Compliance 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 

Oak Ridge, Tennessee 

January 2009 
COMPLIANCE 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 2009 
i 

Table of Contents 

List of Tables.................................................................................................................................. ii 

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

List of Acronyms ........................................................................................................................... iii 

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

2.0 Test Conditions and Technical Approach .......................................................................2 

2.1 Test Conditions and Schedule..................................................................................2 

 2.2 Sample Location ......................................................................................................2 

 2.3 Technical Approach.................................................................................................2 

2.3.1 EPA Methods 1 and 2, Determination of Stack Gas 

 Volumetric Flow Rate..................................................................................3 

2.3.2 EPA Method 3A, Determination of Stack Gas 

 Molecular Weight ........................................................................................4 

2.3.3 EPA Method 4, Determination of Stack Gas 

 Moisture Content .........................................................................................4 

2.3.4 EPA Method 5, Determination of Stack Gas 

 Particulate Matter Emissions.......................................................................4 

2.3.5 EPA Method 6C, Determination of Stack Gas 

Sulfur Dioxide Emissions............................................................................5 

2.3.6 EPA Method 9 Determination of Stack Gas 

 Opacity Emissions .......................................................................................6 

2.3.7 Determination of Hood Face Velocities 

using a Propeller Anemometer.....................................................................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 Thermocouples and Thermocouple Readouts........................................................12 

 4.4 Barometer...............................................................................................................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 Company Process Data 

Appendix D: Calibration Data 
ii 

List of Tables 

2-1 Reference Method Test Procedures.....................................................................................3 

2-2 Face Velocity Results ..........................................................................................................8 

3-1 Main Stack Particulate Matter Results Summary................................................................9 

 

List of Figures 

2-1 Schematic of Method 5 Train ............................................................................................14 
iii 

List of Acronyms 

BRC Battery Recycling Company 

CFR Code of Federal Regulations 

CO2 Carbon Dioxide 

dscfm Dry Standard Cubic Feet per Minute 

USEPA U.S. Environmental Protection Agency 

MACT Maximum Achievable Control Technology 

NSPS National Emission Standards for Hazardous Air Pollutants 

O2 Oxygen 

QA Quality Assurance 

QC Quality Control 

SO2 Sulfur Dioxide 

scf standard cubic foot 

scm standard cubic meter 

URS URS Corporation 
1 

1.0 Introduction 

The Battery Recycling Company, Inc. (BRC) owns and operates a lead recycling facility in 

Arecibo, Puerto Rico. BRC’s operations are subject to the compliance requirements established 

in 40 CFR Part 63, Subpart X (National Emission Standards for Hazardous Air Pollutants from

Secondary Lead Smelting, “Secondary Lead Smelting MACT Standard”). URS Corporation 

(URS) was contracted by BRC to conduct compliance particulate matter (PM) testing on their 

Main Baghouse stack, and face velocity measurements on the Lead and Slag Taps/Molds. The 

compliance testing was conducted on December 16-17, 2008. 

The compliance testing allowed BRC to achieve four compliance objectives. The first two 

objectives were to determine if the Main Baghouse is in compliance with the 0.022 grains/dry 

standard cubic foot (gr/dscf) PM requirement, and the <20% opacity requirement, as set forth in 

the NSPS Standard Requirement 40 CFR 60.122(a). The third objective was to verify that the 

face velocity of the emission control hoods on the lead taps/molds and slag tap/molds were >300 

feet per minute (fpm), as required in the MACT Standard 40 CFR 63.544. The fourth objective 

was to measure the sulfur dioxide (SO2) emissions from the Main Baghouse to confirm that the 

facility is below the major source threshold of 100 tons per year of SO2. 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 methods and techniques that were used to conduct the compliance 

testing. Section 3.0 is a discussion of the compliance test results for the stack. Section 4.0 

discusses the quality assurance (QA) and quality control (QC) procedures that were followed in 

the performance of the testing. Appendix A contains the compliance test calculation data for the 

stack. Appendix B contains the field data sheets . Appendix C contains the process data. 

Appendix D contains field equipment calibration data used in the compliance test. 
2 

2.0 Test Conditions and Technical Approach 

The following sections describe the methods and techniques that were used to complete the 

compliance testing on the Main Baghouse stack. 

2.1 Test Conditions and Schedule 

On December 16 and 17, 2008 URS performed three 1-hour test runs for particulate matter, three 

1-hour tests to determine Opacity, three batch test runs for sulfur dioxide on the main baghouse 

stack and face velocity measurements at the opening to the rotary furnace and to each kettle. 

Volumetric flow rate, molecular weight, and moisture were also determined on the main 

baghouse stack. The results of the tests will be used to confirm compliance with the emission 

limits. 

2.2 Sample Locations 

The stack sampling location was a baghouse exhaust stack 62.25 inches in diameter. Samples 

and velocity measurements were collected by accessing two test ports. The ports were located 

approximately 38 ft (7.32 diameters) downstream and 11 ft (2.12 diameters) upstream of the 

nearest duct transition or flow disturbance. Flow measurements were performed using a 12-point 

traverse using two ports (6 points per port). Appendix B contains the reference method field data 

sheets for the stack sampling location. 

2.3 Technical Approach 

The methodologies that were utilized for data collection are presented and summarized in Table 

2-1. The sampling procedures included in the technical approach were selected to accurately 

determine the properties and composition of the stack’s gas stream. The selected methodologies 

were consistent with those recommended and referenced in Title 40 of the Code of Federal 

Regulations Part 60 (40 CFR Part 60), Appendix 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, Method 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, Methods 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, Determination 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 (Qstd) 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 O2 and CO2 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 O2

and CO2 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 (%), Bwo, 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 248o

F + 25oF. After leaving the filter holder, the gas 

stream 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 sample 
5 

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, Determination of Stack Gas Sulfur Dioxide 

Emissions 

The SO2 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 Teflon line that transported the sample from the end 

of the sample probe to the non-contact gas conditioning chiller system which removed the 
6 

moisture from the gas stream. The dried gas sample then passed through an unheated Teflon 

transport line to the SO2 continuous emission monitor (CEM). The CEM analyzer was located in 

a temperature-controlled room to minimize thermal affects on the calibration of the instruments. 

The CEM was connected to a computerized data acquisition system that recorded the SO2

concentrations on a one-minute basis. 

The SO2 concentrations were measured using a Servomex Model 4900 SO2 gas analyzer. The 

SO2 sampling conformed to procedures presented in EPA 40 CFR 60, Appendix A, Method 6C 

and Appendix B Specification 2. The concentration and mass emissions of SO2 in the gas stream 

are reported in parts per million by volume (ppmv) 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 standard 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 provide 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 such 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, noncircular 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 any 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, emission 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 recorded on the field data sheet at the time opacity 

readings were initiated and completed. 

 Observations 

Opacity observations were made at the point of greatest opacity in that portion of the plume where 

condensed water vapor was not present. The observer 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 nearest 5 percent at 15-second intervals on the 

observational record sheet. A minimum of 240 observations were recorded. Each test period took 

60 minutes to complete. Each momentary observation 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/min 
9 

3.0 Performance Testing Emission Results 

The following is a brief summary and discussion of the Main Baghouse stack compliance testing 

results. 

The compliance test results are summarized in Table 3-1. The tests of BRC’s Main Baghouse 

stack shows that it complies with the Particulate Matter performance standard of 0.022 

grains/dscf as stated in the Secondary Lead Smelting MACT Standard. The average particulate 

matter emission rate, for the compliance test was 0.0035 grains/dscf . The results for the 

compliance tests for Visible Emissions averaged 0.021% showing compliance with the less than 

20% standard in the NSPS for Lead Smelters. The results for the Sulfur Dioxide batch runs 

averaged 26.792 tons/year showing compliance with the non major source limit of 100 tons/year. 

Table 3-1 

Parameters Run # 1 Run # 2 Run # 3 Average 

Sample Date 12/16/08 12/16/08 12/17/08

Run Times 15:28-16:30 16:52-17:53 08:00-09:02

Sample Time 60 60 60 60

Vol. Sampled @ STP (ft3) 34.906 33.652 35.868 34.808

Moisture Content (% Vol.) 3.49 4.04 4.90 4.14

O2 (%) 20.0 20.0 19.7 19.9

CO2 (%) 1.0 1.1 1.2 1.1

Stack Gas Temperature (oF) 172.1 169.6 179.0 173.6

Gas Flow Rate (DSCFM) 30,451 29,663 29,993 30,036

Percent Isokinetic 97.9 96.9 102.1 99.0

Particulate Matter Conc. 

(Grains/DSCF) 0.00442 0.0025 0.0036 0.0035

Particulate Matter Mass Rate 

(pounds/hr) 10.1157 5.7708 8.2693 8.0519

Compliance Test Data 

Sulfur Dioxide Mass Rate 

(tons/year) 43.951 27.348 9.077 26.792

Visible Emissions 

 (Opacity %) 0.042 0.021 0.0 0.021
10 

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 for URS’s clients and to meet the data quality 

objectives of regulatory or accrediting bodies. Management, administrative, statistical, 

investigative, preventative, and corrective techniques were employed to maximize the reliability 

of data. 

During the compliance testing, a strict QA/QC program was adhered to. Before actual sampling 

on-site, all the sampling equipment was thoroughly checked to ensure that each component was 

clean and operable. Any damaged or faulty equipment was tagged and removed 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 documented 

in a field QA/QC logbook. 

Proper equipment calibration is essential in maintaining the desired data quality level. All 

calibrations of the equipment used in the stack sampling portion of the testing conformed 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 main 

components of the stack sampling systems. 

4.1 CEM Calibration Procedures and Correction Factor Calculations 

The reference method analyzers were calibrated with EPA-approved RATA Class calibration 

gases prior to the beginning of the test series, and after each compliance test run. The initial 

calibration error checks were performed at the beginning of the test run series in accordance with 

the specific reference method applicable to the analyzer. After the successful completion of the 

initial calibration error check, a system bias check was performed. 
11 

Zero, mid and high point calibration bias checks were performed prior to the beginning of the 

compliance test runs. The bias check is a comparison of instrument response to gas introduced 

into the analyzer with gases routed throughout the entire sampling system. The maximum

allowable bias is 5% of the span. After the bias check was performed, the analyzers were not 

adjusted during the compliance tests, unless an analyzer failed the drift check. No analyzers 

failed the drift check. 

After each compliance test run, a drift check was performed on each analyzer by introducing the 

mid-range calibration gas and the zero nitrogen. The maximum allowable calibration drift is 3% 

of the span. Calibration drift was determined by comparing 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 method, was used to correct the measured concentrations for bias and 

instrument calibration drifts: 

( ) ( )

m o

ma

gas anz o C C

C C C C − = −

where: Cgas = effluent gas concentration, dry basis, ppmv 

 Canz = average gas concentration indicated by the 

gas analyzer, dry basis, ppmv 

Co = average of initial and final system calibration bias check 

responses for the zero gas, ppmv 

Cm = average of initial and final system calibration bias check 

responses for the upscale calibration gas, ppmv 

 Cma = actual concentration of the upscale 

calibration gas, ppmv. 

Response time tests were performed in conjunction with the bias checks. The response time test 

was performed by measuring the time it took for each analyzer to reach 95% of the concentration 
12 

of the high range calibration gas. The zero gas was 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 accuracy ratio factor to the calibration standard (Yi) was 

computed for the individual dry gas meters. A successful calibration for a particular dry gas 

meter would be achieved if each value of Yi was within 2 percent of the average value of Yi (Yi

= 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 H2O) 

at a distinct orifice manometer setting that gives a flow of 0.75 ft3/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 traceable 
13 

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