STANDARD OPERATING PROCEDURES MANUAL

CONTROL OF FUGITIVE DUST EMISSION SOURCES

FOR

COMPLIANCE WITH 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FROM 

SECONDARY LEAD SMELTING

THE BATTERY RECYCLING COMPANY

ARECIBO, PUERTO RICO

JUNE 2011
CONTENTS

1.0 INTRODUCTION 1

1.1 Background 1

1.2 Process Description 1

2.0 FUGITIVE DUST CONTROL PROCEDURES 4

2.1 Plant Roadways 4

2.2 Battery Breaking Area 6

2.3 Furnace Area 6

2.4 Refining and Casting Area 6

2.5 Materials Storage and Handling Area 6

2.52.6 Baghouse Dust Storage and Handling

3.0 DAILY RECORDS 8

FIGURES

Figure 1 Plant Layout

APPENDICES

Appendix 1 Daily Fugitive Dust Log 

Appendix 2 Reuse of Collected Dust
1

1.0 INTRODUCTION

1.1 BACKGROUND

The Battery Recycling Company (TBRC) owns and operates a lead recycling facility in Arecibo, 

Puerto Rico. The National Emission Standards for Hazardous Air Pollutants from Secondary Lead 

Smelting (40 CFR Part 63 Subpart X) or Maximum Achievable Control Technology (MACT) 

standard requires the preparation and implementation of a Standard Operating Procedures (SOP) 

Manual for controlling fugitive dust emission sources.

As defined under Subpart X, a fugitive dust source is: “a stationary source of hazardous air pollutant 

emissions at a secondary lead smelter that is not associated with a specific process or process fugitive 

vent or stack. Fugitive dust sources include, but are not limited to, roadways, storage piles, materials 

handling transfer points, materials transport areas, storage areas, process areas, and buildings.”

At TBRC, fugitive dust sources include:

• Plant roadways

• Battery breaking area

• Furnace areas

• Refining and casting area

• Materials storage and handling area

• Baghouse dust waste storage and handling 

This SOP addresses the elements required by the MACT standard, including:

• Measures used to control fugitive dust sources

• Daily records

1.2 PROCESS DESCRIPTION

Secondary lead smelting at TBRC includes three major operations: scrap pretreatment, smelting, and 

refining. 

Scrap pretreatment is the partial removal of metal and nonmetal contaminants from lead-bearing 

batteries. The batteries are initially placed in an inclined conveyor which brings the batteries into a 

mill to be crushed and separated. In this process, the mill removes the electrolytes from the batteries 

and transfers the fluid through multiple sets of settling tanks. After the last set of settling tanks, the 

electrolyte material is sent to the facility’s wastewater treatment plant. The milling machine shreds 

the plastic battery housings and separates the remaining battery components in water by their 

densities. The separation process produces solid lead (cell plates), lead oxide, separators, and plastic. 

The battery milling system operates independently from the facility furnaces. The operations of the 
2

milling system depends on the amount of raw material (batteries) that are available for processing 

and the amount of lead and lead oxide that is stored. 

Sufficient amounts of lead and lead oxide are stored to allow the facility to continue to operate its 

smelting process even during mill ruptures. Emissions from the furnace operations are not affected 

by the operation of the mill. The battery crushing process is limited to the mill. Batteries are not 

broken or cut before being placed in the mill conveyor., The steel casing of the large industrial 

batteries is removed prior to placing such batteries in the conveyor. No lead dust is generated when 

the steel casing is removed.

Once dried, the lead-containing separated components are prepared to be fed to one of the two

facility rotary furnaces for smelting. Charge preparation is the process of loading the stored lead 

scrap and the other raw materials (soda ash, coal, lead, lead oxides, etc..) to the proper metallurgical 

requirements so it can be charged to the furnaces. Materials are loaded to a rotary steel hopper. 

TBRC loads raw materials into the hopper using one of four tractor loaders that are available at the 

site. Materials are not loaded by hand. To minimize emissions during charge preparation and furnace

loading, some of the following OSHA recommended measures are implemented:

- TBRC provides vehicles with enclosed cabs that have positive pressure, HEPA-filtered air or

employees using the loaders are always required to use full face OSHA approved respirators.

- Surfaces are kept wet and clean through the use of the water supply systems and vacuum 

cleaners.

- Vehicle speeds are reduced to minimize the dust activity.

- All surfaces have been repaved to facilitate housekeeping.

The rotary furnaces are fueled with used oil. Raw materials are charged into the furnaces using a 

rotary steel hopper which is charged into the furnace using a lift truck. Certain additives (soda ash, 

coal, etc.) are blended with the lead-containing components to achieve the desired properties of the 

product. Slag is removed from the furnaces, and the molten lead is then transferred to one of nine

identical kettles for further refining (adding various constituents to achieve desired product 

properties). During the refining process, waste dross is skimmed from the top of the kettles and 

removed for later use. After the refining process has been completed, the lead is shaped into ingots 

(either round or square, depending on the customer’s specification). 

The battery breaking area, furnaces, kettles, slag, and raw materials are located inside covered 

buildings. 

TBRC’s operations do not include a blast furnace, dryer, or an agglomerating furnace; therefore, the 

requirements in the MACT standard related to these emission sources are not applicable.

Currently, the rotary furnaces, nine kettles, and process fugitive sources (lead taps and slag taps) are 

all exhausted to two eight-module baghouse units. A separate area was built for the ingot 
3

preparation. This area is equipped with a exhaust system that collects emissions to be sent to the 

baghouses. The two baghouses exhaust through a common stack. The bags are cleaned by the 

shaker method. A particle detector is installed on each baghouse. 

The following operations at the plant have the potential to generate fugitive dust. These areas 

include:

Plant roadways – Plant roadways include any area of a secondary lead smelter that is subject to 

vehicle traffic, including traffic by forklifts, front-end loaders, or vehicles carrying whole batteries or 

cast lead ingots. Excluded are employee and visitor parking areas that are not subject to traffic by 

vehicles carrying lead-bearing materials. Most of the sources of fugitive dust are inside the main 

plant building. The lead in the raw materials (batteries) coming into the plant and the final product 

(lead ingots) leaving the plant is transported in closed trucks or containers and will not become 

airborne.

Battery breaking area – This is the area of the plant in which lead-acid batteries are broken, crushed, 

and disassembled and separated into components.

Furnace and refining/casting area – This area includes the area where the rotary furnaces are located, 

refining operations occur (i.e., the kettle area), and casting operations occur.

Materials storage and handling area – The materials storage and handling area is any area of the plant 

in which lead-bearing materials (such as, broken battery components, reverberatory furnace slag, flue 

dust, and dross) are stored or handled between process steps including, but not limited to, areas in 

which materials are stored in piles, bins, or tubs, and areas in which material is prepared for charging 

to a smelting furnace.

Baghouse dust storage and handling area – This area includes the building where the baghouses are 

located, and any area where the containers of baghouse dust are stored or handled between the point 

of generation and its reuse in the smelting furnacesincluding, but not limited to, the soda ash storage 

building.
4

2.0 FUGITIVE DUST CONTROL PROCEDURES

This section identifies the procedures that are or will be put into place to control emissions from 

fugitive dust sources. The procedures include the source-specific requirements identified in 

§63.545(c) of the MACT standard.

Figure 1 is a schematic of the plant and shows the location of the various operating areas.

2.1 PLANT ROADWAYS

Truck traffic carrying raw materials (batteries and other lead-bearing scrap) and finished lead-bearing 

product enter and exit at the access gate at the south end of the property. The roads are paved. Plant 

operations (battery breaking, smelting, refining, slag storage, and raw material storage) occur inside 

covered buildings with paved travel surfaces. 

2.1.1 Exterior Plant Roadways

Exterior plant roadways will be cleaned twice per day on days when there is not enough natural 

precipitation to prevent fugitive dust. Roadways include any surface that is subject to vehicle traffic, 

including forklifts, front-end loaders, and vehicles carrying whole batteries or cast lead ingots. 

Employee and visitor parking areas not subject to traffic by vehicles containing lead-bearing 

materials are excluded. 

Cleaning of external roadways will include an appropriate combination of the following: 

• Material removal – Materials deposited on the roadway will be promptly removed to prevent 

entrainment. Since the raw materials are stored indoors in bins, spilled materials are not 

anticipated; however, this bin storage can be a source of fugitive dust and any spilled 

materials will be promptly removed by shovel, broom, or other appropriate method.

• Wetting – Roadway dust in the truck loading/unloading area will be suppressed using a water 

spray system designed to keep the area damp as needed. Wetting suppresses particulate 

matter and helps prevent the material from becoming airborne and binds smaller particles 

together to further prevent them from becoming airborne. Water with no added suppressants 

will be used as needed. The water will be applied using a series of nozzles located throughout

in the yard area.

• Vacuum cleaning – Paved travel roadways that handle lead-bearing traffic will be vacuumed 

as necessary.
5

2.1.2 Interior Travel Surfaces

Areas inside the plant production area are paved and are continuously cleaned and not less frequent 

than twice per day. Cleaning of internal travel surfaces will include the following:

• Material removal – Materials deposited outside of storage bins will be promptly removed to 

prevent entrainment. Spilled materials or materials outside of designated storage areas will be 

promptly removed by shovel, broom, or other appropriate method.

• Vacuum cleaning or wash down – Travel surfaces will be vacuumed or wet washed down, as 

necessary.

2.2 BATTERY BREAKING AREA

The battery breaking area is located inside the production building. Storage piles are contained 

within storage bins within the building. The storage bins consist of walls on three sides enclosing at 

least three-quarters of the perimeter of the stored material, which meets the MACT requirements for 

partial enclosure. The processed material in the battery breaking area is sufficiently wet from the 

process; no additional wetting of the material is necessary to prevent fugitive dust. (There is no dryer 

at the facility.)

2.3 FURNACES AREA

The furnaces area is located inside the production building. The production building is enclosed at 

least three-quarters of the perimeter of the operating area; therefore, the building is considered a 

partial enclosure. Additionally, the paved area within the building is cleaned twice a day as described 

above under Section 2.1.2.

Furnaces Areas

i. TBRC will maintain at all times during operations a face velocity not less than 300 feet per 

minute at the furnace area.

ii. Access doors at the furnaces must be closed during normal operations. Except during the 

charging of raw materials, when an operator needs to access the area, at least one of the four 

doors must remain closed.

iii. After completing any repairs or equipment replacement in the furnaces that could affect the 

face velocity of the hood, the face velocity must be measured to make sure the 300 feet per 

minute requirement is met.

iv. A log of all face velocity measurements must be maintained that indicates the reason or event 

that made taking a measurement necessary.

2.4 REFINING AND CASTING AREA

The refining and casting area is located inside the production building. The production building is 

enclosed at least three-quarters of the perimeter of the operating area; therefore, the building is 
6

considered a partial enclosure. Additionally, the paved area within the building is cleaned twice a day 

as described above under Section 2.1.2.

Kettles

i. BRCTBRC will maintain at all times during operations a face velocity not less than 250 feet 

per minute at the refining kettles.

ii. After completing any repairs or equipment replacement in the kettle area that could affect the 

face velocity of the hood, the face velocity must be measured to make sure the 250 feet per 

minute requirement is met.

iv. A log of all face velocity measurements must be maintained that indicates the reason or event 

that made taking a measurement necessary.

2.5 MATERIALS STORAGE AND HANDLING

Materials are stored and handled inside the production building or slag building. Storage piles are 

contained within storage bins. The storage bins consist of walls on three sides enclosing at least 

three-quarters of the perimeter of the stored material, which meets the MACT requirements for 

partial enclosure. The material inside the production building is sufficiently wet from the process; no 

additional wetting of the material is necessary to prevent fugitive dust. (There is no dryer at the 

facility.) The area inside the building is paved, as is the area near the slag storage building.

2.6 BAGHOUSE DUST WASTE STORAGE AND HANDLING

The dust generated by the baghouses is collected, stored and reused in the smelting furnaces. This 

dust is a listed hazardous waste pursuant to 40 C.F.R.§ 261.

The baghouse hoppers directly discharge the dust waste into open 187-gallon containers. Generally, 

the facility generates about 6 of these containers every day, but this amount can vary depending on 

the intensity of the furnaces operation (e.g. maximum capacity). 

An employee will monitor the container every 2 or 3 hours to verify when it gets full. The designated 

employee must ensure that excessive accumulation does not occur. Once full, each container will be 

carefully washed with an industrial water hose, and then will be covered with a resistant plastic wrap 

to minimize fugitive emissions. The area where the containers are placed, stored or handled between 

will be washed down to remove dust. The water from washing down the containers will go into a 

grid, then to a sump and will end in the water treatment plant to remove lead content. 

Any spilled material will be promptly removed by shovel, broom, or other appropriate method.

A designated employee will take the covered container to the soda ash storage building where it will 

remain until reused and reintroduced into the furnaces along with raw material. The soda ash storage 

building is equipped with a steel security door that must remain closed at all times, except during 

unloading or transfer of the containers to the production building. Operators must ensure that doors 
7

are properly closed.

All employees handling baghouse dust must wear at all times personal protective equipment, 

including respiratory protection devices.
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3.0 DAILY RECORDS

Plant operators have been trained and conduct daily wet suppression, pavement cleaning, and vehicle 

washing activities performed to control fugitive dust emissions. Records of events or conditions not 

allowing daily controls will be kept at the site.
APPENDIX 1

DAILY FUGITIVE DUST LOG
THE BATTERY RECYCLING COMPANY

DAILY FUGITIVE DUST LOG

NOTE: CHECK ITEMS TWICE PER DAY

DATE:

Item to Check

First Daily 

Check

Second Daily 

Check Comments (Indicate if 

raining and identify any 

problems encountered.)

Yes/

No

Time/

Initials

Yes/

No

Time/

Initials

Wet Suppression – Piles:

Indoors – Are piles wet 

enough to prevent fugitive 

dust?

Slag pile – Is pile wet enough 

to prevent fugitive dust? 

(Check spray nozzles and 

water supply)

Pavement Cleaning – Exterior:

Is wet suppression in yard 

working adequately? (Check 

spray nozzles and water 

supply) 

Start time for pavement 

cleaning

End time for pavement 

cleaning

Pavement Cleaning – Interior:

Start time for cleaning

End time for cleaning

Vehicle Washing:

Wash system operating?

Baghouse Dust Waste 

Storage and Handling Area:

Start time for cleaning

End time for cleaning
THE BATTERY RECYCLING COMPANY

APPENDIX 2

Reuse of Collected Dust
THE BATTERY RECYCLING COMPANY

Reuse of Collected Dust

Dust collected from the facility baghouses and the cleaning of the main building floor is reused and 

reintroduced into the furnace. 

Proper handling of the collected dust can be accomplished in four steps: 

1. Maintaining the hopper doors closed at all times except during unloading,

2. Frequently (at least once per day) removing dust from baghouse hoppers or building floor 

areas,

3. Enclose or cover containers used to transport collected dust from dust collection system,

4. Wearing at all times appropriate personal protection equipment during handling of collected 

dust,

5. TBRC provides vehicles with enclosed cabs that have positive pressure, HEPA-filtered air or

employees using the loaders are always required to use full face OSHA approved respirators.

Hopper Doors 

Hopper doors must be kept closed at all times, except during unloading operations. Operators must 

ensure that doors are properly sealed and the excessive accumulation does not occur. Operators must 

notify Shift Supervisor if the hopper is overloaded.

Removing Dust from Hopper

Collected dust must be removed on a daily basis. 

Moving Collected Dust

After the dust has been removed from the collector hopper, it must be transported back to the 

furnaces to be mixed with the charge preparation. The charge preparation is the process of loading 

the stored lead scrap and the lead from with the other raw materials (soda ash, coal, lead, lead oxides, 

etc..) to the proper metallurgical requirements so it can be charged to the furnace. Materials are 

loaded to a steel hopper. TBRC loads raw materials into the hopper using one of four tractor loaders 

that are available at the site. Materials are not loaded by hand. To minimize emissions during charge 

preparation and furnace loading, some of the following OSHA recommended measures are 

implemented:

- TBRC provides vehicles with enclosed cabs that have positive pressure, HEPA-filtered air or 

employees using the loaders are always required to use full face OSHA approved respirators.

- Surfaces are kept wet and clean through the use of water supply systems and vacuum 

cleaners.

- Vehicle speeds are reduced to minimize the dust activity.

- All surfaced have been repaved to facilitate housekeeping.

Dust collected from the building floors must be placed with the charge preparation with every batch.

Vehicles and Protective Equipment

TBRC must provide vehicles with enclosed cabs that have positive pressure, HEPA-filtered air. 
THE BATTERY RECYCLING COMPANY

Employees using the loaders or handling collected dust must always use full face OSHA approved 

respirators.