RE: Proposed ICR Test Plan for the Association of Battery Recyclers 

 

Chuck, 

Attached is revised test protocol which I believe addresses your requested changes. I will be in my office on Monday if 

you have questions. 

Billy R. Nichols, P.E. 

URS Corporation 

1000 Corporate Centre Drive, Suite 250 

Franklin, TN 37067 

office 615-771-2480 

direct line 615-224-2135 

fax 615-771-2459 

cellular 615-202-6556 

Email: billy_nichols@urscorp.com 

From: <Billy_Nichols@URSCorp.com>

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

Date: 6/25/2010 7:48 AM

Subject: RE: Proposed ICR Test Plan for the Association of Battery Recyclers

CC:

 

"Danny Greene" <Danny.Greene@erg.com>, "Donna Lazzari" <Donna.Lazzari@erg.com>, 

<Fairchild.Susan@epamail.epa.gov>, "rkemp@environcorp.com" <rkemp@environcorp.com>, 

"Steinwurtzel, Robert N." <Robert.Steinwurtzel@bingham.com>

Attachments: ABR Proposed Test Plan-Rev 1-June 24 -10.doc; Attachment A - 24JUN10.xls

This e-mail and any attachments contain URS Corporation confidential information that may be proprietary or privileged. If you receive this message in error or 

are not the intended recipient, you should not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any attachments or 

copies.

French.Chuck@epamail.epa.gov

06/22/2010 01:10 PM 

To "Steinwurtzel, Robert N." <Robert.Steinwurtzel@bingham.com>

cc "Billy_Nichols@URSCorp.com" <Billy_Nichols@URSCorp.com>, "Danny 

Greene" <Danny.Greene@erg.com>, "Donna Lazzari" 

<Donna.Lazzari@erg.com>, "rkemp@environcorp.com" 

<rkemp@environcorp.com>, Fairchild.Susan@epamail.epa.gov

Subject RE: Proposed ICR Test Plan for the Association of Battery Recyclers

Page 1 of 7
Hi Rob, 

 There is no real significance to 6/23 as a deadline. I did 

not intend the 6/23 to be a firm deadline. I suggested more as a 

question.... Nevertheless, we need the revised plan soon (e.g., by 

the end of this week, if possible). If Billy could send us the 

revised plan sometime later this week that would be greatly appreciated. 

 Thanks. 

 Chuck 

 

 

 From: "Steinwurtzel, Robert N." <Robert.Steinwurtzel@bingham.com> 

 

 

 

 To: Chuck French/RTP/USEPA/US@EPA, "Billy_Nichols@URSCorp.com" 

<Billy_Nichols@URSCorp.com> 

 

 

 Cc: "Danny Greene" <Danny.Greene@erg.com>, "Donna Lazzari" 

<Donna.Lazzari@erg.com>, "rkemp@environcorp.com" 

 <rkemp@environcorp.com>, Susan Fairchild/RTP/USEPA/US@EPA 

 

 

 

 Date: 06/22/2010 01:41 PM 

 

 

 

 Subject: RE: Proposed ICR Test Plan for the Association of Battery Recyclers 

 

 

 

Chuck, what is the significance of the June 23 deadline referenced in 

your email to Billy? I know that he received EPA's comments at the end 

of the day on June 16 with respect to the draft plan submitted to the 

agency on June 10. Billy worked on revising the plan and transmitted it 

on June 19, a Saturday, to the smelters for their review. He is on 

vacation this week, but checks his emails each morning. I understand 

that Billy hopes to submit the revised plan this week notwithstanding 

his vacation but I was not aware of a June 23 deadline. Regards, Rob. 

Robert N. Steinwurtzel 

Attorney

T 202.373.6030 

F 202.373.6001 

robert.steinwurtzel@bingham.com

B I N G H A M 

Bingham McCutchen LLP 

2020 K Street NW 

Page 2 of 7
Washington, DC 20006-1806 

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

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

Sent: Tuesday, June 22, 2010 1:06 PM 

To: Billy_Nichols@URSCorp.com

Cc: Danny Greene; Donna Lazzari; rkemp@environcorp.com; Steinwurtzel, 

Robert N.; Fairchild.Susan@epamail.epa.gov

Subject: Re: Proposed ICR Test Plan for the Association of Battery 

Recyclers 

Dear Mr. Nichols, 

 How is the review of the test plan modifications coming along? 

Will you be able to get back to us by end of day tomorrow (COB on 

6/23/2010)? 

Thanks. 

Chuck 

 From: Billy_Nichols@URSCorp.com

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

 Cc: Danny Greene <Danny.Greene@erg.com>, "Donna Lazzari" 

<Donna.Lazzari@erg.com>, Susan Fairchild/RTP/USEPA/US@EPA, 

 rkemp@environcorp.com, Robert.Steinwurtzel@bingham.com

 Date: 06/16/2010 07:09 PM 

 Subject: Re: Proposed ICR Test Plan for the Association of Battery 

Recyclers 

Thanks Chuck, 

Page 3 of 7
We will address the modifications you have requested and get it back to 

you as soon as possible for your approval. 

Billy R. Nichols, P.E. 

URS Corporation 

1000 Corporate Centre Drive, Suite 250 

Franklin, TN 37067 

office 615-771-2480 

direct line 615-224-2135 

fax 615-771-2459 

cellular 615-202-6556 

Email: billy_nichols@urscorp.com

This e-mail and any attachments contain URS 

Corporation confidential information that may be 

proprietary or privileged. If you receive this 

message in error or are not the intended 

recipient, you should not retain, distribute, 

disclose or use any of this information and you 

should destroy the e-mail and any attachments or 

copies. 

French.Chuck@e 

pamail.epa.gov 

 To 

06/16/2010 Billy_Nichols@URSCorp.com

04:09 PM cc 

 rkemp@environcorp.com, 

Robert.Steinwurtzel@bingham.com, Danny 

 Greene <Danny.Greene@erg.com>, 

 Fairchild.Susan@epamail.epa.gov, "Donna 

 Lazzari" <Donna.Lazzari@erg.com>

 Subject 

 Re: Proposed ICR Test Plan for the 

 Association of Battery Recyclers 

Dear Mr. Nichols, 

 Thank you for sending the proposed Test Plan by the Association of 

Battery Recyclers (ABR). Generally, we think it is a good proposal. 

However, we have some comments and recommendations, as follows: 

Page 4 of 7
1. We observe that the proposed ABR Test Plan does not include method 

OTM 28 and OTM 27 for testing for PM 2.5 (condensible PM). As you 

probably know, these methods were included in the draft test plan 

(enclosure #2) that we sent to Russell Kemp on April 26, 2010. 

Nevertheless, after considering this issue further, we conclude that we 

can accept the exclusion of testing for PM 2.5 (methods OTM 28 and OTM 

27) from the Test Plan, at least for the time being. So, testing for PM 

2.5 emissions is not needed in this test plan. However, please be aware 

that in the future EPA might need data on PM 2.5 (condensible PM). 

Therefore, EPA could possibly ask for this type of testing in the 

future. 

2. In the draft plan (enclosure #2) that we sent to Russell Kemp on 

April 26, 2010, we forgot to include hydrogen chloride (HCl), which is a

HAP that should be included in the testing. We think that testing for 

HCl (using method 26 or 26A) needs to be added to the test plan for the 

furnaces. Therefore, please add HCL (using Method 26 or 26A) to the 

test plan for all furnaces. 

3. We think one more stand alone Blast Furnace with a scrubber (such as 

the Blast furnace at Exide in Forest City, MO) needs to be added to the 

plan for testing of multi-metals, HCl, organic HAP, total hydrocarbons, 

and dioxins. However, to reduce the burden for this additional furnace, 

testing for hexavalent chromium (Cr VI) for this furnace is not needed. 

4. We think that one more co-located blast/reverb furnace with scrubber 

needs to be added to the test plan (such as the co-located furnaces 

located at one of the following facilities: Exide in Reading, PA; 

Gopher in Eagan, MN; Exide in Vernon, CA; or Exide in Muncie, IN) for 

testing of multi-metals, HCl, organic HAP, total hydrocarbons, and 

dioxins. However, to reduce the burden for this additional furnace, Cr 

VI testing for this furnace is not needed. 

5. We think that one refinery furnace should be tested for Cr VI. 

Therefore, please add Cr VI testing for the refinery test at one of the 

following facilities: Doe Run, MO; Exide, TX; or Quemetco, IN. 

6. We think that testing at one more raw material storage enclosure 

area at another facility is needed. For example, we suggest that raw 

material storage be tested at one of the following facilities: East 

Penn, PA; Exide, PA; or Quemetco, IN. 

7. To help alleviate some of the burden of this additional testing, we 

could reduce the number of units that need to test for Cr VI. For 

example, the ABR's Test Plan proposes that Cr VI testing be conducted 

at 3 material preparation sources and 3 reverb furnaces. To reduce the 

testing burden, Cr VI could be measured at only 1 of the material 

preparation and 1 reverb furnace source. 

8. For a few facilities shown in the Attachment A of your Test Plan 

(i.e., Quemetco, CA; Gopher, MN; and East Penn, PA) we need some 

clarification regarding the emission points that will be tested in cases 

where the description is not specific (e.g., it is not clear what is 

included in the "original Torit ventilation system" at the Eagan, MN 

facility). Also, it would be very helpful to include the emission point 

identification used in the facilities' Title V permits. 

9. We observed that some of the minimum sample volumes are lower than 

those we included in the draft test plan we sent to Russell on April 26, 

2010. Without knowing exactly what emissions levels represent the best 

performers, we determined sample volumes in our draft test plan that we 

believe would reasonably detect lowest expected emissions. We can not 

pre-approve smaller sample volumes without more information. 

Page 5 of 7
Nevertheless, we could readily accept data from runs with sample volumes 

as outlined in your proposed test plan as long as those tests have 

measured results above the method detection levels. For sources that 

have already conducted such tests, we suggest that these sources review 

the reports of previously conducted tests and determine if the 

measurements exceeded the site-specific emissions measurement detection 

levels. If so, the source may submit those data (provided we get the 

data in the appropriate format along with the appropriate process data). 

If not, the source will need to conduct the testing with the higher 

volumes that we outlined in our draft test plan. In summary, sources 

may conduct test runs with smaller sample volumes. However, the testers 

must recognize that if those runs result in measured values below MDL, 

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

provide in the draft plan we sent on April 26. 

10. With regard to alternative test methods shown in Table 1.4 of ABR's 

test plan, we expect that some or all of these will be acceptable. 

However, the EPA test experts have not yet finished reviewing these. 

So, we can not yet confirm whether these will be acceptable 

alternatives. We will let you know ASAP about these alternatives. 

 Thanks again for submitting the proposed test plan. Please 

let us know ASAP if you have major concerns, comments or questions about 

our comments and recommendations listed above. 

 Best Regards. 

 Chuck French, 

 Project Manager, 

 U.S. EPA, 

 Office of Air Quality Planning and Standards 

 Sector Policies and Programs Division 

 Minerals and Metals Group 

 Phone: 919-541-7912 

From: Billy_Nichols@URSCorp.com

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

Cc: Robert.Steinwurtzel@bingham.com, rkemp@environcorp.com

Date: 06/10/2010 05:47 PM 

Subject: Proposed ICR Test Plan for the Association of Battery 

Recyclers 

Dear Mr. French, 

Page 6 of 7
On behalf of the 6 Member Companies of the Association of Battery 

Recyclers (ABR), please find proposed sampling plan for fulfilling their 

testing obligations relative to ICR for the Secondary Lead Smelting 

Source Category. Please let us known if you have any questions. 

Billy R. Nichols, P.E. 

URS Corporation 

1000 Corporate Centre Drive, Suite 250 

Franklin, TN 37067 

office 615-771-2480 

direct line 615-224-2135 

fax 615-771-2459 

cellular 615-202-6556 

Email: billy_nichols@urscorp.com

This e-mail and any attachments contain URS 

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proprietary or privileged. If you receive this 

message in error or are not the intended 

recipient, you should not retain, distribute, 

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should destroy the e-mail and any attachments or 

copies. 

[attachment "ABR Proposed Test Plan.pdf" deleted by Chuck 

French/RTP/USEPA/US] 

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Page 7 of 7
1 of 9 

Proposed Test Procedures, Methods, and Reporting Requirements 

for the Information Collection Request for the Secondary Lead 

Smelting Source Category-Revision 1 

June 24, 2010 

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

reporting requirements being proposed by Association of Battery Recyclers (ABR) for providing 

data for the ICR Request for the secondary lead smelting source category. As previously agreed, 

this testing program has been designed such that test data for approximately 50% of the industry 

sources will be provided (See Attachment A). 

The goal of this program will be to provide “preliminary” emission data for all the proposed 

sources no later than 90 days from the date of approval of this Secondary Lead Smelting test 

program. Final test reports will be submitted no later than 108 days following approval of the 

program, and data will be loaded into the ERT within 120 days. 

1.0 Sampling and Analyses Procedures and Methods 

Should it be determined by the individual source owner that test data already exists that meets 

the requirements set forth in this protocol and is representative of current operations for any 

given emission point, this data will be submitted to EPA within 30 days of approval of this test 

program. If EPA determines that any of the existing data that is submitted is not representative 

the submitting company will be notified immediately so testing can be conducted in accordance 

with the above timeline. 

1.1 Stack Testing Procedures and Methods 

The test program has been designed such that stack sampling is conducted to determine emission 

of the following pollutants: 

Arsenic compounds, 

Benzene, 

Beryllium compounds, 

1,3-Butadiene, 

Cadmium compounds, 

Chromium compounds, including Hexavalent Chromium 

Dioxins/furans, 

Hydrogen Chloride 

Lead compounds, 

Manganese compounds, 

Mercury compounds, 

Naphthalene, 
2 of 9 

Nickel compounds, 

Total hydrocarbons, and 

Particulate matter (filterable). 

The select matrix of sources to be included in this program (See Attachment A), includes 

representative process units and emission sources listed in the following Table 1.1. 

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, Hexavalent Chromium, Lead compounds, Manganese compounds, 

Mercury compounds, Nickel compounds, and Particulate matter (filterable). Furnace Charging 

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

compounds, Chromium compounds, Hexavalent Chromium, Dioxins/furans, 

Hydrogen ChlorideLead compounds, Manganese compounds, Mercury 

compounds, Naphthalene, Nickel compounds, Particulate matter (filterable) and 

Total Hydrocarbons. 

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, Hexavalent Chromium, Lead compounds, Manganese compounds, 

Casting Operations Mercury compounds, Nickel compounds, and Particulate matter (filterable). 

1.2 Emissions Sample Location and Gas Composition Analysis Methods 

Unless alternate methodology is specifically approved by EPA, each source will utilize the 

following methods. EPA Method 1 of Appendix A of Part 60 will be used to select the locations 

and number of traverse points for sampling. Where emissions measurement location are at the 

outlet of a positive pressure fabric filter (i.e., roof monitor or multiple short stacks), EPA Method 

5D, sections 8.1 and 8.2 will be used to determine the measurement site and the sample traverse 

points locations. EPA Methods 3A or 3B of Appendix A of Part 60 will be used for analysis of 

flue gas composition, including oxygen concentration. 

1.3 Stack Test Methods 

Testing will be conducted 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 will 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. Unless specifically approved by EPA, the methods 

listed in Table 1.2 will be utilized. 
3 of 9 

In specific instances, especially as it related to the sources located in the State of California, 

alternate test methods may be preferred. Table 1.4 sets forth specific alternative test methods for 

facilities located in California. For alternate method approvals, contact Mr. Chuck French at 

(919) 541-7912 or french.chuck@epa.gov. 

Each test will include a minimum of three test runs at each sampling location. Testing will 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 will be performed on the outlet of the last control device. All pollutant concentrations 

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

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

will be reported as described in Section 2.0. The corresponding emissions point identification 

designated will be included 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, 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, is to be submitted. Note: Where face velocity measurements are indicated, this 

information will be provided only when the Process Emission Point being sampled meets the 

definition of enclosure hoods as defined in 40 CFR 63 – Subpart X. Such measurements may be 

performed by collecting actual face velocity reading or from calculations based on flow 

measurements taken on the enclosure exhaust. Additionally, raw material throughputs and 

production rates will be determined based on procedures currently being used at each facility for 

accounting purposes. 
4 of 9 

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 

HAP metals, 

including 

mercury, 

arsenic, 

cadmium, 

chromium, 

beryllium, lead 

and nickel, and 

PM (filterable) 

EPA Method 29. Determine total filterable 

PM and metal 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 and minimum 

time of 2 hours per run. 

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 m3and a minimum 

time of 2 hours per 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 SW846 Methods 5041A and 8260B for the 

analytical finish. 

At least three test runs with 

a minimum sample volume 

of 0.04 m3per 4 tube 

pairs. (Note: Maximum 

sampling rate per method 

is 1 L/min). 

mg/dscm @ 7 

percent O2

Dioxins/Furans

(for blast 

furnaces and 

collocated 

blast and 

reverberatory 

furnaces only) 

EPA Method 23

At least 3 runs with a 

minimum sample volume 

of 3.4 m3and a minimum 

time of 2 hours per run* 

ng/dscm @ 

7percent O2

Hydrogen 

Chloride 

EPA Method 26 or 26A 

At least 3 runs with a 

minimum sample time of 

two hours per run. 

Minimum volume of 1.5 

m

3

for Method 26 and 

nominal sample rate of 2 

L/min for Method 26A. 

mg/dscm @ 7 

percent O2

* Sample volumes at or above 2.3 m3are acceptable provided the each test run provides 

measured results at or above the method detection level.
5 of 9 

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, as applicable 

Feet per minute 

Raw Material Processing 

Raw material throughput Tons/hr 

3 hours before, during, 

F and 3 hours after sampling ace velocity at enclosure 

openings, as applicable 

Feet per minute 

Charging Material 

Handling 

Charging material 

throughput Tons/hr 

3 hours before, during, 

F and 3 hours after sampling ace velocity at enclosure 

openings, as applicable 

Feet per minute 

Feed Dryer 

Feed material charge rate Tons/hr 

3 hours before, during, 

D and 3 hours after sampling ryer 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 
6 of 9 

Table 1.4: Summary of Test Methods and Alternative Methods 

Pollutant or 

Parameter EPA Recommended Method

 

CA 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 

SCAQMD Methods 2 through 4, simultaneous 

with each test run. Simultaneous with each 

pollutant test run 

dscm/min 

O2 and CO2 EPA Method 3A or Method 3B 

CEMS, SCAQMD Methods 100.1 or Integrated 

sample analyzed according to SCAQMD 

Methods 3.1 or 10.1 as applicable, simultaneous 

with each pollutant test run. 

Simultaneous with each 

pollutant test run 

Volume percent 

dry 

Moisture content EPA Method 4 SCAQMD Methods 2 through 4, simultaneous 

with each test run. 

Simultaneous with each 

pollutant test run 

Volume percent 

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. 

CARB Method 436, except for Chromium-VI 

(CARB Method 425) and Mercury (CARB 

Method 101)3 Runs are performed, 10 hours per 

run, with a minimum sample volume of 11.9 m3

per run. 

At least 3 runs with a 

minimum sample volume of 

3.4 m3 per run. 

mg/dscm @ 7 

percent O2 

Hexavalent Chromium 

(Cr+6) EPA SW-846 Method 0061 

CARB Method 425, 3 Runs are performed, 6 

hours per run, with a minimum sample volume 

of 7.1 m3per run. 

At least 3 runs with a 

minimum sample volume of 

3.4 m3per run. 

μg/dscm @ 7 

percent O2 

Total hydrocarbons EPA Method 25A 

SCAQMD Method 25.3, 2 runs are performed

Additional hydrocarbon information is gathered 

by performing CARB Method 429 for PAH. 3 

Runs are performed, 4 hours per run with a 

minimum sample volume of 4.75 m3per run. 

At least 3 runs simultaneous 

with and for the same duration 

as the Method 23 test runs. 

ppmvd as 

propane @ 7 

percent O2 

Hydrogen Chloride EPA Meethod 26 or 26A 

CARB Method 421, 3 Runs performed, No 

precedent yet established for these sources. 

At least 3 runs with a 

minimum sample time of two 

hours per run. Minimum 

volume of 1.5 m3for Method 

26 and nominal sample rate of 

2 L/min for Method 26A. 

μg/dscm @ 7 

percent O2
7 of 9 

Pollutant or 

Parameter EPA Recommended Method

 

CA Method Test Runs and Duration

Reported 

Units of 

Measure 

Benzene, 1,3-Butadiene, and 

Naphthalene 

EPA SW-846 Method 0031. Use EPA 

SW-846 Methods 5041A and 8260B for 

the analytical finish. 

CARB Method 422.102 and EPA Methods TO14 and TO-15. These methods provide 

information on a number of organics. A 

minimum of 3 runs are performed. A 

volumetric sample is collected for direct 

injection for each run. 

At least three test runs with a 

minimum sample volume of 

0.04 m3per 4 tube pairs. 

(Note: Maximum sampling 

rate per method is 1 L/min). 

mg/dscm @ 7 

percent O2 

Dioxins/Furans (for blast 

furnaces and collocated blast 

and reverberatory furnaces 

only) 

EPA Method 23 

CARB Method 428, 3 Runs are performed, 8 

hours per run with a minimum sample volume 

of 9.5 m3per run. 

At least three test runs with a 

minimum sample volume of 

3.4 m3per run. 

ng/dscm @ 7 

percent O2 
8 of 9 

2.0 Test Program Quality Control 

Where provided in the specific methods, strict adherence to the specified quality control 

procedures will be followed and documented, where applicable. Due to extremely short timeline 

for getting these tests scheduled and conducted, it is not feasible to require all testing to be 

conducted by the same testing company or for a given sample matrix be analyzed by the same 

laboratory. Therefore, each facility will be responsible for assuring that the selected testing firm 

and laboratory is qualified and competent to complete that sampling program as outlined by this 

program. 

In absence of specific quality control guidance by the approved method, procedures outlined in 

EPA Quality Assurance Handbook will be used as guidance. 

3.0 Reporting 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. 

3.1 Reporting Stack Test Data 

For all stack test data, from a stack test from this program or from a previously conducted stack 

test, the data will be submitted using the EPA ERT Version 3. In addition to the ERT, an 

electronic copy of the emission test report (PDF format preferred) must be attached via the 

Attachments module of the ERT. 

Table 3.1: 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)
9 of 9 

3.2 Reporting Stack Test Measured Values Below the Detection Level 

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

the ERT will be performed as described in EPA’s Draft Test Procedures, Methods, and 

Reporting Requirements for the Information Collection Request for the Secondary Lead 

Smelting Source Category provided to ABR on April 26, 2010. 

 

4.0 Data Submittal 

Emission testing data will be provided by completing the non-confidential survey response to the 

submittal link provided on the following website:

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

or by mailing the completed non-confidential survey response on a CD-ROM or DVD-ROM 

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 

If the process data or other information being provided is to be considered confidential, a 

separate CD or DVD will be completed containing only the confidential portion of the data or 

hard copy of the materials containing only the pages that include the information considered 

confidential. Each disk and/or materials will be clearly marked with the words “Confidential 

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

Roberto Morales at the following address: 

Certified Mail or Overnight Delivery, Return Receipt Required 

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 
Attachment A 
Mult metals Hex Chrome Furnace Organics HCl Dioxins

Quemetco - City of Industry, CA

WESP Exhaust Unique facility - WESP controlling almost whole plant exhaust. EAF

Busch Unit G Material Handling Area fugitive dust emission control and negative pressure enclosure ventilation

Busch Unit D Drying Kiln and Reverb Furnace Area fugitive dust emission control and negative pressure ventilation

Exide - Reading, PA

Exide - Frisco, TX

Collocated reverb/blast Furnaces collocated but offgases not actually blended for THC control - SO2 scrubber

Breaker Scrubber

Hard Pb baghouse Part of refinery plus blast furnace hygiene hooding

Supplemental Baghouse Baghouse serving hoods above blast and reverb

Slag Treatment Baghouse serving slag crushing and treatment operation

Raw Material Storage Baghouse serving charge makeup area - negative pressure ventilation

EnviroFocus - Tampa, FL

East Penn - Lyon Station, PA

Collocated reverb/blast Facility tested for original NESHAP background effort, offgases actually blended

#3 Carborundum baghouse Stack S02, blast furnace charging 

#7 Scientific Cartridge w/HEPA Stack S21, slag storage building

#1 Wheelabrator Dust Collector Stack S03, Material storage feed room ventilation

Sanders - Troy, AL

Stack 1 or Stack 5 - blast furnace exhausts Largest of the three "blast-only" facilities (Sanders, EFT, Exide MO) - no SO2 scrubber

Stack 4a Sanitary Hygiene hooding baghouse

Slag Treatment

Gopher - Eagan, MN

Breaker Scrubber

Original Torit ventilation system 166,000 CFM negative pressure system installed in 1993 (furnace/refinery/containment room)

2009 Torit supplemental ventilation system 132,000 CFM additional negative on top of afterburner/Material Transfer Room/blast penthouse)/breaker dock)

Quemetco - Indianapolis, IN

Dryer Baghouse Rotary Kiln feed dryer

Kettle Baghouse Refining Kettle hygiene hooding

Furnace process exhaust Reverb and EAF

Doe Run - Boss, MO

Main Baghouse reverb and blast furnaces

Refinery baghouse

Reverb hygiene baghouse

Rotary baghouse refining kettles and dross screw

Ceilcote scrubber battery breaker scrubber

Exide - Forest City, MO

Furnace process scrubber exhaust

Revere Smelting & Refining - Middletown, NY

Reverb Scrubber Exhaust stand-alone reverb exhaust

Rotary Furnace New furnace, test if operating yet

Exide - Muncie, IN

Exide - Vernon, CA

Scrubber exhaust, combined blast/reverb process

Feed Dryer Rotary Kiln feed dryer

Exide - Baton Rouge, LA No testing, Facility not currently operating

Additional Logic

Cover approx half of sources

Facilities with extensive test data already could provide in lieu

Covers two dryers, two slag treatment units, and three battery breaker scrubbers

Notes:

Multiple Metals: Includes Hg, As, Cd, Cr, Be, Mn, Ni and simultaneous filterable PM - ADD LEAD (not in EPA Draft for multiple metals method)

Furnace Organics: Includes Total Hydrocarbons (THC) with benzene, 1,3-butadiene, and naphthalene

FACILITY/ Unit(s) Constituents Comments