options above the MACT
floor, so the MACT floor is the basis for the proposed MACT
for both new and existing sources. The OSHA manual
recommends enclosure-type hoods with minimum face velocities
of 75 m/min (250 fpm) and flow rates of at least 60 m3/min
per m2 (200 acfm/ft2) of the surface area of the kettle's
contents.
d. Dryers. Dryers are sources of metal HAP's. They
are currently in use at six smelters to remove moisture from
materials just prior to charging them to reverberatory
smelting furnaces. Each dryer has a transition piece
between the dryer cylinder and the furnace feed chute.
These transition pieces on all dryers are hooded and
ventilated to a baghouse. The MACT floor for both existing
and new dryers is, therefore, hoods over the transition
pieces with ventilation to a baghouse. There are no control
options above the MACT floor, so the MACT floor is the basis
for the proposed MACT for both new and existing sources.
The OSHA manual does not contain recommendations for
dryers, but the transition piece on a dryer is analogous to
the transition piece on a rotary smelting furnace, for which
the manual recommends an enclosure-type hood with a face
velocity of at least 110 m/min (350 fpm). The proposed MACT
includes these specifications.
3. Impacts of Proposed Standards for Process Fugitive
Sources
There are no controls more stringent than those
established by the MACT floor described above for process
fugitive sources. Therefore, the EPA is proposing standards
for process fugitive sources that correspond to the MACT
floor.
One smelter would be required to upgrade its process
fugitive controls by adding a hood over its blast furnace
charging chute. The estimated capital and annualized costs
to enclose and ventilate this one source would be $47,000
and $4,400, respectively. The estimated pollutant reduction
would be 26 Mg/yr (29 tpy) of metal HAP's.
Another smelter would be required to balance existing
ventilation air at the blast furnace charging chute to
preclude the inadvertent collection of process gases that
contain organic HAP's. The potential emission reductions at
the one smelter at which organic HAP process emissions were
detected in the charging hood exhaust air would be about
50 Mg/yr (55 tpy).
The EPA has no data on the performance of the wet
scrubbers being used to control the refining kettle
emissions at three smelters. The MACT floor for refining
kettles is hooding and ventilation to a baghouse, and
baghouses are generally more efficient than scrubbers in
controlling metal HAP's. However, refining kettles are very
similar to scrap melting operations at battery manufacturing
facilities. Data from the latter that are controlled by wet
scrubbers indicate that refining kettles controlled by wet
scrubbers should be able to achieve a lead limit that is
based on the performance of a baghouse (Docket No. A-92-43,
Item No. II-A-8). Therefore, it should not be necessary to
replace the existing wet scrubbers with baghouses and there
should be no associated cost impacts.
4. Selection of MACT for Fugitive Dust Sources
Fugitive dust sources are similar in emissions
characteristics and control technology for all smelters,
regardless of smelting furnace configuration. Therefore,
there was no need to distinguish among furnace
configurations when developing the standards for fugitive
dust sources. The entire population of 23 secondary lead
smelters was used to determine the MACT floors for new and
existing fugitive dust sources.
The four areas of fugitive dust sources being regulated
are battery breaking areas, furnace and refining and casting
areas, materials storage and handling areas, and plant
roadways.
Controls for fugitive dust sources include: (1) Paving
all areas subject to vehicle traffic to facilitate the
removal of accumulated dust, (2) periodic cleaning of all
paved areas to remove deposited dust and prevent its
re-entrainment or transfer to other areas by vehicle
traffic, (3) vehicle washes at exits from materials storage
and handling areas to prevent carry-out of metal HAP-bearing
residues and dust, (4) wetting or use of chemical
surfactants, binding agents, or sealers on storage piles
coupled with partial or total enclosures to limit wind
erosion and the generation of dust associated with materials
storage and handling, and (5) ventilating total enclosures,
where used, to a baghouse or equivalent device to capture
airborne dust.
Total enclosure of a fugitive dust source and
ventilation of the enclosure to a control device may at
first appear to be the most effective means of controlling
fugitive dust emissions. However, the EPA has determined
from observations of operating smelters and a technical
analysis of fugitive dust control measures applicable to
this source category that partial enclosures with
appropriate wetting and pavement cleaning cost much less and
are equally effective in controlling fugitive dust emissions
when coupled with monitoring and recordkeeping to ensure
these activities are performed (Docket No. A-92-43, Item
No. II-B-28).
It should be noted that existing Clean Water Act
effluent limitation guidelines already provide discharge
allowances, based on technology-based controls, for
pollutants in the wastewater generated from facility wash
down and truck washing. This proposed regulation should not
require any amendments to those standards. (See 40 CFR 421,
subpart M).
a. Battery Breaking Area. At least nine smelters
control fugitive dust emissions from the battery breaking
area. Controls include partial or total enclosures, vacuum
or powerwashing systems, and the wetting of storage piles.
Therefore, these controls are the MACT floor for existing
sources. Because there exists no more stringent controls
that are demonstrated for the battery breaking area, these
floor level controls are the proposed MACT for existing
sources and are also the proposed MACT for new sources. An
equivalent alternative technology is to totally enclose the
area and ventilate the entire building or enclosure volume
to a baghouse.
b. Furnace and Lead Refining and Casting Areas. At
least 12 smelters either totally enclose the furnace and
lead refining and casting areas and ventilate the enclosure
to a baghouse, or partially enclose this area on at least
three sides and vacuum or powerwash the pavement. The
remaining smelters use some, but not all, of these
techniques. Therefore, partial enclosure coupled with
pavement cleaning (vacuuming or powerwashing) or total
enclosure ventilated to a baghouse is the MACT floor for
existing sources. Because no more stringent controls are
available, these floor level controls are the proposed MACT
for existing sources and are also the proposed MACT for new
sources.
c. Materials Storage and Handling Areas. At least
12 smelters have paved the materials storage and handling
areas, operate vehicle washes at exits from these areas, and
either totally enclose the area and ventilate the enclosure
to a baghouse or partially enclose the storage piles and use
wetting or other dust suppression techniques on the storage
piles. The remaining smelters use some, but not all, of
these techniques. Therefore, vehicle washes, paving, and
either partial enclosure coupled with wet suppression or
total enclosure and a baghouse is the MACT floor for
existing sources. Because no more stringent controls are
available, these floor level controls are the proposed MACT
for existing sources and also the proposed MACT for new
sources.
d. Roadways. At least 16 smelters have paved their
roadways and periodically clean the pavement by vacuuming or
powerwashing. Therefore, these controls are the MACT floor
for existing sources. Because no more stringent controls
are available, these floor level controls are the proposed
MACT for existing sources and also the proposed MACT for new
sources.
5. Impacts of Proposed Standards for Fugitive Dust
Sources.
The EPA is proposing that the MACT floors should serve
as the basis of the proposed standards for fugitive dust
sources because there are no available control technologies
more stringent than the MACT floors. Each smelter would be
required to develop an SOP manual that describes how it will
use MACT controls to limit fugitive dust emissions and
operate according to the manual at all times.
Thirteen smelters would be required to upgrade their
fugitive dust controls and practices to meet the MACT level
of control in the proposed standards. Four smelters would
need to purchase mobile vacuum systems and allocate
additional labor hours to operate them. Nine smelters that
already operate vacuums would need to increase the operation
of the vacuums to clean additional areas not currently
vacuumed or begin implementing some form of dust suppression
practices in the materials storage area.
The capital costs of adopting the proposed standards
would be about $190,000 for the purchase of vacuums at four
smelters. The total annual cost would be $110,000, which
includes the annualized cost of the new vacuums, operating
labor for additional vacuuming, and the cost of additional
water (including treatment) for wet suppression. The
estimated emission reductions would be 23 Mg/yr (25 tpy) of
metal HAP's. The dust collected by the additional vacuum
sweepers and other fugitive dust controls would be recycled
back into the smelting furnace to recover the lead content.
Therefore, there would be no significant costs incurred for
the management of the captured fugitive dust.
D. Selection of the Format for the Proposed Standards
Several formats were considered to implement the
control techniques selected as the basis for the proposed
standards. These include emission standards in a variety of
format options, as well as design, equipment, work practice,
and operational standards. Section 112(d) of the Act
requires the Administrator to prescribe emission standards
for HAP control unless, in the Administrator's judgement, it
is not feasible to prescribe or enforce emission standards.
Section 112(h) defines two conditions under which it is
not feasible to prescribe or enforce emission standards:
(1) If the HAP cannot be emitted through a conveyance device
designed and constructed to emit or capture the HAP, or
(2) if the application of measurement methodology to a
particular class of sources is not practicable because of
technological or economic limitations. If it is not
feasible to prescribe or enforce emission standards, then
the Administrator may instead promulgate equipment, work
practice, design, or operational standards, or a combination
thereof.
Format options for numerical emission standards or
limits include mass concentration (mass per unit volume),
volume concentration (volume per unit volume), mass emission
rate (mass per unit time), process emission rate (mass per
unit of production or other process parameter), and percent
reduction.
1. Process Emission Sources
The EPA is proposing numerical emission standards,
expressed as mass or volume concentrations, for lead, THC,
and HCl/Cl2 emissions from smelting furnaces. As noted in
section II.D of this preamble, lead and THC have been
selected as surrogates for metal HAP's and organic HAP's,
respectively.
Baghouses constitute the technological basis for the
MACT standards proposed to limit metal HAP emissions from
smelting furnaces. Because of the physical mechanism by
which baghouses operate, they characteristically achieve a
constant outlet concentration independent of the inlet
concentration or loading. Tempering air is introduced
before the baghouse at some smelters to cool furnace process
emissions and control baghouse temperature, but this
dilution prior to the baghouse does not affect outlet
concentrations or baghouse performance. Dilution with
ambient air between the control device and an emission
monitoring or testing point is prohibited under section 63.4
of the General Provisions.
Other format options considered included mass rate
(kg/hr), a production-based emission rate (kg/Mg of furnace
charge), and percent reduction. The EPA is not proposing
the mass emission rate format (kg/hr) because it cannot
account for differences in actual emission rates between
different size smelting furnaces. The production-based
emission rate format is not proposed because production rate
is difficult to measure over short periods and the mass
emission rate from a baghouse may not correlate well with
production rate during an emissions test. The EPA is not
proposing the percent reduction format because baghouses are
constant outlet devices, causing removal efficiency to vary
with inlet loading. In addition, this format would require
simultaneous testing at inlet and outlet locations, which
would subject smelters to unnecessary additional testing
costs. Consequently, the EPA is proposing a concentration
limit for lead reflecting performance of a properly operated
baghouse.
The format the EPA is proposing for the THC emission
standard is concentration expressed in ppmv as propane,
corrected to a constant CO2 concentration. The correction
to a constant CO2 concentration accounts for any dilution
due to blending with process fugitive emission streams prior
to discharge to the atmosphere. Alternative formats that
were evaluated but not selected were mass emission rate,
production-based emission rate, and percent reduction.
The format of the proposed HCl/Cl2 standard is
concentration expressed as mg/dscm and corrected to a
constant CO2 concentration to account for dilution from
combined process fugitive streams. Format options examined
but not selected for the HCl/Cl2 emission standard include
mass emission rate, production based emission rate, and
percent reduction.
For both the THC and HCl/Cl2 emission standards, the
kg/hr mass emission format was not proposed because it does
not account appropriately for size differences among
smelting furnaces. The EPA is not proposing the production-
based emission rate format because of the difficulty in
establishing relationships between emissions and production
or process parameters during the short time period of an
emissions test. The percent reduction format is not
proposed because there is often no suitable inlet location
for testing. In addition, even if a suitable test location
were available, this format requires simultaneous inlet and
outlet testing, which would subject smelters to unnecessary
additional testing costs.
The measured THC and HCl/Cl2 concentrations would be
corrected to a constant CO2 concentration of 4 percent to
account for dilution from tempering air or from combined
process fugitive emission sources. The measured THC or
HCl/Cl2 concentration would be multiplied by a correction
factor determined by dividing 4 percent CO2 by the CO2
measured during the compliance test. If the measured CO2
concentration is less than 0.4 percent, then a maximum
correction factor of 10 would be used. A cap on the
correction factor was selected because the relation between
the correction factor and the measured CO2 concentration is
non-linear and the correction factor becomes unreasonably
high at a CO2 concentration below 0.4 percent. Furthermore,
the proposed method for measuring CO2 (EPA reference
method 3B) is only accurate to within 0.2 percent CO2.
A cap on the correction factor will not bias compliance
calculations towards less stringent enforcement of the THC
or HCl/Cl2 emission standards. It is unlikely, because of
the economic cost of moving such a large volume of air, that
any smelter would attempt to dilute a process emission
stream more than 10 times above the level needed for normal
gas stream conditioning.
2. Process Fugitive Sources
The proposed standards for process fugitive emissions
would require: (1) Proper capture of process fugitive
emissions, and (2) control or destruction of the captured
emissions. Equipment specifications (i.e., requirements for
hoods with specified face velocities) are proposed to ensure
that emissions from process fugitive sources are effectively
captured and conveyed into a duct that can be directed to a
control device.
Numerical emission limits are being proposed to judge
the performance of the control device. A numerical emission
limit (mg/dscm) for lead compounds, as a surrogate for metal
HAP's, is proposed for the control device that collects the
captured process fugitive emissions (e.g., the sanitary
baghouse). A mass rate (kg/hr) THC emission limit, as a
surrogate for organic HAP's, is being proposed for emissions
from blast furnace charging. A concentration THC limit was
considered but is inappropriate because of the variability
among smelters in the quantity of ventilation air applied at
furnace charging locations and the frequent mixing of
furnace charging air with ventilation air from other process
fugitive sources, such as furnace tapping locations and
refining kettles.
The THC limit on blast furnace charging would apply
only if the charging process fugitive emissions are
discharged through a separate stack from the process
emissions. The facility operator would not need to
demonstrate compliance with the THC emission standard for
process fugitive charging emissions if two conditions exist:
(1) The ventilation air from the hood and the process
exhaust gases are combined and discharged through a common
stack, and (2) compliance with the THC emission limit for
process sources is determined downstream from the point at
which the charging ventilation air and process source
exhaust are combined. In this case, compliance with the THC
limit for process sources would be sufficient to confirm
that process emissions are not escaping into the blast
furnace charging hood and that all organic HAP emissions are
being properly controlled.
3. Fugitive Dust Sources
Work practice standards are being proposed to control
fugitive dust sources, as allowed under section 112(h) of
the Act. Because of their nature, fugitive dust emissions
can not be captured and subsequently discharged through a
stack, vent, or other conveyance. Consequently, the use of
conventional stack sampling methods are not practical or
feasible. The proposed work practice standards would also
require the development of a site-specific SOP manual that
describes the steps that would be taken to limit fugitive
dust emissions from all affected sources. The controls
included in the SOP manual must be equivalent to those
specified in the proposed regulation.
E. Selection of Emission Limits and Equipment and Work
Practice Standards for New and Existing Sources
The proposed emission limits for lead, THC, and HCl/Cl2
are based on emissions data collected by the EPA primarily
through an emission source testing program conducted at
several well-controlled secondary lead smelters. The
purpose of the testing program was to evaluate the
performance of candidate MACT systems and to establish
appropriate and corresponding limits.
Prior to the EPA testing program, compliance test data
and emissions data from previous EPA studies of the
secondary lead smelting industry were collected and
reviewed. These data were mostly for criteria pollutants
(PM, lead, and SO2) and included insufficient data for metal
HAP's, organic HAP's, or HCl/Cl2 to accurately estimate
baseline emissions and to establish emission limits.
Therefore, the EPA testing program was initiated to collect
additional data on HAP emissions and on surrogates that are
strongly correlated with HAP emissions.
The EPA testing was conducted at six facilities: a
collocated reverberatory/blast furnace facility, a rotary
furnace-only facility, a reverberatory furnace-only
facility, and three blast furnace facilities. These
facilities were selected for testing because they were
representative of other facilities with similar furnace
configurations and because each facility had controls for
organic HAP's, metal HAP's, and HCl/Cl2 that represented the
MACT floor controls.
Complete results of the testing program and their
analyses are summarized in chapter 3 and appendix A of the
BID. The derivation of the proposed emission limits for
process and process fugitive sources is described in more
detail in Docket No. A-92-43, Item No. II-B-32.
1. Process Sources
Emission limits for process sources were developed from
EPA test data for lead and THC (surrogates for metal HAP's
and organic HAP's, respectively) and for HCl/Cl2.
a. Lead Emission Limit. The proposed lead emission
limit was selected primarily on the basis of the results of
EPA-sponsored tests of smelting furnaces controlled by well-
maintained and well-operated baghouses. The EPA tested
three baghouses used to control furnace exhausts from a
blast furnace, a combined reverberatory/blast furnace, and a
rotary furnace. The baghouse on the blast furnace also
treated ventilation air from furnace charging and lead and
slag tapping. Three sample runs using EPA reference method
12 were conducted at the outlet of each baghouse to quantify
lead emissions.
The average lead concentration from each baghouse
ranged from 0.60 to 0.70 mg/dscm (0.00026 to
0.00031 gr/dscf). The average lead concentration for all
three baghouses tested (total of nine sample runs) was
0.66 mg/dscm (0.00029 gr/dscf). Individual runs ranged from
0.28 mg/dscm to 1.03 mg/dscm.
A statistical analysis of the variability in the
process baghouse data was performed. The analysis
inherently accounts for variability in emissions from well-
operated and well-maintained baghouses as well as
measurement variability. At a 95-percent confidence level,
lead emissions measured during subsequent tests of the same
baghouses could be as high as 1.3 mg/dscm (0.00057 gr/dscf)
with no changes in baghouse operation or maintenance. This
suggests that the proposed lead emission limit should be no
lower than 1.3 mg/dscm.
Compliance test data collected from other operating
smelters were also examined. These data, consisting of
23 individual compliance tests, show lead emissions from
process baghouses ranging from 0.04 to 4.7 mg/dscm
(0.00002 to 0.0021 gr/dscf) and suggest that the lead
emission limit should be higher than 1.3 mg/dscm.
Most of the data are distributed continuously at
concentrations less than or equal to 1.6 mg/dscm. The
emissions of 1.6 mg/dscm were measured at a new smelter just
after it began operating in 1992. Close examination of the
data greater than 1.6 mg/dscm and available documentation
provided the following comments. Lead emissions of
2.3 mg/dscm were measured in 1988 at a smelter that has
since upgraded its air pollution control systems. The other
emissions data greater than 2.3 mg/dscm were measured at
smelters that are not currently operating. The operation
and maintenance quality of the baghouses at these latter
smelters cannot, therefore, be determined.
These compliance data indicate that the lead emission
limit should be greater than 1.6 mg/dscm but less than
2.3 mg/dscm. Based on this information, the EPA selected an
emission limit of 2.0 mg/dscm (0.00087 gr/dscf) as a
reasonable value between 1.6 and 2.3 mg/dscm.
A complete and detailed presentation of the baghouse
test data, both EPA-collected and industry-supplied, is
included chapter 3 and appendix A of the BID. The analysis
performed in selecting the proposed lead emission limit is
described in Docket No. A-92-43, Item No. II-B-32.
The compliance data available to the EPA show several
smelters with lead emissions substantially lower than
2.0 mg/dscm. These data may lead to the conclusion that the
MACT floor emission limit (based on the average emission
limitation achieved by the best-performing five sources)
should also be substantially lower than 2.0 mg/dscm.
However, it should be kept in mind that these compliance
data, like the EPA test data, were collected over a brief
time period, i.e., three 1-hour runs. Therefore, these data
represent only a "snapshot" of the performance of each
source and do not necessarily represent an emission level
that can be continuously achieved on a long-term basis by
the MACT floor control technology.
There are variations in emissions over time that cannot
be attributed to variation in any particular furnace or
control device operating or maintenance parameter. This is
demonstrated, for example, by the variation in the
measurements observed over the three runs during a single
emissions test. The EPA took this variation in emissions
into account when developing the proposed emission limit of
2.0 mg/dscm by examining all of the data that are available
for smelting furnaces controlled by well-operated and well-
maintained baghouses. The proposed 2.0 mg/dscm emission
limit represents the average of the five best-performing
sources adjusted for variability and it is continuously
achievable on a long-term basis by a smelter controlled by a
well-operated and well-maintained baghouse.
b. THC Emission Limits. The EPA measured controlled
THC concentrations at the following smelting furnace
configurations with corresponding MACT controls: (1) A
reverberatory/blast furnace combination controlled by gas
stream blending with a combined exhaust temperature of
930 oC (1,700 oF); (2) a blast furnace controlled by an
afterburner operating at 700 oC (1,300 oF); (3) a rotary
furnace with no add-on organic HAP controls; and (4) a
reverberatory furnace with no add-on organic HAP controls.
The THC concentration at each smelter was measured
using EPA reference method 25A and expressed as an
equivalent concentration of propane. The average CO2
concentration was also measured as part of the gas stream
analysis using EPA reference method 3B (40 CFR part 60,
appendix A). The results of this testing program are
presented in more detail in chapter 3 and appendix A of the
BID. The methodology for the selection of the THC limits is
described in more detail in Docket No. A-92-43, Item
No. II-B-32.
The reverberatory/blast furnace configuration tested by
the EPA was controlled by blending the blast and
reverberatory furnace gases and then venting the combined
stream to an afterburner. The average temperature of the
combined stream at the afterburner inlet was 780 oC
(1,430 oF) and the average afterburner outlet temperature
was 940 oC (1,720 oF). The temperature range of the
afterburner outlet was 900 oC to 980 oC (1,650 oF to
1,800 oF). The residence time of the afterburner was
2.5 seconds. In this configuration, the fuel input to the
afterburner was minimal and most of the afterburner
temperature increase was probably due to the fuel value of
the organic compounds in the blast furnace exhaust.
At the reverberatory/blast furnace smelter, the
controlled THC measurements were made over three 3-hour
sampling runs. The average THC concentrations for the three
runs were 3.0 ppmv, 5.1 ppmv, and 20 ppmv at 4 percent CO2.
The average concentration for all three runs was 9.4 ppmv at
4 percent CO2. The variation observed in THC concentrations
could not be correlated with any variation in the smelting
furnaces or combustion conditions during the tests and,
therefore, appears to be normal for a well-controlled
reverberatory/blast furnace configuration. The THC
emissions limit selected for collocated reverberatory/blast
furnaces is 20 ppmv (as propane corrected to 4 percent CO2),
which is the highest THC concentration obtained during the
individual 3-hour runs. The EPA selected the highest run as
the proposed THC limit to account for normal variation in
THC emissions.
The blast furnace tested by the EPA was controlled by
an afterburner with an average operating temperature of
700 oC (1,300 oF), although during the tests the temperature
varied between 680 and 730 oC (1,250 and 1,350 oF), with a
few short-term spikes to 790 oC (1,450 oF). The retention
time of the afterburner was 2.5 seconds.
At the blast furnace-only smelter, the controlled THC
emissions were measured over two 3-hour runs. The average
THC concentration in the first run was 300 ppmv (as propane,
corrected to 4 percent CO2) and the average THC
concentration during the second run was 360 ppmv. The
average afterburner temperature during both runs was 700 oC
(1,300 oF). The 20-percent difference in THC concentration
between the two runs could not be attributed to any other
smelting furnace or afterburner operating parameter, so the
difference is expected to represent normal variation in THC
emissions from a well-controlled blast furnace. Based on
these tests, the EPA is proposing a THC emissions limit for
blast furnace facilities of 360 ppmv (as propane, corrected
to 4 percent CO2), which is the higher concentration from
the two 3-hour runs. The EPA selected the higher
concentration to account for the normal variability in THC
emissions from a blast furnace controlled by an afterburner
operating at 700 oC (1,300 oF).
No data are available for the THC concentration from a
blast furnace controlled by an afterburner operating at
870 oC (1,600 oF), the proposed MACT for new blast furnaces.
However, previous EPA studies have demonstrated that
afterburners operating at 870 oC and a minimum residence
time of 0.75 seconds are capable of achieving a 98-percent
destruction efficiency for vent streams with organic
concentrations greater than 2,000 ppmv as carbon (about
700 ppmv as propane) (Docket No. A-92-43, Item No. II-B-31).
Based on a typical uncontrolled level for THC of 3,500 ppmv
as propane, the predicted THC concentration from a blast
furnace controlled by an afterburner operating at 870 oC
(1600 oF) is 70 ppmv, at 4 percent CO2. Therefore, the EPA
is proposing a THC limit for new blast furnace facilities of
70 ppmv (as propane, corrected to 4 percent CO2).
The exhaust temperature from rotary and reverberatory
furnaces are comparable to the afterburner outlet
temperature of the reverberatory/blast furnace configuration
(940 oC [1720 oF]), so there is nearly complete combustion
of organic compounds within the furnace itself and no add-on
organic HAP controls are needed. Rotary furnaces are
operated in batches lasting from 15 to 24 hours in length.
During charging, the furnace temperature is reduced and
there are brief (1-hour) periods when the THC level may
reach as high as 1,500 ppmv. The THC level drops quickly,
however, to less than 10 ppmv when charging is completed and
the furnace is brought to normal operating temperature.
Reverberatory furnaces are operated at a constant
temperature so there are no peaks in organic emissions
associated with charging.
None of the rotary furnaces in use at secondary lead
smelters have add-on controls for organics or CO. At the
rotary furnace smelter tested by the EPA, the THC
concentration at the furnace outlet was measured over six
complete batch cycles. Each batch cycle lasted from 15 to
24 hours. The THC concentration averaged over the length of
each batch cycle ranged from 35 to 170 ppmv as propane,
corrected to 4 percent CO2. The organic HAP emission rate
from the rotary smelting furnace was only about 0.5 kg/hr
(1 lb/hr), compared to about 3 and 9 kg/hr (7 and 20 lb/hr)
of uncontrolled organic HAP emissions from the
reverberatory/blast and blast furnaces tested by the EPA,
respectively.
The proposed MACT for new and existing rotary furnaces
is no add-on control for organic HAP's, which is consistent
with the MACT floor for these furnace types. For this
reason, and because of the low organic HAP emissions
potential from rotary furnaces, no THC emissions limit is
being proposed for rotary furnaces.
At the reverberatory furnace smelter tested by the EPA,
the THC concentration was measured at the furnace outlet
over one 5-hour run and three 1-hour runs. The average THC
concentration, as propane, for each run ranged from 9 to
11 ppmv, at 4 percent CO2. The average THC concentration
was lower than for rotary furnaces because reverberatory
furnaces are operated on a continuous basis and the furnace
temperature is not lowered during charging. No add-on or
process modification organic HAP controls are in use for
this furnace type, and the proposed MACT for new and
existing reverberatory furnaces is no add-on control.
Therefore, no THC emissions limit is being proposed for
reverberatory furnaces.
No THC or organic HAP emissions data are available for
the electric smelting furnace. However, this furnace
processes only slag that is essentially free of organic
material, and, therefore, is not likely to be a source of
organic HAP emissions. This presumption is confirmed by CO
emissions (which are correlated with organic HAP emissions)
that are similar to CO emissions from other furnace types
that also have low organic HAP emissions (Docket
No. A-92-43, Item II-I-22).
The EPA is not proposing organic HAP or THC standards
for rotary, reverberatory, and electric smelting furnaces
because of the low organic HAP emission potential and
because the MACT floor for organic HAP controls is no
control for these configurations. Moreover, efficient
production of lead in these furnace types requires operating
and exhaust temperatures that result in low organic HAP and
THC emissions. Relatively low emissions, therefore, should
be ensured even in the absence of an emissions standard or a
monitoring requirement.
c. HCl and Chlorine Emission Limits. The EPA measured
HCl and Cl2 emissions at the following smelting furnace
configurations with corresponding MACT controls: (1) A
reverberatory/blast furnace configuration controlled by the
addition of soda ash to the blast furnace and by a wet SO2
scrubber on the combined blast and reverberatory furnace
exhausts; (2) a blast furnace controlled by the addition of
soda ash to the furnace and a wet SO2 scrubber; and (3) a
rotary furnace controlled by the addition of soda ash to the
furnace and a wet SO2 scrubber. The facilities were
selected for testing because they were representative of
other facilities with similar furnace configurations and
because each smelter was fitted with a wet SO2 scrubber. At
the time the testing program was initiated, wet SO2
scrubbers were the only HCl/Cl2 controls being evaluated.
The use of fluxing to control HCl/Cl2 emissions was
developed as a result of the EPA testing program.
Emissions of HCl and Cl2 were measured ahead of and
after the scrubber at each smelter in three 1-hour sample
runs using EPA reference method 26A. The average CO2
concentration was also measured as part of the gas stream
analysis using EPA reference method 3B (40 CFR part 60
appendix A).
At the blast furnace and rotary furnace smelters, the
total HCl/Cl2 concentrations and emission rates measured
ahead of the scrubber were less than 1 mg/dscm
(0.0004 gr/dscf) and 0.05 kg/hr (0.1 lb/hr), respectively.
At these low levels, no detectable incremental control was
observed across the scrubber at either facility.
The reverberatory/blast furnace had a much higher total
HCl/Cl2 concentration and emission rate ahead of the
scrubber than either the blast and rotary furnaces:
273 mg/dscm (0.119 gr/dscf) and 12.5 kg/hr (27.6 lb/hr),
respectively. About 98 percent of these emissions were HCl
and 2 percent were Cl2. The scrubber was measured to be
99.8-percent effective in reducing total HCl/Cl2 emissions,
and the controlled emissions were less than 1 mg/dscm
(0.0004 gr/dscf) and 0.05 kg/hr (0.1 lb/hr).
The EPA believes that the very low uncontrolled HCl
emissions observed are due to the use of soda ash and
limestone as fluxing agents in the rotary and blast
furnaces. Both smelters reported that soda ash or limestone
were added primarily to enhance the reduction of lead
compounds to lead metal. An analysis performed by the EPA
indicates that these fluxing agents will also bind chloride
ions in the feed material as NaCl or CaCl2 salts so that the
chlorides are removed in the slag rather than being emitted
as HCl or Cl2. No fluxing agents were added to the
reverberatory furnace in the reverberatory/blast
configuration tested, and uncontrolled emissions of HCl
recorded were substantially higher than those recorded at
the blast and rotary furnaces tested with fluxing. However,
the wet scrubber was effective in reducing the HCl/Cl2
emissions from the reverberatory/blast furnace to the same
level as observed from the blast and rotary furnaces using
fluxing agents.
All three of these furnace types charge the smelting
furnace with battery scrap which contains PVC battery plate
separators. These separators, when burned, are believed to
be the source of the chlorides observed. These chlorides
may be removed from the furnace in two ways, either in the
form of HCl and Cl2 in the exhaust gas or they may be bound
in the slag and subsequently removed. At both the blast and
rotary furnaces, soda ash or limestone are normally charged
with the battery scrap. These compounds react with the
available chlorides to form salts (NaCl or CaCl2), which are
stable at typical furnace temperatures. These salts are
then removed from the furnace during slagging. At the
reverberatory/blast furnace combination, neither soda ash
nor limestone was charged to the furnace with the battery
scrap. Subsequently the chlorides are eliminated from the
furnace as HCl and Cl2 emissions.
Tests were also conducted at a reverberatory furnace at
which soda ash is charged to the furnace. These tests
indicate that substantial reductions in HCl emissions are
possible (greater than 90 percent) by adding soda ash to
this type of furnace. Other facilities operating this type
of furnace also add soda ash or limestone to the furnace
feed, but the EPA has no emissions data on these furnaces.
Because these other facilities normally charge these fluxing
agents to the furnaces, it is believed that the addition of
these fluxing agents will have no detrimental effect on the
final lead product.
A related method called de-sulfurizing also appears
effective in eliminating emissions of HCl/Cl2. The
chlorides are eliminated from the furnace in the slag using
the same chemical mechanism previously described. In this
process, the battery paste and flue dust are reacted with
soda ash to remove the sulfur from the feedstock. In this
process, unreacted soda ash remains with the resulting paste
and is charged into the furnace. Data indicate that
resulting HCl emissions are very low, less than 1.5 mg/dscm
(Docket No. A-92-43, Item Nos. II-D-18 and II-D-21).
If a facility chooses not to add these fluxing agents
to the furnace for process-related reasons, wet scrubbers
are capable of achieving the same emission rates for
HCl/Cl2.
It is also important to note that the EPA believes the
potential for HCl emissions from this source category will
be diminishing over the next several years. As stated
earlier, the source of chlorides in the furnace is the PVC
separators. Most battery manufacturers are phasing out the
use of PVC separators in favor of other materials (Docket
No. A-92-43, Item No. II-I-11).
Based on the EPA test results and technical analysis,
the EPA is proposing an HCl/Cl2 limit of 15 mg/dscm,
corrected to 4 percent CO2, for all smelting furnace
configurations except the electric smelting furnace. The
EPA is proposing an HCl/Cl2 limit of 15 mg/dscm rather than
1 mg/dscm, which was the emission concentration measured
during testing, because EPA reference method 26A has a
possible negative bias below an HCl concentration of
30 mg/dscm (59 FR 19306-19323). The margin between
1 mg/dscm and 15 mg/dscm was selected to account for this
potential bias. The CO2 correction factor is to account for
dilution if the process emissions at a facility are combined
with process fugitive emissions before the point at which
compliance with the HCl/Cl2 limit is determined.
No data are available for HCl or Cl2 emissions from the
electric smelting furnace. However, this furnace processes
only reverberatory furnace slag in which chlorides are
present in the form of NaCl or CaCl2 and there is a very low
potential for HCl and Cl2 emissions. Therefore, the EPA is
not proposing an HCl or Cl2 limit for this configuration.
2. Process Fugitive Sources
Equipment specifications are being proposed for process
fugitive emission capture systems. Emission limits for lead
emissions as a surrogate for metal HAP's are being proposed
for control devices that handle captured process fugitive
emissions. Emission limits for THC emissions as a surrogate
for organic HAP's are being proposed for control devices
that handle the gas streams from blast furnace charging
capture systems.
a. Equipment Specifications. The proposed equipment
specifications for process fugitive emission capture systems
were selected on the basis of observations at operating
smelters and the recommendations contained in the OSHA
Cooperative Assessment Program Manual for the Secondary Lead
Smelter Industry. The proposed equipment specifications are
described in more detail under the selection of MACT for
process fugitive sources in section VI.C of this preamble.
Observations made during EPA visits to operating
smelters indicated that nearly all process fugitive emission
sources at all the smelters visited are controlled by
enclosure-type hoods consistent with those recommended in
the OSHA manual. All of these hoods were ventilated to
baghouses or wet scrubbers. Face velocities measured with a
hand-held anemometer at one smelter were greater than the
minimum face velocities recommended in the OSHA Manual.
(Docket No. A-92-43, Item No. II-B-34).
b. Lead Emission Limit. The proposed lead emission
limit was selected on the basis of the results of EPA-
sponsored tests of process fugitive sources controlled by
well-maintained and well-operated baghouses.
The EPA determined baghouse performance for the control
of process fugitive metal HAP emissions by measuring
baghouse outlet lead concentrations using EPA reference
method 12. The EPA tested six baghouses controlling process
fugitive sources at three smelters. One baghouse controlled
the refining kettles at a blast furnace smelter. Another
baghouse controlled the refining kettles and furnace
charging and tapping at a rotary furnace smelter. The
remaining four baghouses controlled the process fugitive
emissions and building ventilation sources at a
reverberatory/blast furnace smelter. The average of three
runs was used to characterize the performance of each
baghouse.
The average lead concentration from each baghouse
ranged from 0.33 to 1.82 mg/dscm (0.00015 to
0.00080 gr/dscf). The average lead concentration for all
six baghouses tested was 0.83 mg/dscm (0.00036 gr/dscf).
The baghouse with the highest lead emission rate appeared to
be well operated and well maintained, although removal
efficiency was substantially lower because the inlet grain
loading was also lower than for the other process fugitive
baghouses.
A statistical comparison of the average emission
concentrations indicate that there is no significant
difference in the controlled lead emissions from the process
fugitive baghouses compared to the process baghouses at the
5 percent probability level. A statistical analysis of the
normal variability in the process fugitive baghouse data
(excluding the baghouse with the lowest efficiency)
predicted at the 95-percent confidence level that lead
emissions measured during subsequent tests of the same
baghouses could be as high as 2.0 mg/dscm (0.00087 gr/dscf)
with no changes in baghouse operation or maintenance.
Compliance test data provided to the EPA by smelter
operators show lead emissions from process fugitive
baghouses ranging from 0.02 to 1.1 mg/dscm (0.00001 to
0.00048 gr/dscf), indicating that all smelters could achieve
a lead emission level of 2.0 mg/dscm. This emission level
also accommodates the baghouse with the 1.82 mg/dscm outlet
concentration measured by the EPA. Based on the outcome of
the EPA testing program, the EPA has selected a proposed
lead emissions limit of 2.0 mg/dscm (0.00087 gr/dscf) for
process fugitive sources.
The EPA baghouse data are presented in chapter 3 and
appendix A of the BID. The analysis performed in selecting
the proposed lead emission limit is detailed in Docket
No. A-92-43, Item No. II-B-32.
c. THC Emission Limit. The proposed THC emissions
limit for process fugitive emissions from blast furnace
charging was selected on the basis of the results of EPA-
sponsored tests of the charging system at two blast
furnaces. Each blast furnace charging chute was enclosed in
a hood. On the first furnace, the chute was also fitted
with a door that opened during charging. The flow rate of
each hood was balanced against the flow rate of the primary
furnace exhaust to minimize the escape of primary exhaust
gases to the charging hood.
The THC emission rate was measured in the duct leading
from the charging hood using EPA reference method 25A. Each
test consisted of two 3-hour runs. The THC emission rates
measured during each run of the first test were 0.026 kg/hr
(0.058 lb/hr) and 0.035 kg/hr (0.077 lb/hr) (Docket
No. A-92-43, Item No. II-A-5). The THC emission rates
measured during each run of the second test were 0.11 kg/hr
(0.24 lb/hr) and 0.20 kg/hr (0.44 kg/hr) (Docket
No. A-92-43, Item II-A-6). The average THC emission rate
for all four runs was 0.090 kg/hr (0.20 lb/hr). The THC
emissions were substantially lower from the furnace fitted
with the door, but it could not be confirmed that the
difference was due to the door or simply normal variation in
emissions from well-controlled charging ventilation systems.
The THC emission rate from the higher of the two sources
tested was less than 1 percent of the THC emissions from the
blast furnace charging chute at which the potential emission
problem was first detected.
Based on these test results, the EPA is proposing a THC
emissions limit for blast furnace charging process fugitive
emissions of 0.20 kg/hr (0.44 lb/hr), which was the highest
THC value obtained during the test runs and was selected to
account for normal variation in THC emissions. The EPA THC
data from blast furnace charging are presented in chapter 3
and appendix A of the BID.
3. Fugitive Dust Sources
The proposed standard requires an SOP manual for the
control of fugitive dust emissions and also establishes a
lead emissions limit for building and enclosure ventilation
systems.
a. SOP Manual. The EPA is proposing that each smelter
develop an SOP manual that would describe the controls and
work practices that would be implemented to control fugitive
dust emissions. These control and work practices would be
equivalent to those specified in the proposed regulation.
The EPA selected the controls in the proposed regulation on
the basis of observations made during visits to smelters
that had already implemented fugitive dust controls
equivalent to the proposed MACT and on the basis of a
technical analysis of the effectiveness of different control
options (Docket No. A-92-43, Item No. II-B-28).
The use of a site-specific SOP manual is being
proposed, rather than a list of required work practices,
because there are several equivalent control options
available for fugitive dust. The flexibility of the SOP
approach is needed because the best control option for a
particular smelter would be determined by the physical
layout of the smelter and the control measures that are
already in place. These two factors vary greatly among
smelters.
b. Lead Emissions Limit. The EPA is proposing a lead
emissions limit of 2.0 mg/dscm (0.00087 gr/dscf) for
ventilation systems for buildings that enclose fugitive dust
sources, such as the materials storage and handling area or
the furnace and refining and casting areas. This limit was
selected on the basis of controlled lead emissions from the
process fugitive baghouses (which also controlled some
building ventilation emissions) measured during the EPA
testing program and is the same limit that was selected for
process and process fugitive sources.
F. Reconstruction Considerations
Section 112(a) of the Act defines a new source as a
stationary source, the construction or reconstruction of
which is commenced after the proposal date of a relevant
regulation. An existing source is defined as any stationary
source other than a new source.
Reconstructed sources are considered to be new sources.
Reconstruction means the replacement of components of an
existing source to such an extent that: (1) The fixed
capital cost of the new components exceeds 50 percent of the
fixed capital cost that would be required to construct a
comparable new source, and (2) it is technologically and
economically feasible for the reconstructed source to meet
all relevant promulgated standards for new sources.
Some changes can be made at secondary lead smelters
that may be deemed reconstructions under section 63.5 of the
General Provisions. However, the proposed standards for
secondary lead smelters are the same for both existing and
new sources except in the case of the THC emission limit for
blast furnace-only configurations. As a result, the
designation as a "reconstruction" has limited practical
significance. If a change to an existing blast furnace is
determined to constitute a reconstruction, then that furnace
would be subject to the proposed THC limit for new blast
furnaces, which is more stringent than the limit for
existing blast furnaces. In order to meet the more
stringent THC limit, a reconstructed blast furnace would
probably need to install a new afterburner that could reach
a temperature of 870 oC (1,600 oF), based on the proposed
MACT for new blast furnaces.
G. Selection of Compliance Dates
The proposed regulation would require owners or
operators of existing secondary lead smelters to achieve
compliance with the proposed standards within 24 months of
promulgation. This schedule would allow the affected
sources the time necessary to modify existing processes and
control equipment; design, fabricate, and install new
control equipment as needed; develop and implement the SOP
for equipment and work practice standards; and complete
installation of all required continuous monitoring systems.
The proposed 2-year period for existing sources to
achieve compliance with the proposed standard is based on
the estimated time needed for a blast furnace facility to
have a new afterburner designed, fabricated, installed, and
tested. The installation of a new afterburner is the most
significant upgrade anticipated under the proposed standard.
The EPA believes that a 2-year period is realistic and
practical to accomplish these required tasks. The proposed
standard is also consistent with compliance deadlines
allowed by section 112(i) of the Act, which allows existing
sources up to 3 years to achieve compliance.
Owners or operators of new secondary lead smelters
would be required to achieve compliance upon startup or
promulgation of this NESHAP (whichever is later) and must
perform compliance testing within 6 months of startup or
promulgation, pursuant to sections 63.6 and 63.7 of the
General Provisions.
H. Selection of Emission Test Methods and Schedule
Testing requirements are being proposed for lead, THC,
and HCl/Cl2 from process, process fugitive, and fugitive
dust sources.
1. Process Sources
Lead emissions from process emission control devices
would be measured using EPA reference method 12, THC
emissions would be measured using EPA reference method 25A,
and HCl/Cl2 emissions would be measured using EPA reference
method 26A. For all of these tests, EPA reference method 1
would be used to determine the number and locations of
sampling points, method 2 would be used to determine stack
gas velocity and volumetric flow rate, method 3 would be
used for flue gas analysis, and method 4 would be used to
determine the volume percent moisture content in the stack
gas. For the measurement of THC and HCl/Cl2, the Single
Point Integrated Sampling and Analytical Procedure of
method 3B would be used to measure CO2 in order to correct
for excess air or dilution.
Each test would consist of three runs conducted under
representative operating conditions. The average of the
three runs would be used to determine compliance. The test
methods selected above were used by the EPA to collect the
data upon which the proposed emission limits are based.
The proposed standard would require initial tests of
lead emissions from all sources and annual compliance tests
for process fugitive sources and building ventilation
systems. Annual tests of the latter two sources must be
performed because compliance with the lead emission standard
cannot be continuously monitored. The proposed standard
would also require initial compliance tests for THC and
HCl/Cl2 and then monitoring to demonstrate continuous
compliance. Following the initial THC compliance test, no
annual compliance test would be required if the facility
maintains or exceeds the minimum afterburner temperature
established during the initial compliance test. Following
the initial HCl compliance test, no annual compliance test
would be required if the facility maintains the required
level of fluxing, scrubber parameters, or SO2 concentration
established during the initial compliance test or operates
and maintains an HCl monitor.
2. Process Fugitive Sources
An annual compliance test for lead using the same
methods as for process sources would be required for process
fugitive control devices. If a facility is subject to the
THC emission limit for blast furnace charging, then an
initial test would be required that would use the same THC
measurement methods as for process sources.
Compliance with the face velocity and flow rate
requirements for enclosure hoods over process fugitive
emission sources would be determined by measuring the flow
in the duct leading from the source and by measuring the
area of the openings in the hood and the area of the
refining kettle, if appropriate. Volumetric flow rate in
the duct would be measured using EPA reference method 2.
Hood face area or kettle surface area would be measured
directly.
There are no EPA reference methods for directly
measuring the face velocity of a hood. The use of a hand-
held anemometer was evaluated, but this technique is not as
accurate or as precise as calculating the face velocity from
the measured volumetric flow rate and face area.
3. Fugitive Dust Sources
Compliance with the lead emission standard for building
ventilation emission points would be determined using the
same methods as for process sources. Compliance would be
determined through an annual test of each emission point,
except in the case of emissions from identical control
devices that are discharged through separate stacks.
If a facility has two or more identical control devices
for building ventilation, then each would be required to
undergo an initial compliance test. Subsequent compliance
tests, however, could be alternated or rotated among the
identical control devices so that not all of them would be
tested every year. However, at least one device would be
tested each year and each device would be tested at least
once every 5 years. This provision assumes that the
maintenance of identical units would be similar as a result
of the baghouse inspection and logging procedures in the
monitoring requirements of the proposed standard. In
addition, smelters would only be allowed to alternate
compliance testing as long as they demonstrate compliance
with the baghouse inspection and logging provisions of the
proposed monitoring requirements. This provision is being
proposed to reduce unnecessary testing costs. This
provision would not apply to control devices receiving
emissions from process or process fugitive sources.
I. Selection of Proposed Enhanced Monitoring
Requirements
Section 114(a) of the Act, as amended under
section 702(b) of title VII of the 1990 amendments, requires
enhanced monitoring and the submission of periodic
compliance certifications for all major stationary sources.
Compliance certifications shall include information on the
methods used for determining compliance status and
statements as to whether compliance was determined on an
intermittent or continuous basis.
The enhanced monitoring requirements proposed herein
were determined by examining the hierarchy of monitoring
options available for specific processes, pollutants, and
control equipment. This hierarchy may range from monitoring
continuously the emissions of a specific pollutant or
pollutant class to the continuous monitoring of a related
process or control device parameter. Each option was
evaluated relative to its technical feasibility, cost, ease
of implementation, and relevance to its underlying process
emission limit or control device.
The proposed standards for secondary lead smelters
contain monitoring requirements for process sources, process
fugitive sources, and fugitive dust sources. The proposed
standards require either pollutant monitoring directly
through the use of a CEM, parameter monitoring that
indicates proper operation and maintenance of a control
device, or recordkeeping to ensure that specific work
practices are being followed.
1. Process Sources
Monitoring requirements are being proposed to ensure
control of metal HAP, organic HAP, and HCl/Cl2 emissions
from process sources.
a. Metal HAP's. The EPA is proposing that each
process baghouse be monitored with a COM and that a site-
specific opacity limit be established for each process
emission point. The site-specific opacity limit for an
affected baghouse would be equal to the maximum 6-minute
opacity reading recorded by a COM during the initial
compliance test for lead emissions, plus 2 percent opacity
to allow for normal drift in the output from the COM.
Exceedance of the site-specific opacity limit would
constitute a violation of the standard for lead emissions.
The proposed MACT for the control of metal HAP's is a
baghouse of the design now used in the industry that is
operated and maintained optimally on a continuous basis.
The facilities at which baghouses were assessed in the EPA
testing program had comprehensive, periodic inspection and
maintenance programs to ensure proper operation of the
baghouses. However, these inspection and maintenance
program are relatively costly to implement, and offer no
explicit assurance that the emission limitations in the
standards are being achieved on a continuous basis.
Emissions from a baghouse change with time as a result
of incidental or periodic upsets (e.g., torn bags) and
normal wear of baghouse components. Inspection and
maintenance programs aid in protecting against slow,
continual degradation of baghouse performance but do not
ensure continuous optimal operation. Although inspection
and maintenance may indicate a baghouse is functioning
normally, there is no assurance that an established emission
limitation is being achieved. Furthermore, these programs,
if sufficiently comprehensive to ensure the baghouse is
performing optimally on a continuous basis, are labor-
intensive and, as noted, quite costly.
The EPA estimates that with a good inspection and
maintenance program a baghouse may still emit, on average,
an emission stream with an opacity of 5 or 10 percent.
Several theoretical and experimental studies have been
performed to quantify the relationship between the PM
concentration in an emissions stream and the opacity of the
stream. From such a relationships developed at a secondary
brass/lead smelter, it is estimated that gases in a stack
with a 1.5 meter diameter exhibiting an opacity of
10 percent could contain as much as 80 mg/dscm PM. Given
that the PM discharged from process baghouses at secondary
lead smelters typically contains about 25 percent lead, the
lead concentration of the baghouse discharge corresponding
to 10 percent opacity would be 20 mg/dscm. This is 10 times
the pollutant concentration of the proposed standard
(Docket No. A-92-43, Item No. II-A-35).
In contrast, the use of COM's offer a timely, sensitive
and direct indication of increased emissions. They give an
immediate indication of an occurrence, which provides for
timely action that will minimize the duration and,
therefore, the emissions, of an upset. They can also
address the long-term gradual deterioration of performance
of a baghouse.
In addition, COM's are cost-effective. A typical,
generally available monitor with auxiliaries costs about
$37,300 to install and about $16,500 to operate annually.
Proper usage of a COM can ensure that the gases emitted from
a baghouse exhibit less than 2 percent opacity on average
over a year (Docket No. A-92-43, Item No. II-B-34. The
approximate cost-effectiveness of reducing the average
opacity from 10 percent to 2 percent through the use of a
COM is $2,100 per ton of lead or $525 per ton of PM.
The EPA invites comments on the reasonableness of
incorporating this strategy for COM into the final standard
promulgated for this source category.
b. Organic HAP's. The EPA is proposing two monitoring
options that smelter operators may pursue. Continuous
monitoring systems are available for THC, but the operating
and maintenance costs of existing systems may be prohibitive
for many sources in this category. Alternatively, operators
may continuously monitor afterburner or exhaust stream
temperature, which correlates strongly with THC emissions,
after conducting an initial performance test to demonstrate
compliance with the THC standard.
Under the second option, THC and temperature would have
to be measured simultaneously for three runs lasting 1 hour
each during the initial THC compliance test. The average
THC concentration and temperature would be determined for
the total sampling period. Compliance with the THC standard
would be determined on the basis of the average THC
concentration. The minimum allowable afterburner or exhaust
temperature would be determined on the basis of the average
temperature during the total sampling period. To remain in
compliance, the owner or operator could not allow the
average temperature for any 3-hour period to fall more than
28 oC (50 oF) below the average measured during the initial
THC compliance test. Allowing the average temperature to
fall below this level would constitute a violation of the
emissions standard.
The proposed allowable temperature range of 28 oC
(50 oF) for the afterburner or combined reverberatory/blast
exhaust streams is based on temperature data collected
during the organic HAP and THC testing performed by the EPA.
During the test of the blast furnace, the 3-hour average
temperature of the afterburner varied over a range of 32 oC
(59 oF). During the test of the reverberatory/blast furnace
configuration, the 3-hour average temperature of the
combined exhaust stream varied over a range of 29 oC
(52 oF). The proposed 28 oC (50 oF) allowable temperature
range is consistent with the range allowed in the monitoring
requirements for sources controlled by afterburners in other
Federal standards (40 CFR part 60, subparts EE, MM, SS, TT,
WW, BBB, DDD, FFF, III, NNN, QQQ, SSS, and VVV).
Another THC compliance test would be required if the
operator desires to establish a lower afterburner
temperature. Owners or operators also have the option of
monitoring THC using a CEM instead of temperature.
c. HCl and Chlorine. Continuous emission monitors are
available for HCl, but they have not been used in this
industry. Furthermore, the estimated capital and annual
costs of these CEM's for the entire industry would be
$2,900,000 and $1,400,000, respectively. The cost of
requiring an HCl CEM would double the capital and annual
cost impacts of the proposed standards and would increase
the number of facilities that are significantly impacted.
Other, less costly monitoring options are available, so the
EPA has determined that an HCl CEM should not be required
and several alternative monitoring options are being
included in the proposed standard. However, these
alternatives allow the use of an HCl CEM to fulfill the
monitoring requirements for HCl/Cl2, if an operator chooses
to use one.
Where SO2 scrubbers are used, continuous emission
monitoring for SO2 can be used as an indicator of scrubber
performance. Alternatively, scrubber parameters, including
sorbent injection rate and pH, can also be monitored as
indicators of scrubber performance. Where fluxing with soda
ash or limestone is used to preclude HCl/Cl2 emissions,
monitoring the use of these fluxing agents can ensure that
sufficient quantities are being added to control emissions.
The EPA is therefore proposing four alternative
monitoring options for control of HCl/Cl2: (1) manual
monitoring of the addition of soda ash and limestone,
(2) instrument monitoring of scrubber parameters, (3) CEM
for SO2, or (4) CEM for HCl. Each of these alternatives is
described below.
Option 1. Owners or operators could monitor the
amounts of soda ash and limestone added to the smelting
furnace and the total amount of charge material added during
the 8-hour shift in which the initial HCl/Cl2 compliance
test was performed. This ratio of soda ash and limestone to
total charge material would establish a minimum ratio that
would be maintained thereafter. A new HCl/Cl2 compliance
test would be required if the operator wanted to alter the
amount or type of fluxing agent to be used in the future.
Continued compliance would be determined on the basis of the
ratio of soda ash and limestone to total charge material
added to the furnace during each 8-hour shift thereafter.
Failure to maintain the same ratio would constitute a
violation of the HCl/Cl2 standard.
Option 2. The owner or operator of a facility that has
a scrubber to control HCl and Cl2 could record the scrubber
liquid injection rate and pH every 15 minutes during the
initial HCl/Cl2 compliance test, which consists of three
1-hour runs. The average of these recorded values for pH
and media injection rate would be used to establish minimum
operating parameters for the scrubber that must be
maintained thereafter. Failure to maintain the minimum
scrubber media injection rate or minimum inlet pH would
constitute a violation of the HCl/Cl2 standard.
The media injection rate would be recorded every
15 minutes after the HCl compliance test and could be no
less than 70 percent of the average injection rate
demonstrated during the initial HCl compliance test. No
data were collected during the EPA tests on the variability
of SO2 scrubber media injection rates. The proposed
30-percent allowable drop in media injection rate is adopted
from the range allowed in the monitoring requirements in
other Federal standards (40 CFR part 60, subparts LL, OOO,
and PPP) for sources controlled by wet scrubbers.
The standards in subparts LL, OOO, and PPP are for
control of PM sources, not acid gases. Therefore, the EPA
is also considering allowing no drop in liquid injection
rate, but has not included that requirement in the proposed
regulation. The EPA solicits comment on the appropriateness
of allowing a 30-percent drop in liquid injection rate.
The scrubber media inlet pH would also be recorded
every 15 minutes and the 3-hour average could be no more
than 1.0 pH points below the average inlet pH demonstrated
during the initial HCl/Cl2 compliance test. The allowable
pH range of 1.0 for the scrubber media inlet pH is based on
data collected during the HCl/Cl2 testing performed by the
EPA. During the EPA test of the blast furnace, the 3-hour
average pH of the sorbent at the SO2 scrubber inlet varied
from 7.7 to 8.3, a range of 0.6. At the reverberatory/blast
furnace tested, the pH of the sorbent at the SO2 scrubber
outlet showed a similar pH range. An allowable pH range of
1.0, rather than 0.6, is being proposed because HCl and Cl2
are absorbed more easily than SO2, and control of HCl and
Cl2 would not vary significantly over a scrubber sorbent pH
range of 1.0.
Option 3. The owner or operator of a facility that
operates an SO2 scrubber could record the SO2 concentration
every 15 minutes during the initial HCl/Cl2 compliance test.
The average of these recorded values for SO2 concentration
would be used to establish a 3-hour average maximum SO2
concentration that could not be exceeded thereafter. The
SO2 concentration would be recorded every 15 minutes and the
average for any 3-hour period could be no more than 200 ppmv
above the average SO2 concentration measured during the
initial HCl/Cl2 compliance test. A 3-hour average SO2
concentration exceeding the maximum SO2 concentration would
constitute a violation of the HCl/Cl2 standard.
The allowable SO2 range is based on data collected
during the HCl/Cl2 testing performed by the EPA. During the
test of the reverberatory/blast furnace configuration, the
3-hour average SO2 concentration, as recorded by the
facility's SO2 CEM, ranged from 37 ppmv to 195 ppmv. During
the test of the blast furnace, the 3-hour average SO2
concentration ranged from 0 ppmv to 50 ppmv. An allowable
range of 200 ppmv above the average SO2 concentration
measured during the initial HCl/Cl2 compliance test is being
proposed to reflect the range of SO2 concentrations measured
and the fact that HCl and Cl2 are absorbed more easily than
SO2.
Option 4. The owner or operator could also install,
operate, and maintain an HCl CMS and demonstrate compliance
with an initial HCl/Cl2 compliance test and by meeting all
of the requirements for CMS's found in the General
Provisions. The CO2 concentration needed to correct for
dilution would be determined during the initial HCl/Cl2
compliance test and would not need to be continuously
monitored. To remain in compliance, the HCl concentration
measured by the CMS and corrected to 4 percent CO2 must
remain below an HCl limit of 15 mg/dscm.
The HCl limit of 15 mg/dscm for enhanced monitoring was
based on the results of the EPA-sponsored HCl/Cl2 testing.
These tests indicated that about 98 percent of the chlorine
was emitted as HCl.
2. Process Fugitive Sources
The proposed MACT for control of metal HAP emissions
from process fugitive sources is an enclosure-type hood
ventilated to a baghouse. When these hoods are in place and
the smelter has demonstrated compliance with the proposed
face velocity and flow rate requirements, no further
monitoring of capture efficiency would be necessary.
Similarly, the proposed MACT for control of organic HAP
emissions from blast furnace charging is proper balance
between the blast furnace charging and primary exhaust
ventilation systems. No monitoring of blast furnace
charging would be necessary after compliance has been
demonstrated with the THC limit for blast furnace charging.
As noted previously, no CMS's are available for lead.
In addition, a COM cannot be used to monitor process
fugitive baghouse performance because the opacity of
uncontrolled process fugitive emissions is too low to
indicate a control device failure. Therefore, the proposed
standard would require daily, weekly, and monthly inspection
of process fugitive baghouses and would require monitoring
the pressure drop and water flow rate of PM scrubbers.
Scrubbers are used instead of baghouses at some smelters to
control process fugitive sources.
The majority of smelters already perform regular
inspections of baghouses and monitor scrubber operating
parameters as part of normal baghouse and scrubber operation
and maintenance. These monitoring requirements would ensure
that the control devices are being operated and maintained
in a manner consistent with good air pollution control
practices. These monitoring requirements are being proposed
as separately enforceable standards. However, a violation
of the proposed monitoring requirements could not be used to
indicate a violation of the proposed lead emissions limit
for process fugitive sources. Therefore, the proposed
standard would also require an annual compliance test of
lead emissions.
The proposed baghouse inspection program is the only
monitoring option available for process fugitive sources
controlled by baghouses at secondary lead smelters. This
proposed requirement is not intended to serve as a model of
monitoring requirements for other source categories of
particulate or HAP emissions controlled by baghouses.
3. Fugitive Dust Sources
Monitoring of compliance with the work practice
controls for fugitive dust sources specified in each
smelter's SOP manual would be accomplished through
recordkeeping requirements that would also be specified in
the SOP.
A COM is not applicable to the building and enclosure
ventilation emission points that are subject to the lead
emissions limit. The proposed standard, therefore, would
require a baghouse inspection program and an annual
compliance test of lead emissions for the same reasons as
those described above for process fugitive baghouses.
J. Selection of Notification Requirements
Owners or operators of secondary lead smelters would be
required to comply with all of the notification requirements
under section 63.9 of the General Provisions. An owner or
operator would be required to submit the initial
notification, notifications of performance tests,
notification of CMS performance evaluations, and the
notification of compliance status. Information submitted in
these notifications would confirm that the source is subject
to the standards and establish the source's compliance
status.
Each operator of a smelter would also be required to
submit the fugitive dust control SOP manual to the
Administrator or his or her authorized representative, along
with a notification that the smelter is seeking review and
approval of the manual. Operators of existing smelters
would be required to submit the manual no later than 180
days before the compliance date for existing smelters.
Operators of new smelters would be required to submit the
manual no later than 180 days before startup of the new
smelter but no sooner than the effective date of the
proposed standard.
The notification of compliance status would list the
results of any performance tests and opacity measurements,
methods used for determining continuous compliance,
descriptions of the air pollutant control equipment and
methods applied at each affected emission point, and a
statement as to whether the source is in compliance with all
relevant standards and provisions of this subpart. The
proposed regulation would waive the requirement that the
smelter perform an analysis demonstrating whether the
smelter is a major source or area source since the
regulation would apply equally to all smelters. The
compliance notification would also certify that the facility
has completed an SOP manual for the control of fugitive dust
emissions and that the SOP manual has been approved by the
Administrator.
K. Selection of Recordkeeping and Reporting
Requirements
The recordkeeping and reporting requirements of the
General Provisions for 40 CFR part 63 would apply to
secondary lead smelters unless specifically superseded in
this part.
1. Recordkeeping
Consistent with the General Provisions of part 63 and
with the operating permit rules in part 70, promulgated
under title V of the Act, records required by this part
would be retained for at least 5 years. Each affected
source would be required to maintain records of the results
of compliance tests for each of the proposed emission
limits, including THC, lead, and HCl/Cl2. These records are
necessary to document the initial compliance determination
with these standards. If a smelter is subject to the
proposed emission standards for THC and must monitor
afterburner or exhaust stream temperature to comply with the
proposed enhanced monitoring requirements, then records of
the afterburner or exhaust stream temperature would be
maintained. These records could be in the form of strip
charts or digital printouts, with the period between
measurements not to exceed 15 minutes. A block average
temperature would be recorded every 3 hours. These records
would be used by an affected source to demonstrate
continuous compliance with the THC standards.
The source would be required to maintain records
explaining any periods when the monitored afterburner
temperature dropped below the minimum established during the
facility's initial THC compliance test. Maintenance records
of the afterburner temperature monitor would also be
required pursuant to section 63.10 of the General
Provisions. All secondary lead smelters that currently
operate afterburners already monitor and record afterburner
temperature as part of normal afterburner operation and
maintenance. Therefore, the incremental burden associated
with these proposed recordkeeping requirements for
temperature are considered minimal.
Each source would be required to maintain records of
opacity, as measured by a COM and in terms of 6-minute
averages. Records would also be maintained of any
exceedances of the site-specific opacity limit and any
corrective actions following those exceedances. Maintenance
records of the opacity monitor probes would also be
maintained, including records of periodic cleaning and
replacements and calibration checks, pursuant to
section 63.10 of the General Provisions. These records
would be used to demonstrate continuous compliance with the
opacity standard.
Each source would also be required to maintain records
consistent with the enhanced monitoring approach chosen for
controlling HCl/Cl2 emissions to ensure that the source is
in continuous compliance with the HCl/Cl2 standard. If an
owner or operator chooses to rely on fluxing as a control
for HCl/Cl2, records of the soda ash or limestone added to
the smelting furnace and the total amount of material
charged would have to be maintained. The amount of fluxing
agent added and material charged would be recorded on a
total-per-shift basis. Most smelters already maintain
records of fluxing agents added to the furnace and material
charged as a normal part of production and quality control.
Consequently, the incremental burden associated with this
recordkeeping requirement would be minimal.
If a source operates an acid gas scrubber and the owner
or operator chooses to control HCl and Cl2 with the scrubber
rather than through fluxing, then the source would be
required to either (1) maintain records of scrubber media
injection rate and pH, or (2) maintain records of SO2
concentrations measured continuously with a CMS. Most
sources with scrubbers already maintain records of media
injection rate and pH as part of normal scrubber operation,
as well as CMS's for SO2. If a source operates a CMS for
HCl, it would maintain records of HCl concentration.
Records would also be maintained of fugitive dust
control activities, as required by each smelter's SOP.
2. Reporting
Owners or operators of secondary lead smelters would be
required to comply with all of the reporting requirements
under section 63.10 of the General Provisions. They would
be required to report the results of performance tests and
CMS performance evaluations, and to submit quarterly excess
emissions and CMS performance reports or summary reports.
These quarterly reports would include summaries (e.g.,
3-hour averages) of the records required to demonstrate
continuous compliance with the proposed standards. These
reports would also contain summaries of the records that are
required to demonstrate continuous compliance with the
fugitive dust control measures described in the source's SOP
manual, including an explanation of the periods when the
procedures outlined in the SOP were not followed.
The Administrator believes that excess emissions and
compliance parameter monitoring reports are a critical
enforcement tool. Therefore, the proposed standard would
require quarterly, rather than semi-annual reports.
However, pursuant to section 63.10(e)(3)(ii) of the General
Provisions, sources may request to reduce reporting
frequency after they can demonstrate continuous compliance
for a one-year period.
L. Operating Permit Program
Under title V of the Act, all HAP-emitting sources
would be required to obtain an operating permit.
Oftentimes, the emission limits and the requirements for
monitoring, reporting, and recordkeeping for a facility are
scattered among numerous provisions of State Implementation
Plans or Federal regulations. As discussed in the final
rule for the operating permit program, published on July 21,
1992 (57 FR 32295), an operating permit under this new
permit program will include all of the requirements that
pertain to a single source in a single document.
After a State's permit program has been approved, each
secondary lead smelter within that State must apply for and
obtain an operating permit. If the State where the
secondary lead smelter is located does not have an approved
permitting program, the owner or operator must submit the
application under the General Provisions of 40 CFR part 63.
The addresses for the EPA Regional Offices and States are
included in the General Provisions.
M. Whether to Also Regulate Air Emissions Under RCRA
As noted earlier, air emissions from secondary lead
smelting furnaces are also potentially subject to regulation
under RCRA because the battery and other lead-bearing
secondary feed is often classified as a hazardous waste
because of lead content. These emissions are presently
exempt from regulation [40 CFR part 266.100(c)], but the EPA
is considering whether RCRA controls are necessary as part
of this rulemaking. The EPA has agreed to reexamine the
appropriateness of the exemption as part of a settlement
agreement in Horsehead Resources Inc. v. Browner,
No. 92-1221. The settlement agreement provides that the EPA
may issue revised regulatory standards under the Act alone,
under RCRA, or under both statutes.
The EPA is proposing to continue exempting air
emissions from secondary lead smelting furnaces from RCRA
essentially because the EPA believes these emissions will be
comprehensively and adequately regulated under the
section 112 rules proposed here, plus the subsequent
residual risk determination. Although the RCRA standard for
regulation ["as may be necessary to protect human health and
the environment", RCRA section 3004 (a)] differs from the
initial technology-based regime of section 112 of the Act,
the EPA does not believe that further RCRA regulation of air
emissions is necessary. The reasons are that: (1) The
proposed MACT optimizes control of the principal HAP
contributed by the hazardous waste (i.e. lead-bearing feed,
as opposed to fossil fuels) processed by the source by
imposing the best pollution control technology for the
principal HAP--lead compounds--emitted from these sources;
(2) all secondary lead smelters (both major and area
sources) would be controlled by the proposed standards;
(3) the proposed standards control not only stack emissions,
but facility-wide fugitive emissions; (4) organic HAP's are
controlled as well, and emissions of chlorinated organic
HAP's (such as PCDD's and PCDF's) are minimal; and (5) HCl
and Cl2 emissions are controlled as well. To the extent any
significant residual risk remains after MACT standards are
implemented, the risk will be addressed through the
section 112 (f) residual risk process. Consequently, the
EPA believes that RCRA regulation of air emissions from
these sources should not be required.
In this regard, it is important to remember that RCRA
section 1006 requires the Agency to "integrate all
provisions of [RCRA] for purposes of administration and
enforcement and ...avoid duplication, to the maximum extent
practicable, with the appropriate provisions of the Clean
Air Act....". The EPA believes that imposition of RCRA air
emission standards for these sources could result in the
types of unnecessary duplication that section 1006 is
intended to prevent. Accordingly, the Agency is proposing
to retain the current regulatory exemption from RCRA
regulation for air emissions from secondary lead smelters.
There is also a second potential area of overlap
between RCRA standards and the proposed MACT standards.
This is with respect to strategy units that are presently
regulated under RCRA. The EPA believes that the controls
for fugitive dust emissions proposed in this rule [proposed
sections 63.545(c)(2) and (c)(5) in particular] are
consistent with, and complement, the existing RCRA
standards. The RCRA standards are directed largely at
preventing releases of waste to land and groundwater, and so
would be complemented by the proposed rules, which are
directed to preventing exposure via an air exposure pathway.
In addition, the provisions of the RCRA rules preventing air
emissions are consistent with the standards proposed today.
For example, section 264.1101(c)(1)(iv) prevents fugitive
dust emissions from containment buildings by prohibiting
visible emissions and achieves the same emission control
objective of the fugitive dust control standards being
proposed today. The Agency solicits comment, however, to
ensure that none of the requirements for RCRA storage units
are incompatible with the standards proposed today.
N. Solicitation of Comments
The EPA welcomes comments on all aspects of the
proposed standards and specifically solicits comments on the
following: (1) The determination by the EPA that area
sources in the category present a threat of adverse effects
to human health and therefore should be regulated; (2) the
use of fluxing agents to eliminate HCl and Cl2 emissions
from smelting furnaces, including the technical feasibility
of this approach, any adverse impacts on smelting
operations, and its effectiveness in reducing HCl/Cl2
emissions; (3) the feasibility and impacts of establishing a
THC limit for existing blast furnaces based on an
afterburner temperature above that identified as the MACT
floor (700 oC); and (4) the proposed enhanced monitoring
requirements, including the proposed strategy of
establishing a site-specific opacity limit concurrent with
the initial lead compliance test. Comments on these aspects
of the standards will be most useful if they contain
specific information and data pertinent to an evaluation of
the magnitude and severity of the impact(s) and suggested
alternative courses of action that would avoid the
impact(s).
VII. Administrative Requirements
A. Public Hearing
A public hearing will be held, if requested, to discuss
the proposed standards for secondary lead smelters, in
accordance with section 307(d)(5) of the Act. Persons
wishing to make an oral presentation at a public hearing
should contact the EPA at the address given in the ADDRESSES
section of this preamble. Oral presentations will be
limited to 15 minutes each. Any member of the public may
file a written statement before, during, or within 30 days
after the hearing. Written statements should be addressed
to the Air Docket Section address given in the ADDRESSES
section of this preamble and should refer to Docket
No. A-92-43. A verbatim transcript of the hearing and
written statements will be available for public inspection
and copying during normal working hours at the EPA's Air
Docket Section in Washington, D.C. (see ADDRESSES section of
this preamble).
B. Docket
The docket is an organized and complete file of all the
information submitted to, or otherwise considered by, the
EPA in the development of this proposed rule. The principal
purposes of the docket are to: (1) Allow interested parties
to readily identify and locate documents so they can
intelligently and effectively participate in the rulemaking
process, and (2) serve as the record in case of judicial
review, except for interagency review materials
[section 307(d)(7)(a) of the CAA].
C. Executive Order 12866
Under Executive Order 12866 (58 FR 5173, October 4,
1993), the EPA must determine whether a regulatory action is
"significant" and, therefore, subject to Office of
Management and Budget (OMB) review and the requirements of
the Executive Order. The Order defines "significant"
regulatory action as one that is likely to lead to a rule
that may: (1) Have an annual effect on the economy of
$100 million or more, or adversely and materially affect a
sector of the economy, productivity, competition, jobs, the
environment, public health or safety, or State, local, or
tribal governments or communities; (2) create a serious
inconsistency or otherwise interfere with an action taken or
planned by another agency; (3) materially alter the
budgetary impact of entitlements, grants, user fees, or loan
programs or the rights and obligation of recipients thereof;
or (4) raise novel legal or policy issues arising out of
legal mandates, the President's priorities, or the
principles set forth in the Executive Order.
The proposed regulation presented in this notice was
submitted to the OMB for review. Any written EPA response
to those comments are included in the docket listed at the
beginning of today's notice under ADDRESSES. The docket is
available for public inspection at EPA's Air Docket Section,
which is listed in the ADDRESSES section of this preamble.
D. Paperwork Reduction Act
The information collection requirements in this
proposed rule were submitted for approval to OMB under the
Paperwork Reduction Act, 44 U.S.C. 3501 et seq. An
Information Collection Request document was prepared by the
EPA (ICR No. 1686.01), and a copy may be obtained from
Sandy Farmer, Information Policy Branch, U.S. Environmental
Protection Agency, 401 M Street, S.W. (2136), Washington,
D.C. 20460, or by calling (202) 260-2740. The public
reporting burden for this collection of information
(including emission testing) is estimated to average
1,200 hours per smelter for reporting in the first year in
which compliance is demonstrated and 550 hours per year for
subsequent years, and to require 210 hours annually per
smelter for recordkeeping. These estimates include time for
reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing
and reviewing the collection of information.
Send comments regarding the burden estimate or any
other aspect of this collection of information, including
suggestions for reducing this burden, to Chief, Information
Policy Branch, 2136, U.S. Environmental Protection Agency,
401 M Street, S.W., Washington, D.C. 20460, and to the
Office of Information and Regulatory Affairs, Office of
Management and Budget, Washington, D.C. 20503, marked
"Attention: Desk Officer for EPA." The final rule will
respond to any OMB or public comments on the information
collection requirements contained in this proposal.
E. Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.)
requires the EPA to consider potential impacts of proposed
regulations on small business entities. If a preliminary
analysis indicates that a proposed regulation would have any
economic impact on any small entities, then a regulatory
flexibility analysis must be prepared.
Present Regulatory Flexibility Act guidelines indicate
that an economic impact should be considered significant if
it meets one of the following criteria: (1) Compliance
increases annual production costs by more than 5 percent,
assuming costs are passed on to consumers; (2) compliance
costs as a percentage of sales for small entities are at
least 10 percent more than compliance costs as a percentage
of sales for large entities; (3) capital costs of compliance
represent a significant portion of capital available to
small entities, considering internal cash flow plus external
financial capabilities; or (4) regulatory requirements are
likely to result in closure of small entities. Based on
discussions with technical support experts, the EPA
formulated alternative criteria for the determination of
significant impacts in the secondary lead industry. The
guidelines were discussed in the economic impacts section of
this preamble.
The results of an economic assessment indicated that
the proposed rule will have an economic impact on small
business entities. However, adverse economic impacts have
been minimized to the greatest extent possible in this rule
making, and those that remain are unavoidable. All of the
small entities that are currently operating and that are
impacted are major sources of HAP's for which the EPA is
required to propose MACT standards. Consequently, the
economic impacts can not be minimized by proposing less
stringent standards based on GACT. The standards being
proposed in this rule making are based on MACT floor
controls, and in no instance did the EPA choose to propose
standards based on controls more stringent than the floor.
The EPA was also able to identify alternatives to add-on
controls (e.g., process modifications and work practices) in
the MACT floors that offered equivalent levels of control.
The EPA has minimized the impacts associated with monitoring
by adopting a surrogate pollutant approach and by allowing
for alternative monitoring strategies when available.
Finally, the EPA has minimized the impacts associated with
recordkeeping and reporting by proposing only the minimum
requirements needed to document continuous compliance with
the proposed emission limits.
F. Pollution Prevention Considerations
Pollution prevention/source reduction is the use of
process modifications or alternative processing technologies
to reduce air pollutant emissions from the source, rather
than through the use of add-on controls. Several pollution
prevention and source reduction options were considered for
application to the secondary lead smelter industry in this
rulemaking. These options are described in more detail in
chapter 3 of the BID.
1. Emission Prevention Through Electrowinning
Electrowinning is a process to recover lead metal by
dissolving lead compounds in acid and then depositing lead
metal on a cathode in an electrolytic cell. Electrowinning
is being developed as an alternative to the use of smelting
furnaces to reduce lead compounds to lead metal.
Electrowinning would reduce potential emissions of metal
HAP's, organic HAP's, and HCl/Cl2. This process is still
experimental and has not been demonstrated on a commercial
basis anywhere in the world. However, the proposed
standards would not prevent a smelter from pursuing this
technology. The proposed standards for process sources are
in the form of emission limits and operators may use any
technology that can achieve the emission limit. There are
no design, equipment, or work practice requirements that
would discourage or prohibit the use of this technology.
2. Organic HAP and HCl/Chlorine Emission Prevention
Through Plastic Removal
Plastic battery separators are sources of organic HAP
and HCl/Cl2 emissions from smelting furnaces. Technology is
available to remove these materials from the furnace feed
material and this may decrease organic HAP and HCl/Cl2
emissions. However, no data are available to confirm such a
decrease and the recycling options for the recovered
material are limited. Material that is not recycled would
need to be disposed of as hazardous waste if it is
contaminated with lead. However, the proposed standards
would not prevent a smelter from pursuing this option.
3. HCl and Chlorine Emission Prevention Through
Fluxing
Soda ash or limestone can be added to a smelting
furnace to prevent emissions of HCl and Cl2. The use of
fluxing agents would avoid the need for a wet scrubber and
the solid waste and wastewater impacts associated with a wet
scrubber. This practice is currently in use in the
secondary lead industry and is incorporated in the proposed
regulation.
4. HCl and Chlorine Emission Prevention Through
Dechlorination of Flue Dust
Chlorine is found in the flue dust of secondary lead
smelters in the form of lead chloride. Recycling the flue
dust to the smelting furnace causes the chlorine to build up
in the furnace and baghouse system until it is released as
HCl or Cl2, unless it is removed in the slag. The same
technology that can be used to perform paste desulfurization
can be used to remove chlorine from the flue dust by
diverting the flue dust to the paste desulfurization system
before recycling it to the furnace. This strategy is being
used by at least one secondary lead smelter and it appears
to be as effective as fluxing in the control of HCl and Cl2
emissions. The proposed standards would not prevent
smelters from pursuing this option.
G. Miscellaneous
In accordance with section 117 of the Act, publication
of this proposal was preceded by consultation with
appropriate advisory committees, independent experts, and
Federal departments and agencies. The Administrator
welcomes comments on all aspects of the proposed regulation,
including health, economic, and technological issues, and on
the proposed test methods.
This regulation will be reviewed 8 years from the date
of promulgation. This review will include an assessment of
such factors as evaluation of residual health risks, any
overlap with other programs, the existence of alternative
methods, enforceability, improvements in emission control
technology and health data, and the recordkeeping and
reporting requirements.
VIII. Statutory Authority
The statutory authority for this proposal is provided
by sections 101, 112, 114, 116, and 301 of the Clean Air
Act, as amended; 42 U.S.C., 7401, 7412, 7414, 7416, and
7601.
List of Subjects in 40 CFR Part 63
Air pollution control, Hazardous substances, Reporting
and recordkeeping requirements, Secondary lead smelters.
Date Carol M. Browner
Administrator
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