T o : C h u c k F r e n c h / R T P / U S E P A / U S @ E P A F r o m : " R i c a r d o R o s s e l l o " < r o ss e ll o @ b a t t er y re c

. c o m> D a t e: 09 / 07 / 2 0 1 1 0 3 : 1 3 P M S u b j e c t : F W : re s p u e s t a

D ea r M r

. F

r e n c h :

E n c l o s e d i s t h e a n s w e r t o y o u r r e qu e s t f o r i n f o r m a t i o n

.

P l e a s e c o n t ac t m

e i f y o u h a v e a n y f

u r t h e r qu e s t i o n s

.1. Copies of all stack test reports for lead emissions tests performed within the last 5 years as required by your Air Quality permit condition in Section VI, item 4 and 5.

The permit conditions indicated in this request appear to refer to Section VI, paragraphs 4 and 5 of the Draft Title V permit for the facility. The permit has not been finalized and was subject to extensive comments from BRC. The draft permit only includes one of the two furnaces
operat ing at the facility. It also only incl udes one of the two baghouse control systems. Each furnace is controlled by a separate baghouse system. Both baghouses discharge into a common stack. The conditions applicable to the second furnace and its control equipment have not been included by th e Puerto Rico Environmental Quality Board in this draft. BRC objected the permit and requested EQB to include the second furnace and its control equipment in the draft and final permit.

Enclosed are PDF copies of all stack emission tests conducted in the last five years , except for a test conducted on October 31, 2006 which was conducted during a malfunction event and therefore was deemed to be invalid/unrepresentative

. The following is a summary of the test
results attached to this email.

Testing Compan y Date of
Test Date of Test Report Pollutant or Parameters Tested

Pace August 8, 2007 August 28, 2007 Lead

URS December 3, 2007 December,
2007 Lead

URS December 16 to 17, 2008 January, 2009 PM Opacity Face Velocity
SO2
URS February 17, 2010 March, 2010 PM Opacity Face Velocity Lead
URS June 28, 2010 June 2010 PM Opacity Face Velocity Lead Sulfur2. A description of the activities conducted to comply with the fugitive emissions control requirements of your Air Quality permit in Section VI, item 6, 7 and 8.

The permit conditions indicated in this request appear to refer to Section VI, paragraphs 6, 7 and 8 of the Draft Title V permit for the facility. The permit has not been finalized and was subject to extensive comments from BRC. The draft permit only incl udes one of the two furnaces operat ing at the facility. It also only includes one of the two baghouse control systems. Each furnace is controlled by a separate baghouse system. Both baghouses discharge into a common stack. The conditions applicabl e to the second furnace and its control equipment have not been included by the Puerto Rico Environmental Quality Board in this draft. BRC objected the permit and requested EQB to include the second furnace and its control equipment in the draft and final permit.

The conditions in the draft permit

, to which you refer in this request, incorporate the requirements of 40 CFR 63.544 (a), (b) and (c) (Subpart X

— National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting). The process sources covered by such section are equipped with extraction hoods which collect and convey fumes to the 2 baghouse systems at the facility. The 2 baghouse systems discharge into a common stack.

The process equipment at TBRC includes a single battery bre aker, two rotary furnace for
smelt ing and nine refining kettles. Five (5) kettles belong to one of the furnaces and the other four (4) to the second furnace. Each furnace

- kettles system has its dedicated baghouse. Both baghouses vent the process flu e gasse s through a single stack.

The stack emissions have been tested periodically, as shown in the reports provided in response no. 1, to measure emissions for several parameters and pollutants and to verify compliance
with the N ew Source Performance Standards ( NSPS) and the National Emissions Standards for Hazardous Air Pollutants (NESHAPs) for Secondary Lead Smelters

. 3. A copy of the standard operating procedure manual for fugitive emissions as required by Section VI, item 10 through 13 of your Air Quality permit.

Enclosed is copy of the SOP.

As indicated before, the permit conditions indicated in this request appear to refer to Section VI, paragraphs 10 to 13 of the Draft Title V permit for the facility. The permit has not been finalized and was subject to extensive comments from BRC. The draft permit only includes one
of the two furnaces operat ing at the facility. It also only includes one of the two baghouse control systems. Each furnace is controlled by a separate baghouse system. Both baghouses discharge into a common stack. The conditions applicable to the second furnace and its control equipme nt have not been included by the Puerto Rico Environmental Quality Board in thisdraft. BRC objected the permit and requested EQB to include the second furnace and its control equipment in the draft and final permit.

4. A complete description of your CD

- 1 baghouse control device including: the manufacturer and model number, date installed, design flow rate of inlet gas, cloth type, bag dimensions, number of compartments, number of bags per compartment, total filtering area, and cleaning mechanism. A description of how dust from the control device is handled and disposed.

The facility operates two furnaces and two baghouse systems. Each baghouse CD

- 1 and CD

- 2

are used to control emissions from one of the two furnaces and its refining kettles. Bot h baghouses have identical specifications as follows:

a. Baghouse Manufacturer: Lead Metal Technologies

b. Model Number: Not available

c. Design Flow Rate: 60,000 cfm @ 20 in wg

d. Cloth Type: Renner DT/DT 551 CS17/1

e. Bag Dimensions : 3370 mm L, 12 7 mm Ø

f. Compartments: 8
g. Bags/Compartment: 240

h. Total Filtering Area: 25,237.5 ft 2

i. Cleaning Mechanism: Shaker

Baghouse Dust Handling and Disposal

The facility generates a dry emission control dust that is collected, stored and reused in the smelting furnaces.

The baghouse hoppers directly discharge the dust waste into 187

- gallon containers located at
the four dust bin building s . Generally, the f acility generates about 12 of these containers every day, but this amount can vary depending on the intensity of the operation of the furnaces(e.g. maximum capacity).

Employees monitor the container s every 2 or 3 hours to verify when the containers are full. The designated employee must ensure that excessive accumulation does not occur. Once full, each
container is carefully washed with an industrial water hose and then covered with a resistant plastic wrap to minimize fugitive emissions during transportation for reuse at themanufacturing area . The water from washing down the containers go es into a grid, then to a sump and back into the water treatment plant to remove lead content.

Any spilled material is promptly removed by shovel, broom, or other appropriate method and placed back in the drums

.

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

, including respiratory protection devices.

5. A brief description of your furnace operation including the operating temperature, the furnace exhaust gas flow rate, temperature of the exhaust gas, description of any afterburner or organic control device and operating temperature of the control device.

The 5 and 10 cubic m eter short body rotary furnace s are illustrated in the figure provided below. Both furnaces have similar characteristics and rotary furnace technology. Both furnaces burn used oil as their main fuel. The main difference between the two furnaces is their capacity. Both are controlled by identical baghouse systems. The burner and exhaust are both located at the rear end of the furnace s so the flame travels across each furnace and charge twice. The charge door is opposite to the burner and exhaust end and the furnace s can be charged with the burner operating.

The furnace s are loaded by forklift truck with a scoop bolted to a rotating head attachment.

The furnace s are fired with an oxyburner burning used oil

.

The fluxes used are soda ash, anthracite coal and east iron borings.

The charge used in the furnace s includes materials from scrapped batteries, such as metallic lead and lead oxide, battery plant process scrap, flue dust from baghouses and drosses generated by the refining process.

Charge material must not contain excessive moisture levels (10 % by wt). Materials containing free standing liquid must never be charged into the furnace. The furnace s operat e at a temperature between 900 and 1200° C depending on the lead beari ng material charged in the furnace and thermal capacity required for each charge to be processed.

During the furnace s cycle s from charge heat up to smelting completion the following main reaction sequence occurs:

A.

- Drying out the charge

B.

- Material organics bumC.

- Melting metallic Lead

D.

- Melting paste and other metallic compounds

E.

- Reduction of metallic compounds

F.

- Formation of fluid slag

G.

- Slag treatment

Description of Reactions When the raw materials are fed into a rotary furna ce along with the fluxes and reductants, the metallic lead melt s when the temperature inside the charge reaches the 300 °C

- 500 °C. The rest of the lead bearing materials must react to be converted to metallic lead.

The different lead compounds react at different temperatures requiring the presence of carbon (C), iron (Fe) and soda ash (Na 2 CO3).

The lead oxides (PbO, PbO 2 ) coming from the spent batteries, from the bag house as a byproduct, and from the scrap in the battery plant, are reduced by the carbo n element (C), contained in the anthracite or the coke to get the metallic lead (Pb) and carbon dioxide (CO 2 ) as final products. These reactions take place in the rotary furnace at a minimum temperature of 900 °C.

PbO 2 + C Pb + CO2

2PbO + C 2Pb + CO2

The lead sulphate (PbSO 4 ) coming from the spent batteries and from the scrap in the battery plant, is converted by the carbon element (C), contained in the anthracite or coke into lead sulphide (PbS), carbon monoxide and/or carbon dioxide (CO, CO 2 ). These reactions take place in the rotary furnace at a minimum temperature of 1200 °C.

PbSO 4 + 4C PbS + 4CO

PbSO 4 + 2C PbS + 2 CO 2

The lead sulphide (PbS) generated from the former reactions and coming as a byproduct from the bag house is converted to lead oxide (PbO) or metallic lead (Pb) by the sodium carbonate and/or by the iron present in the original charge. The metallic lead (Pb) generated is a final product, while the lead oxide (PbO) generated reacts again with carbon element (C) the same way described above.Also generated in the previous reactions are the sodium sulphide (Na 2 S) and the iron sulphide (FeS), these compounds separate in a different phase from the metallic lead, this phase is the so called slag material.

Na2CO3 + PbS PbO + Na2S + CO2

PbS + Fe Pb + FeS

The reactions inside the rotary furnace s come to the end when the two phases (metallic lead on the bottom and slag on the upper part), are clearly formed and separated and no more bubbling ca n be observed on the surface.

When the fluxes and the reductant materials fed into the furnace s are not well balanced, the charge may experiment different troubles like more gas consumption, low lead recovery, delayed cycle time or incomplete phases sepa ration.6. A plot plan of the facility with a brief description of the activities in each area of the facility.Enclosed is a plot plan.

7. The approximate number of employees of the business enterprise (Parent Company) that owns the facility. If the number of employees is less than 750 for all world

- wide operations, we are requesting the company’s annual revenue in order to conduct our small business analysis as required by the Small Business Regulatory Enforcement Fairness Act.

The facility em ploys 1 4 0 workers

.

2010 Annual Sales are approximately 30 million dollars.

The Battery Recycling Company is a small minority family owned corporation with no operations outside Puerto Rico. The facility is a certified under the minority business employe r
program

. 8. Any additional information that you believe will aid our analysis of your facility in light of the proposed regulations.

The EPA shall carefully evaluate whether a total enclosure and any other required control

measures are appropriate and feasible for facilities like ours oper ating in a tropical
environment.