# Compliance T est Report for the Main Baghouse S t ack at the Arecibo Facility

Prep ared for: The Battery Recycling Comp any Inc. Arecibo, Puerto Rico

Prep ared by: URS Corporation Oak Ridge, T e nnessee

January 2009COMPLIANCE TEST REPORT FOR THE MAIN BAGHOUSE STACK AT THE ARECIBO FACILITY

Prepared For:
The Battery Recycling Company Inc. Arecibo, Puerto Rico

Prepared By:
URS Corporation 1093 Commerce Park Drive, Suite 100 Oak Ridge, Tennessee 37830

January 2009i 

## Table of Contents

List of Tables

................................................................................................................. ................. ii List of Figures

................................................................................................................ ................. ii List of Acronym s

............................................................................................................... ............ iii

1.0 Introduction ........................................................................................................................1

2.0 Test Conditions and Technical Approach .......................................................................2 2.1 Test Conditions and Schedule ..................................................................................2 2.2 Sam p le Location ......................................................................................................2 2.3 Technical Approach .................................................................................................2 2.3.1 EPA Methods 1 and 2, Determ ination of Stack Gas Volum e tric Flow Rate ..................................................................................3 2.3.2 EPA Method 3A, Determ ination of Stack Gas Molecular W e ight ........................................................................................4 2.3.3 EPA Method 4, Determ ination of Stack Gas Moisture Content .........................................................................................4 2.3.4 EPA Method 5, Determ ination of Stack Gas Particulate Matter Em issions .......................................................................4 2.3.5 EPA Method 6C, Determ ination of Stack Gas Sulfur Dioxide Em issions ............................................................................5 2.3.6 EPA Method 9 Determ ination of Stack Gas Opacity Em issions .......................................................................................6 2.3.7 Determ ination of Hood Face Velocities using a Propeller Anem om eter.....................................................................8

3.0 Performance Testing Emission Results ............................................................................9

4.0 Quality Assurance/Quality Control Procedure .............................................................10 4.1 CEM Calibration Procedures and Correction Factor Calculations ........................10 4.2 Dry Gas Meters/Orifice Meters ............................................................................12 4.3 Therm o couples and Therm o couple Readouts ........................................................12 4.4 Barom e ter ...............................................................................................................13 4.5 Analytical Balance

......................................................................................................... 13 4.6 Pitot Tubes

...................................................................................................................... 13

Appendix A: Calculation Data Appendix B: Reference Method Field Data Sheets Appendix C: Battery Recycling Com p any Process Data Appendix D: Calibration Dataii 

## List of Tables

2-1 Reference Method Test Procedures .....................................................................................3
2-2 Face Velocity Results

...................................................................................................... ....8
3-1 Main Stack Particulat e Matter Results Sum m a ry ................................................................9



## List of Figures

2-1 Schem a tic of Method 5 Train ............................................................................................14iii 

## List of Acronyms

BRC Battery Recycling Com p any CFR Code of Federal Regulations
CO 2 Carbon Dioxide dscfm Dry Standard Cubic Feet per Minute
USEPA U.S. Environm ental Protection Agency
MACT Maxim u m Achievable Control Technology
NSPS National Em ission Standards for Hazardous Air Pollutants
O 2 Oxygen QA Quality Assurance QC Quality Control
SO 2 Sulfur Dioxide scf standard cubic foot

scm standard cubic m e ter URS URS Corporation1 

## 1.0 Introduction

The Battery Recycling Com p any, Inc. (BRC) owns and operates a lead recycling facility in Arecibo, Puerto Rico. BRC’s operations are subject to the com p liance requirem e nts established in 40 CFR Part 63, Subpart X (National Em issi on Standards for Hazardous Air Pollutants from Secondary Lead Sm elting, “Secondary Lead Sm elting MACT Standard”). URS Corporation (URS) was contracted by BRC to conduct com p liance particulate m a tter (PM) testing on their Main Baghouse stack, and face velocity m easurem ents on the Lead and Slag Taps/Molds. The

com p liance testing was conducted on Decem ber 16-17, 2008.

The com p liance testing allowed BRC to achieve four com p liance objectives. The first two objectives were to determ ine if the Main Baghouse is in com p liance with the 0.022 grains/dry standard cubic foot (gr/dscf) PM requirem e nt, and the <20% opacity requirem e nt, as set forth in the NSPS Standard Requirem e nt 40 CFR 60.122(a). The third objective was to verify that the face velocity of the em ission control hoods on the lead taps/m olds and slag tap/m o lds were >300 feet per m i nute (fpm ), as required in the MACT Standard 40 CFR 63.544. The fourth objective

was to m easure the sulfur dioxide (SO 2 ) em issions from the Main Baghouse to confirm that the facility is below the m a jor source threshold of 100 tons per year of SO 2 . This test report presents the results of these test objectives along with the test data and description of the procedures used
to collect the data.

Section 2.0 describes the m e thods and techniques that were used to conduct the com p liance testing. Section 3.0 is a discussion of the com p liance test results for the stack. Section 4.0 discusses the quality assurance (QA) and quality control (QC) procedures that were f o llowed in the perform a nce of the testing. Appendix A contains the com p liance test calculation data for the stack. Appendix B contains the field data sh eets . Appendix C contains the process data. Appendix D contains field equipm ent calibration data used in the com p liance test.2 

## 2

. 0 Test Conditions and Technical Approach

The following sections describe the m e thods and techniques that were used to com p lete the

com p liance testing on the Main Baghouse stack.

2.1 Test Conditions and Schedule

On Decem ber 16 and 17, 2008 URS perform e d three 1-hour test runs for particulate m a tter, three
1-hour tests to determ ine Opacity, three batch test runs for sulfur dioxide on the m a in baghouse stack and face velocity m easurem ents at the opening to the rotary furnace and to each kettle.
Volum e tric f l ow rate, m o lecular weight, and m o isture were also determ ined on the m a in baghouse stack. The results of the tests will be used to confirm com p liance with the em ission
lim its.

2.2 Sample Locations

The stack sam p ling location was a baghouse exhaust stack 62.25 inches in diam eter. Sam p les and velocity m easurem ents were collected by accessing two test ports. The ports were located approxim a tely 38 ft (7.32 diam eters) downstream and 11 ft (2.12 diam eters) upstream of the
nearest duct transition or flow disturbance. Flow m easurem ents were perform e d using a 12-point traverse using two ports (6 points per port). Appe ndix B contains the reference m e thod field data
sheets for the stack sam p ling location.

2.3 Technical Approach

The m e thodologies that were utilized for data collection are presented and sum m a rized in Table
2-1. The sam p ling procedures included in the technical approach were selected to accurately
determ ine the properties and com position of the stack’s gas stream . The selected m e thodologies
were consistent with those recom m e nded and ref e renced in Title 40 of the Code of Federal Regulations Part 60 (40 CFR Part 60), A ppendix A, and 40 CFR Part 63, Subpart X.3 Table 2-1
Reference Method Test Procedures

Source Pollutant Reference Procedures for Performance Test Particulate

Matter EPA Title 40 CFR Part 60, Appendix A, Me thod 5, Determination of Particulate Matter Emissions from Stationary Sources Opacity EPA Title 40 CFR Part 60, Appendix A, Method 9, Determination of Opacity Emissions from Stationary Sources EPA Title 40 CFR Part 60, Appendix A, Me thods 1 and 2, Determination of Stack Gas Volumetric Flow Rate EPA Title 40 CFR Part 60, Appendix A, Method 3A, Gas Analysis for Determination of Dry Molecular Weight Main Baghouse

Stack Sulfur Dioxide EPA Title 40 CFR Part 60, Appendix A, Method 4, Determination of Moisture Content in Stack Gases
The following are summary descriptions of the sampling methodologies that were followed to complete the sampling program.

2.3.1 EPA Methods 1 and 2, Determina tion of Stack Gas Volumetric Flow
Rate

U.S. Environmental Protection Agency (EPA) Methods 1 and 2 were used to determine the stack gas volumetric flow rate at the sampling location. An integrated velocity traverse was conducted during each 1-hour PM test run for the Main Baghouse stack at each traverse point. An S-type pitot tube and an incline manometer were used to measure the velocity pressure. A calibrated type “K” thermocouple was used to measure the stack gas temperature at each traverse point. For each test run, the Pitot tube and thermocouple were positioned sequentially at each of the appropriate traverse points. Temperature and ∆ P readings were observed and recorded. Utilizing the stack gas molecular weight and moisture content, the standard (Q std ) and actual volumetric
flow rates were calculated in accordance with the formulas found in EPA Reference Method 2. The flow rate data has been included in Appendices A and B.4 2.3.2 EPA Method 3, Determination of Stack Gas Molecular Weight

The stack gas O 2 and CO 2 concentrations were continuously measured during each test run with a Servomex Model 4900 O2/CO2 analyzer in accordance with EPA Method 3A procedures. Data was collected in one minute average intervals and then averaged for each test. The resulting O 2 and CO 2 concentrations were used to calculate the molecular weight of the stack gas.

2.3.3 EPA Method 4, Determination of Stack Gas Moisture Content

The moisture content (%), B wo , of the stack gas was determined for the Main Baghouse stack exhaust gases in accordance with EPA Method 4. An exhaust gas sample was drawn from the stack and passed through chilled glass impingers. The moisture content of the stack gas was determined for the compliance runs by measuring the weight gain of the chilled impingers over the length of the test run. The moisture determination was integrated into the Method 6C sampling results.

2.3.4 EPA Method 5, Determination of Stack Gas Particulate Matter
Emissions

The solid particulate matter testing was performed in accordance to EPA Method 5. Sampling was performed by extracting a sample of the stack exhaust gas stream through a stainless steel button-hook nozzle attached to a glass-lined, heat-traced, probe. The probe was attached to a heated glass filter holder containing a pre-weighed glass-fiber filter. The probe and filter heater box were maintained at a temperature of 248 o F + 25 o F. After leaving the filter holder, the gasstream sample passed through a series of four glass impingers. The first impinger was a SmithGreenburg filled with 100 ml of distilled water. The second impinger was a modified SmithGreenburg and filled with 100 ml of distilled water. The third impinger was a modified SmithGreenburg and was initially empty. The fourth impinger contained approximately 200 grams of indicating silica gel. The impingers were weighed prior to assembling the sampling train to permit gravimetric moisture determination. After exiting the impingers, the exhaust gas sample5 traveled through an umbilical cord to the control console and was then exhausted to atmosphere. The control console contained the sample pump, dry gas meter, calibrated orifice meter, and heat controls for the probe and filter box.

At the conclusion of each test run, the sample train was recovered by washing the sample probe and nozzle three times with acetone into a sample container. The filter was removed from the filter holder and placed into a Petri dish and sealed for transport. The front half of the glass filter holder and connecting elbow were washed with acetone into the probe wash sample container. A sample of the acetone used in the sample recovery was collected and analyzed as a reagent blank. The impinger train was then disassembled and each impinger was weighed to determine the moisture gained during the sample run. At the conclusion of sampling, all the particulate samples were packaged and returned to the URS facility for subsequent analysis.

The particulate samples were analyzed by URS personnel. The analysis was performed by placing the filters into a desicator for a minimum of 24 hours. The filters were then weighed to a constant weight. The acetone rinses were transferred to pre-weighed cups and allowed to dry in a laboratory hood at ambient temperature. The acetone cups were then transferred to a desicator and allowed to dry for a minimum of 24 hours. The acetone cups were then weighed to a constant weight. The combined weights of the filter and probe wash were used to calculate the mass emission rate of solid particulates. The data collected during the PM sampling is contained in Appendix B.

2.3.5 EPA Method 6C, Determinati on of Stack Gas Sulfur Dioxide
Emissions

The SO 2 sampling was performed by placing a stainless steel probe, complete with stainless steel sintered filter, into the stack and withdrawing a constant sample of exhaust gas from the stack. The sample probe was connected to a heated Tefl on line that transported the sample from the end of the sample probe to the non-contact gas conditioning chiller system which removed the6 moisture from the gas stream. The dried gas sample then passed through an unheated Teflon transport line to the SO 2 continuous emission monitor (CEM). The CEM analyzer was located in a temperature-controlled room to minimize therma l affects on the calibration of the instruments. The CEM was connected to a computerized data acquisition system that recorded the SO 2 concentrations on a one-minute basis.

The SO 2 concentrations were measured using a Servomex Model 4900 SO 2 gas analyzer. The
SO 2 sampling conformed to procedures presen ted in EPA 40 CFR 60, A ppendix A, Method 6C and Appendix B Specification 2. The con centration and mass emissions of SO 2 in the gas stream are reported in parts per million by volume (ppm v) on a dry basis, pounds per hour (lb/hr) and tons per year (tons/year) respectively. The emission rates were calculated using the specific run time average concentration in ppm, the dry standa rd volumetric flow rate, the Ideal Gas Law, and the sampling time.

2.3.6 EPA Method 9 Determination of Stack Gas Opacity Emissions

The VE observer that performed the VE readings used the following procedures for visually determining the opacity of emissions.

Observer’s Position
The VE observer stood at a distance sufficient to provi de a clear view of the emissions with the sun
oriented in the 140 ° sector to his back. Consistent with maintaining the above requirement, the observer made his observations from a position su ch that his line of vision was approximately perpendicular to the plume direction and, when observing opacity of emissions from rectangular outlets (e.g., roof monitors, open baghouses, noncircu lar stacks), approximately perpendicular to the longer axis of the outlet. The observer’s line of sight did not include more than one plume at a time when multiple stacks were involved, and in a ny case the observer made his observations with his line of sight perpendicular to the longer axis of such a set of multiple stacks (e.g., stub stacks on baghouses).7 Field Records
The observer recorded the name of the plant, em ission location, facility type, observer’s name and affiliation, and the date on a field data sheet. The time, estimated distance to the emission location, approximate wind direction, estimated wind speed, description of the sky condition (presence and color of clouds), and plume background were record ed on the field data sheet at the time opacity readings were initiated and completed.

Observations
Opacity observations were made at the point of gr eatest opacity in that portion of the plume where condensed water vapor was not present. The obs erver did not look continuously at the plume but instead observed the plume momentarily at 15-second intervals.
Recording Observations
Opacity observations were recorded to the n earest 5 percent at 15-second intervals on the
observational record sheet. A minimum of 240 obser vations were recorded. Each test period took 60 minutes to complete. Each momentary observati on recorded was deemed to be representative of the average opacity of emissions for a 15-second period.

Data Reduction
Opacity shall was determined as an average of 240 consecutive observations recorded at 15-second intervals. For each set of 240 observations, the average was calculated by summing the opacity of the 240 observations and dividing this sum by 240. The average opacity was recorded on the
observational record sheet.8 2.3.7 Determination of Hood Face Velocities using a Propeller
Anemometer

The face velocities at the hood opening to the rotary furnace and at the opening to each kettle operating during the testing period were measured using a propeller anemometer. The face velocities were measured with the doors open in a manner comparable to normal operating conditions. The measurements were conducted at multiple points around the door openings. The face velocity values listed in the result table consist of the average number observed during each check of the respective source. The results are listed in Table 2-2.

Table 2-2

Source Face Velocity Comments Kettle # 1 Trough 270 ft/min Kettle # 1 Trough was set to be reworked due to loosing some bricks during the last cleaning cycle. Kettle # 2 497 ft/min
Kettle # 3 449 ft/min
Kettle # 4 356 ft/min
Kettle # 5 436 ft/min

Furnace 461 ft/min Tested using multiple door open configurations.
Blower 396 ft/min9 

## 3.0 Performance Testing Emission Results

The following is a brief sum m a ry and discussion of the Main Baghouse stack com p liance testing
results.

The com p liance test results are sum m a rized in Table 3-1. The tests of BRC’s Main Baghouse
stack shows that it com p lies with the Particulate Matter perform a nce standard of 0.022 grains/dscf as stated in the Secondary Lead Sm elting MACT Standard. The average particulate

m a tter em ission rate, for the com p liance test was 0.0035 grains/dscf . The results for the

com p liance tests for Visible Em issions averaged 0.021% showing com p liance with the less than
20% standard in the NSPS for Lead Sm elters. The results for the Sulfur Dioxide batch runs averaged 26.792 tons/year showing com p liance with the non m a jor source lim it of 100 tons/year.

Table 3-1

Parameters Run # 1 Run # 2 Run # 3 Av erage Sample Date 1 2 / 1 6 / 0 8 1 2 / 1 6 / 0 8 1 2 / 1 7 / 0 8

Run Times 1 5 : 2 8

- 1 6 : 3 0 1 6 : 5 2

- 1 7 : 5 3 0 8 : 0 0

- 0 9 : 0 2 Sample Time 6 0 6 0 6 0 6 0 Vol. Sam p led @ STP (ft3) 3 4

. 9 0 6 3 3

. 6 5 2 3 5

. 8 6 8 3 4

. 8 0 8 Moisture Content (% Vol.) 3

. 4 9 4

. 0 4 4

. 9 0 4

. 1 4 O2 (% ) 2 0

. 0 2 0

. 0 1 9

. 7 1 9

. 9 CO2 (% ) 1

. 0 1

. 1 1

. 2 1

. 1 Stack Gas Temperature ( o F) 1 7 2

. 1 1 6 9

. 6 1 7 9

. 0 1 7 3

. 6

Gas Flow Rate (DSCFM) 3 0 , 4 5 1 2 9 , 6 6 3 2 9 , 9 9 3 3 0 , 0 3 6 Percent Isokinetic 9 7

. 9 9 6

. 9 1 0 2

. 1 9 9

. 0 Particulate Matter Conc. (Grains/DSCF) 0

. 0 0 4 4 2 0

. 0 0 2 5 0

. 0 0 3 6 0

. 0 0 3 5 Particulate Matter Mass Rate (pounds/hr) 1 0

. 1 1 5 7 5

. 7 7 0 8 8

. 2 6 9 3 8

. 0 5 1 9 Compliance Test Data Sulfur Dioxide Mass Rate (tons/y ear) 4 3

. 9 5 1 2 7

. 3 4 8 9

. 0 7 7 2 6

. 7 9 2 Visible Emissions (Opacity % ) 0

. 0 4 2 0

. 0 2 1 0

. 0 0

. 0 2 110 

## 4.0 Quality Assurance/Quality Control Procedure

The objective of the URS’s QA Program is to ensure the accuracy and precision, as well as reliability, of the data collected and generated f o r URS’s clients and to m eet the data quality objectives of regulatory or accrediting bodies. Managem e nt, adm i nistrative, statistical, investigative, preventative, and corrective techniques were em ployed to m a xim i ze the reliability
of data.

During the com p liance testing, a strict QA/QC progr am was adhered to. Before actual sam p ling on-site, all the sam p ling equipm ent was thoroughly checked to ensure that each com ponent was clean and operable. Any dam a ged or faulty equipm ent was tagged and rem oved from service until it could be repaired. If any corrective actions were taken in response to these QC checks or in response to supervisor review of QC procedures, the corrective action taken was docum ented in a field QA/QC logbook.

Proper equipm ent calibration is essential in m a intaining the desired data quality level. All calibrations of the equipm ent used in the stack sam p ling portion of the testing conform e d to the guidelines outlined in the EPA quality assurance handbook, Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods (EPA-600/4- 77-027a). The following sections give a synopsis of the calibration procedures for the m a in

com ponents of the stack sam p ling system s

.

4.1 CEM Calibration Procedures and Correction Factor Calculations

The reference m e thod analyzers were calibrate d with EPA-approved RATA Class calibration gases prior to the beginning of the test series , and after each com p liance test run. The initial calibration error checks were perform e d at the begi nning of the test run series in accordance with the specific reference m e thod applicable to the analyzer. After the successful com p letion of the initial calibration error check, a system bias check was perf orm e d.11 Zero, m i d and high point calibration bias checks were perform e d prior to the beginning of the

com p liance test runs. The bias check is a com p arison of instrum e nt response to gas introduced into the analyzer with gases routed throughout the entire sam p ling system . The m a xim u m allowable bias is 5% of the sp an. After the bias check was perform e d, the analyzers were not adjusted during the com p liance tests, unless an analyzer failed the drift check. No analyzers
f a iled the drif t check.

After each com p liance test run, a drift check wa s perform e d on each analyzer by introducing the

m i d-range calibration gas and the zero nitrogen. The m a xim u m allowable calibration drift is 3%
of

the span. Calibration drif t was determ ined by com p aring the before run and after run values.
The test data values were corrected for bias and calibration drift. The following calculation, as
cited in the reference m e thod, was used to corr ect the m easured concentrations for bias and
instrum e nt calibration drif ts:



### ) ( ) (

o m ma o anz gas 

### C C C C C C

− − =

where: C gas = effluent gas concentration, dry basis, ppm v C anz = average gas concentration indicated by the gas analyzer, dry basis, ppm v C o = average of initial and f i nal system calibration bias check responses for the zero gas, ppm v C m = average of initial and f i nal system calibration bias check responses for the upscale calibration gas, ppm v C ma = actual concentration of the upscale calibration gas, ppm v.

Response tim e tests were perform e d in conjunction with the bias checks. The response tim e test was perform e d by m easuring the tim e it took for each analyzer to reach 95% of the concentration12 of the high range calibration gas. The zero gas wa s then introduced into the sample system and the amount of time it took for the analyzer to reach a 95% reduction in scale reading was measured. The greater of these two readings was recorded as the response time for that analyzer.

4.2 Dry Gas Meters/Orifice Meters

The dry gas meter and critical orifice in each control box to be used during the testing were calibrated before the test in order to ensure accurate measurements of the sample gas volumes. The dry gas meter and critical orifice are normally housed as a set inside each control box and were calibrated as such. The control box was calibrated against a secondary calibration standard dry gas meter.

The dry gas meter/critical orifice sets were calibrated at predetermined nominal volume flow settings. For each of these flow rates, an accur acy ratio factor to the calibration standard (Y i ) was computed for the individual dry gas meters. A successful calibration for a particular dry gas
meter would be achieved if each value of Y i was within 2 percent of the average value of Y i (Y i = Y ±0.02Y). In order to establish calibration for the critical orifice, a calibration coefficient ( ∆ H@ I ) was calculated for each flow rate. This coefficient is the orifice pressure differential (in inches H 2 O) at a distinct orifice manometer setting that gives a flow of 0.75 ft 3 /min of air at standard conditions. The desired tolerance for this coefficient is ±0.2 of the average value of the four
values of ∆ H@ I ( ∆ H@ ±0.2). If any of the pre-test calibration coefficients for a particular meter violates the acceptance criteria, the meter in question would be adjusted and recalibrated.

4.3 Thermocouples and Thermocouple Readouts

All thermocouples used during the stack sampling tests were calibrated to ensure accurate temperature measurements. All of the sensors utilized were type "K" thermocouples, which have a working range of approximately -300 °F to approximately 2500 °F. These sensors were used in the measurement of stack gas temperature, probe sheath temperature, filter box temperature, and impinger temperature. The thermocouples were calibrated against an NITS traceable13 mercury-in-glass thermometer at predetermined temperatures. In order to obtain the calibration data from each sensor, a single, recently calibrated thermocouple readout was used.

The thermocouple readouts used during the testing were calibrated using a thermocouple simulator. This calibration apparatus generates a voltage signal that mimics the signal an ideal "K" type thermocouple would exhibit at a particular temperature. The signal can be changed via a slide switch. The readouts were calibrated at ten different points from 200 °F through 2000 °F,
at increments of 200 °F.

4.4 Barometer

The field barometer to be used during the test was a digital type barometer. This barometer was calibrated by comparing it to a standard mercury column barometer and adjusting it if any deviation existed between it and the standard. This exercise was performed both before and after the testing activities.

4.5 Analytical Balance

The field analytical balance was calibrated before the test with certified standard weights. The balance was adjusted for any deviation from the standard weights. In the field, periodic checks were made to insure data validity. This balance was used to measure the impinger weight changes due to moisture gain during the stack sampling (determination of stack moisture content).

4.6 Pitot Tubes

The S-type pitot tubes used on each isokinetic sampling train were calibrated in a wind tunnel against a standard pitot, which is considered a reference source. The basis for the calibration is described in 40 CFR, Part 60, Appendix A, Method 2.

## Appendix A

## Appendix B

## Appendix C

## Appendix D

## Visible Emissions Opacity

## Method 2 Velocities

## Method 4 Moisture

## Method 6C Sulfur Dioxide