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

To: rkemp@environcorp.com

CC: Nizich.Sharon@epamail.epa.gov; Danny.Greene@erg.com;

Robert.Steinwurtzel@bingham.com; Michael.Wigmore@bingham.com

Date: 4/26/2010 3:34 PM

Subject: RE: Secondary Lead - MACT and Residual Risk

Attachments: draft 2nd Pb 114 cover letter 042610.doc; draft 2nd Pb Enclosure 1 (survey) 042310.xls; 

draft 2nd Pb Enclosure 2 (test plan) 042610.doc

Hi Russell,

 Thank you for helping to organize our upcoming meeting. As

you know, the Clean Air Act requires EPA to conduct a review of the

residual risks (under Section 112(f)) and a technology review (under

Section 112(d)(6)) within 8 years after promulgation of the MACT

standard. As you know, the 8 year deadline for the reviews of the

MACT standard for Secondary Lead Smelters passed by awhile ago....

EPA is now on schedule to conduct and finalize these reviews within the

next 19 months or so. I will explain the schedule in more detail when

we meet. Nevertheless, EPA must complete the Residual Risk and

Technology Reviews (RTRs) for Secondary Lead Smelters relatively soon.

 In order to complete this mandate, EPA will need sufficient

data and information on emissions, processes, and controls for Secondary

Lead Smelters. Therefore, in order to obtain such data, we are

planning to send an information collection request (ICR) to several

companies to request data and information on emissions of hazardous air

pollutants, processes, controls and other relevant information. We

believe that some emissions testing will also be needed.

 Therefore, we have produced a draft letter, a draft questionnaire

survey (enclosure 1), and a draft request for emissions testing

(enclosure 2), which are attached below. We welcome you and your

colleagues to review these draft documents. Could you and your

colleagues please review the attached draft documents and be prepared to

discuss them at the meeting on May 4, 2010. Also, please send us

written comments and suggestions by May 6, 2010.

 Thank You.

 Chuck French

(See attached file: draft 2nd Pb 114 cover letter 042610.doc)(See

attached file: draft 2nd Pb Enclosure 1 (survey) 042310.xls)(See

attached file: draft 2nd Pb Enclosure 2 (test plan) 042610.doc)

 

From: "Russell Kemp" <rkemp@environcorp.com> 

 

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

 

Cc: "Wigmore, Michael B." <Michael.Wigmore@bingham.com>, "Steinwurtzel, Robert N." 

 <Robert.Steinwurtzel@bingham.com> 
 

Date: 04/21/2010 11:19 AM 

 

Subject: RE: Secondary Lead - MACT and Residual Risk 

 

Good morning Chuck.

Mike Wigmore, ABR outside counsel at Bingham McCutchen, at I are both

available to come and meet with you and your team at RTP on May 4. I

believe we will both try to do a turnaround that day without spending

the night so a late morning or early afternoon meeting would be

preferable.

Please advise of your preferred time and expected duration of the

meeting, along with address, so that we can plan travel accordingly.

Most importantly, can you please provide an agenda of the topics you

would like to cover and, to the extent we will be discussing any draft

documents (questionaire, etc.), we would most appreciate having them for

advance review prior to the meeting so as to make the meeting more

productive, as we have indicated previously.

Upon receipt of your confirmation of this meeting date and time we can

proceed with making our travel arrangements.

Thanks and have good morning.

Russell

Russell S. Kemp, PE

Principal

ENVIRON International Corporation

1600 Parkwood Circle, Suite 310

Atlanta, Georgia 30339

(Tel) 678-388-1654

(Fax) 770-874-5011

(Cell) 404-374-7836

rkemp@environcorp.com

-----Original Message-----

From: French.Chuck@epamail.epa.gov [mailto:French.Chuck@epamail.epa.gov]

Sent: Tuesday, April 20, 2010 11:00 AM

To: Russell Kemp

Subject: Secondary Lead - MACT and Residual Risk

Hi Russell,

 I look forward to the ABR meeting and the opportunity for
discussing the MACT and plans for residual risk assessment, etc...

However, I am also thinking that maybe we should meet beforehand to

discuss this and related issues (e.g., a possible questionnaire and

emissions data, etc...).

 Would you and some of your colleagues be available to meet (in

person and/or by teleconference) in late April (e.g., on 4/29 or 4/30)

or early May (e.g., 5/3 or 5/4) to discuss the RTR for Secondary Lead

and related issues?

Thank You.

Chuck French

This message contains information that may be confidential, privileged

or otherwise protected by law from disclosure. It is intended for the

exclusive use of the Addressee(s). Unless you are the addressee or

authorized agent of the addressee, you may not review, copy, distribute

or disclose to anyone the message or any information contained within.

If you have received this message in error, please contact the sender by

electronic reply to email@environcorp.com and immediately delete all

copies of the message.
Draft – Under Development – Do Not Cite or Quote 

Secondary Lead Smelting ICR and Testing Request (04/23/10) 

[insert corporate environmental contact name] 

[insert contact title] 

[insert parent company name] 

[insert parent company street address] 

[insert parent company city, state, and ZIP code] 

Dear [insert corporate environmental contact name]: 

Pursuant to section 114 of the Clean Air Act (CAA), the Environmental Protection 

Agency (EPA) is requesting that you provide the information described in Enclosures 1 and 2 to 

this letter. This Information Collection Request (ICR) is being conducted by the EPA Office of 

Air and Radiation (OAR) to assist the EPA Administrator in conducting her review obligations 

pursuant to CAA sections 112(d)(6) and 112(f)(2) with respect to the secondary lead smelting 

source category. EPA understands that your company, [insert parent company name], owns and 

operates one or more secondary lead smelting facilities (NAICS code 331492). 

On June 23, 1995, the EPA issued National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for secondary lead smelting (40 CFR part 63, subpart X) under section 

112 (d) of the CAA. As required under CAA section 112(d)(6), EPA must review, and revise as 

necessary, promulgated emission standards at least every 8 years to account for developments in 

practices, processes, and control technologies. In addition, under section 112(f), EPA must 

consider whether residual risks remain that warrant more stringent standards than the 

technology-based standards that implement section 112 (d), and specifically whether more 

stringent standards are required to provide an ample margin of safety to protect public health, or 

whether (taking into consideration costs, energy, safety, and other relevant factors) more 

stringent standards are needed to prevent an adverse environmental effect. 

This ICR has two parts: a survey and an emission testing requirement. The first part is a 

survey questionnaire (which is provided in enclosure 1) that requests available information on 

process equipment, control devices and other relevant aspects of each secondary lead smelting 

facility that you operate. The survey questionnaire also requests that you provide existing 

information and data on emissions of hazardous air pollutants and particulate matter for each 

secondary lead smelting facility that is owned by [insert parent company name]. To facilitate 

preparation and submittal of the available information on emissions, process equipment and 

control devices, we are providing electronic copies of the survey in Enclosure 1. Please 

complete the survey in electronic form for all secondary lead smelting facilities owned or 

operated by [insert parent company name] and send the completed surveys and existing 

emissions test data and information no later than [insert date 30 days after mail date], to Chuck 

French at the address noted below. If there is a limiting factor that precludes you from 

submitting your data electronically, please contact Chuck French to discuss other options for data 

submission. 
2

We are providing the survey in electronic spreadsheet format. The electronic response 

forms consist of Microsoft® Excel 2003 workbook files that contain each of the required 

response forms discussed in Enclosure 1. Enclosure 1 also contains a summary of the 

information we request including specific form-by-form instructions to assist you in completing 

your response. Please refer to this material in completing your response. You may respond 

“not applicable” to questions that ask for information on processes that do not exist at your 

secondary lead smelting operations. An electronic copy of the survey is included on the CDROM accompanying this letter. 

The second part of this ICR requires emissions testing for emission sources at your 

facilities, which will provide EPA with data on hazardous air pollutants, particular matter, and 

total hydrocarbons emitted by your facilities. Enclosure 2 describes the testing requirements and 

identifies the process units to test. Please complete and submit emissions test results within 90 

days of the date of this letter to the applicable address specified below. 

In lieu of new testing, existing and well-documented test data from your current 

operations that you consider representative and that used the recommended test methods 

identified in Table 1.2 in Enclosure 2 can be submitted. If you intend to submit existing test data 

for current operations, please submit the data within 30 days of receiving this ICR to the 

applicable address specified below. Also, in lieu of the stack testing for all operations requested 

by this ICR, it may be acceptable to test a subset of your operations if you can demonstrate that 

the tested subset is representative of the untested subset. Prior EPA approval is required if you 

choose to test a subset of your operations. If you intend to test a representative subset of your 

operations in lieu of all the testing requested in this ICR, you must request approval from EPA 

within 30 days of receiving this ICR. Please note that if EPA determines that any of the existing 

data that you submit or the proposed subset of your operations to be tested are not representative, 

you will need to conduct the testing required by this ICR and submit the test results within 90 

days of receiving this ICR. Additional information regarding the sampling and emissions testing 

requirements can be found in Enclosure 2. Electronic copies of all related forms and 

spreadsheets for reporting emission test results are included on the CD-ROM accompanying this 

letter. 

In addition to considering the results of this testing in its assessment as to whether more 

stringent standards are needed to protect public health and the environment, EPA will also 

consider emissions allowed by the section 112 (d) NESHAP for secondary lead sources, as well 

as emissions allowed by source’s Title V permits. 

EPA’s legal authority to obtain the information requested in the survey and through 

emissions testing is contained in section 114 of the CAA, as amended (42 U.S.C. §7414). 

Enclosure 3 contains a summary of this authority. If you believe that disclosure of any specific 

information that you submit would reveal a trade secret, clearly identify such specific 

information as confidential. Please do not label an entire response “confidential” if only certain 

portions consist of trade secret information. Refer to Enclosure 3 for the information EPA may 

require, at a later time, to support your confidentiality claims. Any information subsequently 

determined to constitute a trade secret will be protected under 18 U.S.C. §1905. If no claim of 

confidentiality accompanies the information when it is received by EPA, it may be made 

available to the public by EPA without further notice (40 CFR §2.203(a)(2)). (See 40 CFR part 
3

2, subpart B, for EPA’s regulations regarding the confidentiality of business information.) 

Because section 114(c) of the CAA exempts emission data from claims of confidentiality, the 

emission data you provide may be made available to the public. A clarification of what EPA 

considers to be emission data is contained in Enclosure 4. 

We have contracted Research Triangle Institute (RTI) and Eastern Research Group 

(ERG) (Contract No. EP-D-06-118) to help us gather information about your secondary lead 

smelting operations, conduct the survey and analyze the survey data, sampling results, and 

emissions test results. As noted in Enclosure 5, we have designated RTI and ERG to be our 

authorized representatives. Therefore, RTI and ERG have the same rights discussed above and 

in Enclosure 3. This means that RTI and ERG will have access to all information provided to us 

in your completed survey, sampling results, and emissions test results. As designated 

representatives of the Agency, RTI and ERG are subject to the provisions of 42 U.S.C. §7414(c) 

respecting confidentiality of methods or processes entitled to protection as trade secrets. 

Enclosure 6 summarizes our policies and procedures for handling trade secret 

(confidential) information and describes how our contractors also are required to use the same 

procedures as we do. Because our contractors or other authorized representatives are required to 

follow the requirements in Enclosure 6, we believe that we can ensure your rights and protect 

any privileged information you submit to us. 

Please mail the completed non-confidential survey response and emission test results on 

CD-ROM or DVD-ROM disk to: 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Program Division, Metals and Minerals Group 

Mail Code D243-02 

Attn: Mr. Chuck French 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

If you would prefer, you may electronically submit to the following Secondary Lead ICR 

Website: http://www2.ergweb.com/projects/SecondaryLeadSurvey/index.html. If you choose to 

access and use the website, enter the following user ID and password information when 

prompted: 

User ID: 

Password: 

If you are submitting confidential business information (CBI) as described in 

Enclosure 3, then this information must be mailed to EPA on CD-ROM or DVD-ROM disk 

under separate cover to the attention of Mr. Roberto Morales at the address below. Clearly mark 

the disk and/or the materials with the words “Confidential Business Information” and send either 

via U.S. Postal Service Express Mail, registered mail, or private courier to: 
4

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer (Project 09-01) 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

Additionally, if you are submitting CBI on CD-ROM or DVD-ROM disk, you must also 

submit a non-CBI version of your survey response to the mailing address listed above. DO NOT 

SEND CONFIDENTIAL BUSINESS INFORMATION TO EPA BY EMAIL OR FAX 

MACHINE OR TO THE PROJECT WEBSITE.

We believe that it is advisable for each facility subject to emissions testing as part of this 

ICR to prepare a site-specific test plan prior to testing. A site-specific test plan addresses the 

planning and quality assurance and quality control procedures and acceptance criteria for all of 

the testing including the collection of process data. Enclosure 7 provides guidance for 

developing a test plan. 

Please note that you do not have to submit a test plan to EPA for approval prior to testing. 

However, the EPA Electronic Reporting Tool (ERT) Version 3, in which EPA requires that data 

be reported, requires that a test plan be entered into the program prior to submitting test results. 

Enclosure 8 provides an example of the EPA ERT Version 3 test plan. 

We are also requesting that you notify your state air regulatory agency or designated 

permitting authority at least 21 days before the requested stack tests are scheduled to begin. 

If you have questions regarding this request, please contact Mr. Chuck French, Metals 

and Minerals Group, at (919) 541-7912 or french.chuck@epa.gov. Please return to Mr. French 

the completed survey responses by (insert date 30 days after mail date) and the sampling and 

emissions test results by (insert date 90 days after mail date). 

Thank you for your assistance in this effort. 

 Sincerely, 

Peter Tsirigotis 

Director 

Sector Policies and Programs Division 

8 Enclosures 

Enclosure 1: Secondary Lead Smelting Survey 
5

Enclosure 2: Test Procedures, Methods, and Reporting Requirement 

Enclosure 3: EPA’s information gathering authority (section 114 of the CAA) 

Enclosure 4: Clarification of what EPA considers to be emissions data 

Enclosure 5: Summary of contractor’s authority as representative of EPA 

Enclosure 6: Procedures for safeguarding CBI under the CAA 

Enclosure 7: Site Specific Test Plant Development Guidance 

Enclosure 8: Example EPA ERT Version 3 test plan 

cc: State and Regional 
Form

A-1

A-2

A-3

B

C-1

C-2

C-3-a

C-3-b

C-4

C-5

C-6

C-7

C-8

D-1

D-2

D-3

D-4

D-5

E

F

G-1

G-2

H-1

H-2-a

H-2-b

H-2-c

H-2-d

H-2-e

H-2-f

I

email at french.chuck@epa.gov. 

You should never use email to transmit confidential information, as this is not a secure form of communication. For security of your

data, we recommend sending your confidential files to Mr. Morales via Registered U.S. Mail using return receipt requested, Federal Express, or

other method for which someone must provide a signature upon receipt. 

If you have any questions regarding this information request, please contact Charles French by phone at (919) 541-7912, or by 

Roberto Morales

c/o Charles French

U.S. EPA Mailroom (C404-02)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

as follows:

• Email electronic copies of the survey forms and emissions test reports to secondaryleadsurvey@erg.com. 

If you are submitting Confidential Business Information (CBI), please mail a separate CD or DVD hardcopy containing only the CBI portion of 

your data under separate cover. Send the files to:

Emissions Test Data Casting Operations

We request that you complete the survey forms that apply to your facility based upon existing information. No additional 

Emissions Sources Other Than Secondary Lead Smelting Processes

monitoring or emissions testing is required to respond to this information request. Please make additional copies of the individual survey

tables, as needed, to accommodate the number of process equipment and emission control devices located at your facility. 

We request that the completed survey and emissions test reports be returned to EPA by [insert due date ]. You may submit your data

Emissions Test Data

Emissions Test Data Raw Material Processing Operations

Emissions Test Data Charging Material Handling Operations 

Emissions Test Data Feed Dryer Operations

Emissions Test Data Furnace Operations

Emissions Test Data Refining and Alloying Operations

Baghouses

Gas Scrubbers

Fugitive Dust Control

Control Device Cost Information

Startup and Shutdown Information

Startup and Shutdown Information Continued

Emissions Point Information

Charging Material Handling

Feed Dryers

Smelting Furnace

Refining and Alloying

Casting

Emission Control System Overview

Title 

Afterburner or Thermal Oxidizers

Facility Contact Information

Facility Information

Parent Company Information

Process Unit Regulations

Process Description

Raw Material Storage

Raw Material Processing

Raw Material Processing Description

Draft – Under Development – Do Not Cite or Quote

Secondary Lead Smelting Process Equipment and Control Device Questionnaire

into elemental lead or lead alloys by smelting. This survey consist of the following forms:

smelting facility is defined as a facility at which lead-bearing scrap material, primarily, but not limited to, lead-acid batteries, is recycled 

equipment and emission control devices at your secondary lead smelting facility. For the purposes of this survey, a secondary lead 

We, at the EPA, pursuant to Section 114 of the Clean Air Act, are seeking the information requested in this survey for the process

Page 1 of 1

DRAFT PVC Section 114 Survey Part 1

06/23/2009
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

1 of 10 

Draft – Under Development – Do Not Cite or Quote 

Test Procedures, Methods, and Reporting Requirements for the 

Information Collection Request for the Secondary Lead Smelting 

Source Category 

This document provides an overview of approved methods, target pollutants, units of measure, 

and reporting requirements for the secondary lead smelting source category. All recipients must 

complete and submit test results no later than (insert date 90 days after mail out). This document 

will be referred to as the “Secondary Lead Smelting test program.” This document is organized 

as follows: 

1.0 Sampling and Testing Procedures and Methods 

2.0 How to Report Data 

3.0 How to Submit Data 

4.0 Contact Information for Questions on Test Plan and Reporting 

1.0 Sampling and Analyses Procedures and Methods 

The EPA Secondary Lead Smelting test program requires you to conduct emissions tests for 

several pollutants. You must perform new stack tests (or submit reports of previously conducted 

tests) that are representative of current operations at each emission point and each unique process 

unit (described in this enclosure) that you operate. If you intend to submit existing test data for 

current operations, please submit the data within 30 days of receiving this ICR to the applicable 

address specified in Section 3.0. If you intend to test a representative subset of your operations 

in lieu of all the testing requested in this ICR, you must request approval from EPA within 30 

days of receiving this ICR. Please note that if EPA determines that any of the existing data that 

you submit or the proposed subset of your operations to be tested are not representative, you will 

need to conduct the testing required by this ICR and submit the test results within 90 days of 

receiving this ICR. 

You must submit the results of certain stack tests using EPA’s Electronic Reporting Tool (ERT) 

Version 3. Section 2.1 of this enclosure indicates which EPA methods require reporting using 

the ERT. You need not use the ERT to submit reports of previously conducted testing but those 

reports must be complete including clear documentation of the process operations during the 

testing period, summaries of results, raw and fuel materials descriptions, field sample collection 

records and data sheets, analytical data sheets, and discussions of the emissions calculations. 

The stack testing procedures are summarized below. 

1.1 Stack Testing Procedures and Methods 

If you operate a secondary lead smelting facility, you must conduct stack sampling to determine 

your emissions, if any, of the following pollutants: 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

2 of 10 

Arsenic compounds, 

Benzene, 

Beryllium compounds, 

1,3-Butadiene, 

Cadmium compounds, 

Chromium compounds, 

Dioxins/furans, 

Lead compounds, 

Manganese compounds, 

Mercury compounds, 

Naphthalene, 

Nickel compounds, 

Particulate matter (filterable), 

Particulate matter (condensable and filterable PM2.5), and 

Total hydrocarbons. 

At a minimum, you must complete stack emissions testing for the process units and emission 

sources listed in the following table if you operate a secondary lead smelting facility. 

Table 1.1: Summary of Secondary Lead Smelting Facilities Emissions Stack Testing Locations and 

Pollutants 

Emissions Source Pollutant(s) to Test

Raw Material Storage (enclosed 

areas only) 

Arsenic compounds, Beryllium compounds, Cadmium compounds, Chromium 

compounds, Lead compounds, Manganese compounds, Mercury compounds, 

Nickel compounds, and Particulate matter (filterable; filterable and condensable 

PM2.5). 

Furnace Charging

Arsenic compounds, Benzene, Beryllium compounds, 1,3-Butadiene, Cadmium 

compounds, Chromium compounds, Dioxins/furans, Lead compounds, 

Manganese compounds, Mercury compounds, Naphthalene, Nickel compounds, 

Particulate matter (filterable; filterable and condensable PM2.5) and Total 

Hydrocarbons. 

Blast Furnace

Blast Furnace collocated with a 

Reverberatory Furnace 

Reverberatory Furnace

Rotary Furnace

Other Furnace

Refining and Alloying 

Operations 

Arsenic compounds, Beryllium compounds, Cadmium compounds, Chromium 

compounds, Lead compounds, Manganese compounds, Mercury compounds, 

Nickel compounds, and Particulate matter (filterable; filterable and condensable 

PM2.5). 

Casting Operations 

1.2 How to Select Emissions Sample Location and Gas Composition Analysis Methods 

If your emissions measurement location is in a stack or duct, use EPA Method 1 of Appendix A 

of Part 60 to select the locations and number of traverse points for sampling. See 

http://www.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance 

information. If your emissions measurement location is the outlet of a positive pressure fabric 

filter (i.e., roof monitor or multiple short stacks), use EPA Method 5D, sections 8.1 and 8.2 to 

determine the measurement site and the sample traverse points locations (see 

http://www.epa.gov/ttn/emc/promgate/m-05d.pdf). Use EPA Methods 3A or 3B of Appendix A 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

3 of 10 

of Part 60 for analysis of flue gas composition, including oxygen concentration. See 

http://www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or 

http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information. 

1.3 Stack Test Methods 

Conduct the emissions testing at the outlet to the atmosphere of each emissions control system 

(e.g., baghouse, thermal oxidizer, afterburner, gas scrubber) used to reduce emissions from 

secondary lead smelting production operations. The test results should indicate on which control 

device the testing was performed using the emission point identifications corresponding to Forms 

C-1 through C-8 of the survey and the control device identifications corresponding to Forms D-1 

through D-5 of the survey, as applicable. For emissions testing, Table 1.2 presents a summary of 

the recommended emission test methods for each pollutant and possible alternative methods. 

If you would like to use a method not on this list, please contact EPA for approval of an 

alternative method. Please direct test method and reporting questions to Chuck French at (919) 

541-7912 or french.chuck@epa.gov. 

Each test should include three test runs at the sampling location. Testing is to be performed for 

the identified pollutants on a one-time basis after the last control device (i.e., stack or other point 

representing the composition of the gases at the exit to the atmosphere). All testing should be 

performed on the outlet of the last control device. All pollutant concentrations should be 

corrected to 7% oxygen and should be reported on a dry basis. The recommended units of 

concentration for each pollutant vary, and are listed in Table 1.2. Report the results of the stack 

tests according to the instructions in Section 2.0 of this enclosure. Include the corresponding 

emissions point identification designated in Forms C-1 through C-8 of the survey and the control 

device identifications corresponding to Forms D-1 through D-5 of the survey, as applicable, with 

the test results. In addition to the stack emissions test data, we also require a report of the 

applicable process information taken at the time of the emissions test, depending on the emission 

point being sampled, as outlined in Table 1.3. 

For copies of the recommended U.S. EPA methods and additional information, please refer to 

EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. 

Table 1.2: Summary of Test Methods and Alternative Methods 

Pollutant or 

Parameter Recommended Method*

Test Runs and 

Duration 

Reported Units 

of Measure 

Flow rate 

EPA Method 2 for single stacks or ducts; 

EPA Method 5D, section 8.3 for positive pressure 

fabric filters 

Simultaneous with each 

pollutant test run 

dscm/min 

O2 and CO2 EPA Method 3A or Method 3B Simultaneous with each 

pollutant test run 

Volume percent

dry 

Moisture

content EPA Method 4 Simultaneous with each pollutant test run 

Volume percent 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

4 of 10 

Pollutant or 

Parameter Recommended Method*

Test Runs and 

Duration 

Reported Units 

of Measure 

HAP metals, 

including 

mercury, 

arsenic, 

cadmium, 

chromium, 

berylium, and 

nickel, and PM 

(filterable) 

EPA Method 29. Determine total filterable PM 

emissions simultaneously according to section 

8.3.1.1. Use IC(A)P/MS for the analytical finish. 

Report all metals results. 

At least 3 runs with a 

minimum sample 

volume of 3.4 m3 per 

run. 

mg/dscm @ 7 

percent O2

PM2.5

(filterable and 

condensable) 

EPA OTM 28 and EPA OTM 27 

At least 3 runs with a 

minimum sample 

volume of 3.4 m3per 

run (test runs are to be 

conducted 

simultaneously with the 

HAP metals tests). 

mg/dscm @ 7 

percent O2

Hexavalent 

Chromium 

(Cr+6) 

EPA SW-846 Method 0061 

At least 3 runs with a 

minimum sample 

volume of 3.4 m3per 

run. 

μg/dscm @ 

7percent O2

Total 

hydrocarbons 

EPA Method 25A 

At least 3 runs 

simultaneous with and 

for the same duration as 

the Method 23 test runs. 

ppmvd as propane 

@ 7 percent O2

Benzene, 1,3-

Butadiene, and 

Naphthalene 

EPA SW-846 Method 0031. Use EPA SW-846 

Methods 5041A and 8260B for the analytical 

finish. 

At least 3 runs with a 

minimum sample 

volume of 3.4 m3per 

run. 

mg/dscm @ 7 

percent O2

Dioxins/Furans

(for blast 

furnaces and 

collocated 

blast and 

reverberatory 

furnaces only) 

EPA Method 23

At least three test runs 

with a minimum sample 

volume of 3.4 m3per 

run. 

ng/dscm @ 

7percent O2

Table 1.3: Summary of Process Parameter Data to be Recorded with Stack Emissions Testing 

Emission Point Being 

Sampled Parameter Units Duration 

Raw Material Storage 

Dimensions of storage 

pile (length, width, 

height) 

Feet

3 hours before, 

during, and 3 

hours after 

sampling 

Face velocity at enclosure 

openings 

Feet per second 

Raw Material Processing 

Raw material throughput Tons/hr 3 hours before, 

during, and 3 

hours after 

sampling 

Face velocity at enclosure 

openings 

Feet per second 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

5 of 10 

Emission Point Being 

Sampled Parameter Units Duration 

Charging Material 

Handling 

Charging material 

throughput Tons/hr 3 hours before, 

during, and 3 

hours after 

sampling 

Face velocity at enclosure 

openings 

Feet per second 

Feed Dryer 

Feed material charge rate Tons/hr 3 hours before, 

during, and 3 

hours after 

sampling 

Dryer operating 

temperature 

o

F 

Furnaces 

Feed material charge rate 

Tons/hr 

3 hours before, 

during, and 3 

hours after 

sampling 

Furnace operating 

temperature 

o

F 

Lead production rate Tons/hr 

Refining and Alloying 

Operations 

Lead production rate Tons/hr 

3 hours before, 

during, and 3 

hours after 

sampling 

Casting Operations Lead production rate Tons/hr 

3 hours before, 

during, and 3 

hours after 

sampling 

2.0 How to Report Data 

The method for reporting the results of any testing and monitoring requests depend on the type of 

tests and methods used to complete the test requirements. This section discusses the 

requirements for reporting the data. 

2.1 Reporting Stack Test Data 

If you conducted a stack test, or are submitting a previously conducted stack test, using one of 

the methods listed in Table 2.1, you must report your data using the EPA ERT Version 3. There 

are no ‘optional’ test data for this section 114 response: all data fields in the EPA ERT are 

required fields. At present, only the methods identified in Table 2.1 below are supported by the 

ERT. ERT is a Microsoft® Access database application. Two versions of the ERT application 

are available. If you are not a registered owner of Microsoft® Access, you can install the runtime 

version of the ERT Application. Both versions of the ERT are available at 

http://www.epa.gov/ttn/chief/ert/ert_tool.html. The ERT supports an Excel spreadsheet 

application (which is included in the files downloaded with the ERT) to document the collection 

of the field sampling data. After completing the ERT, you will also need to attach an electronic 

copy of the emission test report (PDF format preferred) to the Attachments module of the ERT. 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

6 of 10 

Table 2.1: List of Test Methods Supported by ERT 

Test Methods Supported by ERT

Methods 1 through 4

Method 7E

Method 6C

Method 5

Method 3A

Method 29

Method 26A

Method 25A

Method 202

Method 201A

Method 17

Method 101

Method 101A

Method 10

Method 23

CT Method 40 (OTM 28)

CT Method 39 (OTM 27)

If you have a PM CEMS that meets Performance Specification 11 installed at your secondary 

lead smelting operation, and you used CEMS data to meet PM test requirements at your facility, 

you must report daily averages from the last 30 days (including those days where manual testing 

was conducted) of CEMS data in a Microsoft® Excel CEMS Template: 

“SecPbSURVEY_CEMS_PS11_(Company)_(Facility)_(ProcessUnitID).xls 

You must complete the Microsoft® Excel Template to report hexavalent chromium using EPA 

SW-846 Method 0061. Separate tabs are provided for each test method in the following template 

file: 

 

“SecPbSURVEY_ SW-846 Method 0061_(Company)_(Facility)_(ProcessUnitID).xls” 

The Excel templates are specific to each pollutant and type of unit and they can be downloaded 

from (http://www2.ergweb.com/projects/SecondaryLeadSurvey/). Rename and submit the 

worksheet following the guidance in Enclosure 1. 

2.2 Reporting Stack Test Measured Values Below the Detection Level 

Identify the status of measured values relative to detection levels on the spreadsheet or in the 

ERT using the following descriptions: 

• BDL (below detection level) – all analytical values used to calculate and report an instack emissions value are less than the laboratory’s reported detection level(s); 

• DLL (detection level limited) – at least one but not all values used to calculate and report 

an in-stack emissions value are less than the laboratory’s reported detection level(s); or 

• ADL (above detection level) – all analytical values used to calculate and report an instack emissions value are greater than the laboratory’s reported detection level(s). 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

7 of 10 

For each reported emissions value, insert the appropriate flag (BDL, DLL, or ADL) in the Note 

line of Excel emission test spreadsheet template or in the Comments line of the Electronic 

Reporting Tool (ERT). 

When reporting and calculating individual test run data: 

• For analytical data reported from the lab as “nondetect” or “below detection level;” 

− Include a brief description of the procedures used to determine the analytical 

detection and in-stack detection levels: 

o In the Note line of Excel emission test spreadsheet template; or 

o In the Comments line of Lab Data tab in the Run Data Details in the ERT. 

− Describe these procedures completely in a separate attachment including the 

measurements made, the standards used, and the statistical procedures applied. 

− Calculate the in-stack emissions rate for any analytical measurement below 

detection level using the relevant detection level as the “reported” value. 

− Report the calculated emissions concentration or rate result: 

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Note line; or 

o As a numerical value in the ERT with the appropriate flag in the 

Comments line. 

− Report as numerical values (i.e., no brackets or < symbol) any analytical data 

measured above the detection level including any data between the analytical 

detection level and a laboratory-specific reporting or quantification level (i.e., flag 

as ADL). 

• For pollutant measurements composed of multiple components or fractions (e.g., Hg and 

other metals sampling trains) when the result for the value for any component is 

measured below the analytical detection level: 

− Calculate the in-stack emissions rate or concentrations as outlined above for each 

component or fraction; 

− Sum the measured and detection level values as outlined above using the in-stack 

emissions rate or concentrations for all of the components or fractions; and 

− Report the sum of all components or fractions: 

o As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Note line; or 

o As a numerical value in the ERT with the appropriate flag in the 

Comments line. 

− Report also the individual component or fraction values for each run if the Excel 

emission test spreadsheet template or ERT format allows; if not (i.e., the format 

allows reporting only a single sum value): 

o For the Excel emission test spreadsheet template, next to the sum reported 

as above report in the Notes line the appropriate flag along with the values 

for the measured or detection level value for each component or fraction 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

8 of 10 

as used in the calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four 

fraction sample); 

o For the ERT, next to the sum reported as above, report on the Comments 

line the appropriate flag and the measured or detection level value for each 

component or fraction as used in the calculations (e.g., 0.036, [<0.069], 

1.239, [<0.945] for a four fraction sample). 

• For measurements conducted using instrumental test methods (e.g., Method 3A): 

− Record gaseous concentration values as measured including negative values and 

flag as ADL; do not report as BDL. 

− Calculate and report in-stack emissions rates using these measured values 

− Include relevant information relative to calibration gas values or other technical 

qualifiers for measured values in Comments line in the ERT.

• When reporting and calculating average emissions rate or concentration for a test when 

some results are reported as BDL: 

− Sum all of the test run values including those indicated as BDL or DLL as 

measured values. 

− Calculate the average emissions rate or concentration (e.g., divide the sum by 3 

for a three-run test). 

− Report the average emissions rate or concentration average: 

o As a bracketed “less than” detection level value (e.g., [<20.06]) in the 

Excel emission test spreadsheet template and include the appropriate flag 

in the Note line. 

o As a numerical value in the ERT and include the appropriate flag in the 

Comments line. 

3.0 How to Submit Data 

To submit your data (survey response and emissions testing data): 

• Please submit the completed non-confidential survey response to the submittal link provided 

on the following website: 

http://www2.ergweb.com/projects/SecondaryLeadSurvey/

or you can mail the completed non-confidential survey response on a CD-ROM or DVDROM disk to: 

Chuck French 

U.S. EPA Office of Air Quality Planning and Standards 

Sector Policies and Program Division, Metals and Minerals Group 

Mail Code D243-02 

Research Triangle Park, NC 27711 
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

9 of 10 

• If the process data or other information you are providing is considered confidential, please 

create a separate CD or DVD containing only the confidential portion of your data or prepare 

a copy of the hard copy materials containing only the pages that include the information you 

consider confidential. Clearly mark the disk and/or materials with the words “Confidential 

Business Information.” Send these confidential files under separate cover to the attention of 

Mr. Roberto Morales at the following address:

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

U.S. EPA Mailroom (C404-02) 

Attn: Mr. Roberto Morales, Document Control Officer 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

For the security of your data, EPA recommends sending your confidential files to Mr. 

Morales via Registered U.S. Mail using return receipt requested, Federal Express, or other 

method for which someone must provide a signature upon receipt. Do not electronically 

transmit confidential business information (CBI) to EPA. E-mail and facsimile are not 

secure forms of communication and should never be used to transmit CBI. 

4.0 Contact Information for Questions on Test Plan and Reporting 

For questions on how to report data using the ERT, contact: 

Ron Myers (U.S. EPA) 

(919) 541-5407 

myers.ron@epa.gov

OR 

Barrett Parker (U.S. EPA) 

(919) 541-5635 

parker.barrett@epa.gov

For questions on the test methods contact: 

Peter Westlin (U.S. EPA) 

(919) 541-1058 

westlin.peter@epa.gov

OR 

Gary McAlister (U.S. EPA) 

(919) 541-1062 

mcalister.gary@epa.gov
Enclosure 2 – Draft Under Development - For Review - Do Not Cite Or Quote 04/26/10 

10 of 10 

For questions on the secondary lead smelting test plan, including units selected to test and 

reporting mechanisms other than the ERT, contact: 

Chuck French (U.S. EPA) 

(919) 541-7912 

french.chuck@epa.gov