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

From: "Ricardo Rossello" <rossello@batteryrec.com>

Date: 09/07/2011 03:13PM 

Subject: FW: respuesta 

Dear Mr. French: 

Enclosed is the answer to your request for information. 

Please contact me if you have any further questions. 
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 

operating 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 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. 

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 

Company

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

Sulfur
2. 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 includes one of the two 

furnaces operating 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 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 breaker, two rotary furnace for

smelting 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 flue gasses 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 New 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 operating 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 

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. 

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. Both 

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, 127 mm Ø

f. Compartments: 8

g. Bags/Compartment: 240

h. Total Filtering Area: 25,237.5 ft2

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 buildings. Generally, the facility 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 containers 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 the 
manufacturing area. The water from washing down the containers goes 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 meter short body rotary furnaces 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 furnaces so the flame travels across each furnace and charge 

twice. The charge door is opposite to the burner and exhaust end and the furnaces can be 

charged with the burner operating. 

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

The furnaces 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 furnaces 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 furnaces operate at a temperature between 900 and 1200° C depending on the lead 

bearing material charged in the furnace and thermal capacity required for each charge to be 

processed.

During the furnaces cycles from charge heat up to smelting completion the following main 

reaction sequence occurs:

A. - Drying out the charge

B. - Material organics bum
C. - 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 furnace along with the fluxes and reductants, the 

metallic lead melts 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 (Na2CO3).

The lead oxides (PbO, PbO2) coming from the spent batteries, from the bag house as a 

byproduct, and from the scrap in the battery plant, are reduced by the carbon element (C), 

contained in the anthracite or the coke to get the metallic lead (Pb) and carbon dioxide (CO2) as 

final products. These reactions take place in the rotary furnace at a minimum temperature of 

900 °C.

PbO2 + C Pb + CO2

2PbO + C 2Pb + CO2

The lead sulphate (PbSO4) 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, CO2). These reactions take place in 

the rotary furnace at a minimum temperature of 1200 °C.

PbSO4 + 4C PbS + 4CO

PbSO4 + 2C PbS + 2 CO2

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 (Na2S) 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 furnaces 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 can be observed on the surface. 

When the fluxes and the reductant materials fed into the furnaces are not well balanced, the 

charge may experiment different troubles like more gas consumption, low lead recovery, 

delayed cycle time or incomplete phases separation. 
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 employs 140 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 employer

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 operating in a tropical 

environment.