From: <French.Chuck@epamail.epa.gov>

To: rsflack@yahoo.com

CC: Danny.Greene@erg.com

Date: 6/9/2010 3:28 PM 

Subject: Re: secondary lead smelter testing 

Hi Scott, 

Sorry for the delay responding to your questions. Anyway, below we provide responses to your questions. See 

below. Let us know if you have further questions. 

Thanks. 

Chuck 

From: Scott Flack <rsflack@yahoo.com> 

To: Chuck French/RTP/USEPA/US@EPA 

Date: 05/24/2010 11:35 AM 

Subject: secondary lead smelter testing 

Mr. French: 

Recently I received a testing request from a client of mine who operates a secondary lead smelter. The testing 

request stems from a draft EPA document which requests extensive testing at secondary lead smelting facilities. 

Before I prepare my testing quote for my client, I wanted to ask you some clarifying questions about the potential 

stack tests that will be required. I realize that the EPA information request is in the draft phase right now, but I 

would appreciate it if you could answer the following questions as completely as possible. 

1) When do you expect that this testing will have to be performed? Within the next 6 months, year? 

Response: Yes. We expect to have testing completed within about 4 months or so. 

2) Will the testing be witnessed by a state or federal agency or will we be able to test on our own schedule within 

a certain window of time once the EPA makes the information request? 

Response: It is possible that a State or Federal official would plan to witness the test. However, we do 

not expect that all tests will have such witnesses, and we can not delay such tests to accommodate 

schedules of the officials. So, you will be able to test on your own schedule within a certain window of 

time once the EPA makes the request. However, we will request that you inform us a few weeks ahead of 

time so that we are aware of the timing of the testing, etc... just in case a government official would like to 

witness the test, etc... 

3) In the past 2 years as part of my client's Title V operating permit, we have conducted numerous PM,PM-10 

and condensable PM compliance stack tests using EPA method 5 and 202. We are willing to make the 

assumption that all of the PM at the testing locations is all PM-10 or PM-2.5 since there are baghouses on all of 

the sources; therefore, will we be able to submit these data to EPA to satisfy the PM, PM-2.5 and condensable 

PM testing requirement? All of our tests had detectable results, and the size of the sample volumes collected 

ranged from 35 to 50 dry standard cubic feet. We also perform lead (Pb) compliance tests every other year on 

the facility baghouses using EPA method 12. Will we be able to use these Pb data to satisfy the Pb testing 

requirement? 

Response: The Method 5 filterable PM results in lieu of OTM 27 very likely could satisfy our data needs. 

1) We would expect a zero to slightly positive bias in the filterable PM mass rate from using Method 5 over 

OTM 27. 2) We would also probably accept the shorter run times for PM testing even from FFs. 3) we 

already allow the use of Method 5 in some situations (e.g., water droplets). 

Before we could accept Method 202 data in lieu of OTM 28 data, we would need the source to describe in 

detail how the method was run and the samples analyzed. Then, we would have to agree that the 

method was conducted in accordance with our criteria for minimizing artifact formation. In general, we 

would not accept Method 202 data for tests conducted prior to the revisions proposed last year. 

Method 12 tests for Pb will be acceptable, as long as they were conducted within the last 7 years or so. 

4) Since 40 CFR Part 63 Subpart X specifies lead limits that are expressed as 2.0 mg/dscm with no correction to 
7% oxygen, I'm curious why the draft information request states that the data must be expressed in concentration 

units corrected to 7% oxygen? Since we would also track scrap charging or lead production data during the 

testing, and since we will be measuring the stack gas exhaust flow rate, wouldn't it be desirable to express the 

test results in units such as mg-pollutant/kg of lead production or some similar unit? 

Response: Good comment and question. With regard to your latter part of the question, we would like 

test results expressed in pounds of pollutant emissions per hr (lb/hr) and pounds of emissions per ton of 

lead production (lb/ton). We will also want data reported in mg/dscm. We understand that no correction is 

needed for the compliance to the 1995 MACT rule. However, at this time, we think that a correction to 7% 

oxygen may be needed for the upcoming testing and subsequent reviews and analyses. 

5) I noticed in the pollutant method tables within the draft information request document that a minimum of 3.4 

cubic meters (120 cubic feet) of sample gas will have to be collected during each test run. Since most of the test 

methods typically involve sampling rates around 0.75 cubic feet/min, this would dictate minimum test times 

greater than 2.5 hours per run which is significantly longer than the 60 minute (>30 cubic feet) test runs typically 

required for lead and particulate compliance tests. If we feel confident that we would get detectable results 

sampling at a lower volume than 120 cubic feet per test run, will we be able to sample at lower volumes (i.e. 60 

cubic feet for example)? 

Response: These are not compliance tests but are intended to provide data representative of emissions 

from the processing units (including the best performing units) for our technology review, risk analyses, 

and review of the MACT standard, etc.. Presumably, some of these units would produce emissions far 

below current compliance limits. Without knowing exactly what emissions levels represent the best 

performers, we determined sample volumes that we believe would reasonably detect lowest expected 

emissions. We can not pre-approve smaller sample volumes without more information. Nevertheless, we 

could readily accept data from runs with sample volumes less than 120 cubic feet if the measured results 

are above the method detection level. So, the source may conduct test runs with smaller sample volumes. 

However, the testers must recognize that if those runs result in measured values below MDL, the source 

will have to repeat the runs with the larger sample volumes. 

6) My client currently uses a continuous THC analyzer (coupled with a CO2 analyzer to correct the results to 4% 

CO2) to monitor their THC emissions from their lead blast furnace/reverb melter. Will we be able to use these 

data to satisfy the THC data request for that stack? These analyzers are calibrated daily and RATA's and audits 

are performed annually. 

Response: The source may use the existing equipment by applying the calibration error and rift, 

interference, and sampling procedures as described in Method 25. However, we assume that the source 

would need to conduct Method 3A or other O2 measurement in order to correct the data to 7 percent O2. 

We doubt that a reliable O2/CO2 relationship for smelters has been developed. 

7) What pollutants specifically will be have to quantify from the scrap dryer baghouse? 

Response: The current plan is that the following pollutants would need to be quantified from the scrap 

dryer baghouse: HAP metals (arsenic, berylium, cadmium, chromium, lead, nickel, manganese, mercury, 

etc.), Cr+6, PM, Total hydrocarbons (THC), benzene, 1,3-butadiene, and naphthalene. 

I would appreciate your feedback, so I can accurately quote the testing costs since the cost will be quite 

extensive. I may submit additional questions in the future. 

Sincerely, 

Scott Flack 

Air Consulting Services