# EAST PENN manufacturing co., inc.

**Metals Division**

P.O.BOX 147, DEKA ROAD ● LYON STATION, PA 19536

-0147 PHONE: 610

-682

-6361 ● FAX 610

-682

- 1038 EMAIL : EPMSMT@EASTPENN

- DEKA.COM August 30, 2013 Charles French Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 109 T.W.Alexander Drive Mail Code: D243

-02 Research Triangle Park, NC 27709 Dear Chuck,
I amwriting with regard to the U.S. Environmental Protection Agency’s (“EPA”) pending adm inistrative reconsideration of the national em ission standards for hazardous air pollutants (“NESHAP”) for secondary lead smelters, 77 Fed. Reg. 555 (Jan. 5, 2012). The purpose of the NESHAP requirement that smelters demonstrate the maintenance of negative pressure is to minimize the potential release of fugitive dust emissions. East Penn Manufacturing Company, Inc.’s (“East Penn”) has submitted a pending petition for an alternative standard, which it believes is the most environmentally

-protective way that EPA could address the provisions regarding the dem onstration of continuous negative pressure at its facility. N otwithstanding that petition, in response to yo ur request that East Penn provide input on how best to clarify certain issues that are currently s ubject to adm inistrative reconsideration, East Penn would like to propose the following regulatory language. **First**, EPA should revise 40 C.F.R. § 63.544(c) to read as follows:

(c) You must construct and operate total enclosures for the sources listed in paragraph (a) of this section as specified in paragraphs (c)(1)

–(3) of this section. T he total enclosure must be free of significant cracks, gaps, corrosion or other deterioration that could cause lead bearing material to be released from the primary barrier. Measures must be in place to prevent the tracking of lead bearing material out of the unit by personnel or by equipment used in handling the material. An area must be designated to decontaminate equipment and any rinsate must be collected and properly managed. (1) You must ventilate the total enclosure continuously to ensure negative pressure values of at least 0.013 mm of mercury (0.007 inches of water); or (2) You must maintain an inward flow of air through all natural draft openings.(3) Where one or more sources listed i n paragraphs (a)(1) through (9) of this section are located in a building that meets the definition of a total enclosure under Section 63.542 or portion of a building that meets the definition of a total enclosure under Section 63.542, the requirements of paragraphs (c)(1) or (c)(2) shall be monitored pursuant to Section 63.548(k)(1) at only one (1) leeward, one (1) windward, and one (1) additional wall each. This revised language contains two substantive revisions from the existing language at 40 C.F.R. § 63.544(c): it adds the word “or” between subsections (c)(1) and (c)(2) and it clarifies that sm elters that have numerous fugitive dust sources in a building or portion of a building need only monitor the “big box” enclosed area, rather than each separate fugitive dust source.
With regard to the first of these changes, subsection (c)(1) is not consistent with the regulatory intent that continuous negative pressure be equivalent to 200 fpm of velocity. 1 If negative pressure of 0.007 inches of water is contin uously required for the enclosure then the natural draft openings should be at 0.007 inches of water since the measurement requirement is the pressure difference between am bient air and the pressure inside the enclosure. To measure the pressure differential essentially a natural draft opening is created through the monitor to measure and record either the pressure or the velocity of the air flow. T hus, it would seem that the intent now would be to add the word “or” between the two requirements.
With regard to the second of these changes, East Penn’s smelting operations have incorporated total enclosure and isolation units for decades. T he design of the facility is to place the material storage area (the containment building for broken battery materials an d lead bearing wastes destined for sm elting) at the center of the operations since the operations of this material storage area present the greatest potential for fugitive em issions under normal operations. T his design allows several important benefits to be achieved: (a) the storage area can be isolated from the balance of the facility which eliminates traffic and tracking of materials from the storage area, (b) the lead bearing materials can be mechanically conveyed into and out of the containment building, (c) the material flow can incorporate both the feeding of materials directly to the furnace operations and the return of materials to the room for further processing by the furnace operations, and (d) the area is better suited for enclosure, since the material storage area is under negative pressure and the areas surrounding it are also under negative pressure, thus serving as a dual barrier to fugitive emissions. The processing operations, including the battery breaker, the furnace operations, and the refinery, surround the room.S ince the areas have common walls, the potential exists when attempting to measure the negative pressure for results to be skewed by this design with different areas under negative pressure. M oreover, specific areas are ventilated through different control

1 See Method 204

– Criteria for and Verification of a Permanent or Temporary Total Enclosure Section 8.3, “ The FV shall be at least 3,600 m/hr (200 fpm). Alternatively, measure the pressure differential across the enclosure. Apressure drop of 0.013 mm Hg (0.007 in. H2O) corresponds to an FV of 3,600 m/hr (200 fpm)”.devices. W ithin the East Penn facility different control devices are used to effectively ventilate

different sources and different areas of operation. The way that this works in practice is most easily demonstrated by the attached drawing of the sm elter building. T he areas that are required to be totally enclosed under the NESHAP are indicated and are surrounded by abold black line, which signifies walls in the facility surrounding the areas that are under continuous negative pressure. T his revision would ensure that East Penn need not em ploy what could be dozens of monitors total, but instead would em ploy three monitors total for this totally enclosed portion of the smelter building, one each at the windward, leeward, and additional walls. **Second**, EPA should revise 40 C.F.R. § 63.547(k)(1)(III) to read as follows:

(iii) An additional wall that is not the windward or leeward wall. The location for the third monitor should be s im ply aconfirmation that the operation remains under negative pressure even if there is a substantial wind shift. Otherwise its redundancy is not required. T he monitors’ readings are affected by friction losses in the external tubing and entry losses de pendent upon the configuration. Thus, it can be very difficult to locate a monitor exactly on a midpoint or on a specific area of the enclosure. T his third monitor should be able to be located at the discretion of the facility a nd subject to the specific configurations and layout of the facility. **Third**, EPA should revise 40 C.F.R. § 63.547(k)(3) to read as follows:

(3) The digital differential pressure monitoring systems must be certified by the manufacturer to be capable of measuring and displaying negative pressure in the amount of 0.001 inches of water. Accuracy of the monitors is dependent upon several issues, particularly temperature, since the measurement relates to the ideal gas law and the formula PV=nRT

.

Where P is the pressure of the gas, V is the volume of the gas, n is the amount of substance of gas (also known as number of moles), T is the temperature of the gas and R is the ideal, or universal, gas constant.

**Process Constant**  **Known ratio**  **P 2**  **V 2**  **T**

**2** Isobaric process Pressure V 2 /V1 P2 = P1 V 2 = V1 (T

2 /T1 ) T 2 = T1 (V

2 /V1 ) T 2 /T1 P2 = P1 V 2 = V1 (T

2 /T1 ) T 2 = T1 (T

2 /T1 )

The location of the monitors and the effects of solar exposure and the temperature differential between am bient and indoor temperatures can have an effect upon the reading. East Penn has conducted an extensive evaluation with two different monitor types. O ne type measures differential pressure across a diaphragm, the other measures tem perature via thermistors and converts velocity to differential pressure through an algorithm

. Both of the monitors that East Penn has evaluated express their accuracy as a percent of span or a percentage of the reading. According to the suppliers, these num bers when converted express the differential pressure in increments of 0.001 inches of water.**Fourth** , EPA should revise 40 C.F.R. § 63.547(k)(5) to read as follows: (5) You must calibrate each digital differential pressure monitoring system in accordance with manufacturer’sspecifications. Y ou must not calibrate any digital differential pressure monitoring system that the manufacturer’s specifications state should not be calibrated. The intent of this subsection is to ensure that all monitors are calibrated in accordance with ma nufacturer specifications, but both of the monitors that East Penn has evaluated do not recommend periodic maintenance or calibration.

* * * Thank you for your attention to this matter. Please contact me if you have any questions. Sincerely,

Richard A. Leiby

cc: Robert N. Steinwurtzel Mark W.DeLaquil Nathan To pham