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

To: <rossello@batteryrec.com>

CC: <Topham.Nathan@epamail.epa.gov>, Donna Lazzari <Donna.Lazzari@erg.com>, 

<michael.burr@erg.com>

Date: 8/19/2011 2:18 PM

Subject: Secondary Lead Smelter - Battery Recycling Company

Dear Mr. Ricardo Rossello,

 As you probably know, the EPA is in the process of revising the

National Emission Standards for Hazardous Air Pollutants (NESHAP) for

secondary lead smelting (40 CFR part 63, subpart X). Proposed revisions

to this standard were published in the Federal Register on May 19, 2011

and final standards will be published in December, 2011. To obtain

information for updating this standard, an Information Collection

Request survey was sent to several operating secondary lead companies in

2010 to obtain detailed information about the facilities, their

emissions, and control devices. Your facility was not included in the

original distribution of that survey. However, we believe it is

important for us to obtain some information about your facility that we

can consider as we develop the final standards. Therefore, we are

requesting at this time that some key information from your facility be

provided in an effort to include your facility operations in our

analysis.

 We are not requesting that the entire survey be completed at

this time as we realize that this would take a significant amount of

time and effort for your facility. Instead, we are requesting only some

key information that should be readily available. The information we

are requesting is as follows:

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.

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.

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.

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.
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.

6. A plot plan of the facility with a brief description of the

 activities in each area of the facility.

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.

8. Any additional information that you believe will aid our analysis

 of your facility in light of the proposed regulations.

Please send this requested information by August 30, 2011. You can

 email the information by replying to this email. Or, send by

 overnight mail to the address shown below.

Please let us know if you have questions.

 Thank You.

 Chuck French, Group Leader,

 Metals and Inorganic Chemicals Group,

 Office of Air Quality Planning and Standards,

 US Environmental Protection Agency

 Phone: 919-541-7912

 Overnight mail address:

 Chuck French

 US EPA

 Mail Code D243-02

 109 TW Alexander Drive

 RTP, NC 27709