•EXIDE CORPORATION · -Viability, Section 4.1, pg.10, 3rd paragraph - What is meant by the...

•EXIDE CORPORATION

VIA.AIRBORNE EXPRESS

May 26, 1992

Ms. Donna M. McCartney (3HW27)Remedial Project ManagerU.S. Environmental Protection AgencyRegion 3841 Chestnut BuildingPhiladelphia, PA 19107

RE: Tonolli Corporation Superfund SiteReclamation of Battery Case Materials

Dear Ms. McCartney:

Enclosed are Exide Corporation's responses to your letter ofJanuary 27, 1992 related to the reclamation of battery casematerials from the Tonolli Corporation Superfund site at the Exide/General Battery Corporation secondary lead smelter in Reading,Pennsylvania.

Should additional information or clarification be required, orshould you wish to meet to discuss this matter in further detail,please contact this office at (215) 378-0852.

Very truly yours,

EXIDE CORPORATION

Je\ frey\A. LeedDirector - Environmental Resources

JAL:sb

cc: W. Smith, Rizzo Assoc. - w/attach.Tonolli Site Technical Committee - w/attach.Tonolli Site Executive Committee - w/attach.

645 Painn Street Reading, PA 19601P.O. Box 14205 Reading, PA 19612-4205

215/378-0500 TWX 510/651-5288 Telecopier 215/378-0616

RECEIVEDI}M '-' r ICCpJiV w ^ I/ , C.

UNITED STATES EWWONMENTAL PROTECTION AGENCY EnvREGION M

841 Chestnut BukingPhiadeiphia, Pennsylvania 19107

Mr. Jeff LeedExide Corporation645 Penn StreetReading, PA 19601

Re: Tonolli Corporation Superfund SiteReclamation of Battery Case Materials at Exide/GBC Facility

Dear Mr. Leed:

The purpose of this letter is to present EPA's questionsand/or observations pertaining to the treatability test conductedon the battery case materials by Exide/GBC. Specifically, thefollowing questions arose during our review of the December 18,1991 and January 2, 1992 submittals from Exide and CHMR. Pleasecontact me to discuss and/or review these questions upon yourreceipt of this letter.

EPA's questions on the potential viability of Exide'sprocess are listed below.

1) Regulatory Issues - Exide indicates in both of theabove-referenced submittals that "appropriate permits" are inplace to cover the handling of the battery case materials fromthe Tonolli Site at Exide's/GBC's facility in Reading, PA. Thefollowing questions are raised under this issue:

- Must the processing of Tonolli Site battery casingsdemonstrate economical viability to fit the definition of"reclamation" or "recycling"? Is such "reclamation" or"recycling" permitted to be conducted at the Exide/GBC facilityin Reading under the existing RCRA permit?

-If the processing is not economical, is the battery casingprocess considered to be "treatment" of a hazardous waste? Wouldexisting RCRA permits allow for the "treatment" of batterycasings that may be considered "hazardous wastes"?

-The processing of Tonolli Site battery casings makes for asubstantial change to the typical feed material used byExide/GBC. Does this change pose a problem to Exide's currentRCRA permit?

- Will additional testing and characterization of TonolliSite battery casing materials be required to meet any new oradditional permit requirements?

- The Jan. 2, 1992 submittal (Section 3.3, page 8) indicatesthat the results from monitoring the sulfur dioxide emissionsduring the test burn revealed that "the processing of the Tonollimaterial did not significantly adversely affect sulfur emissionsfrom the plant". Is this anticipated to be the case if projectedover a long-term scenario (i.e., the duration of processing theTonolli Site casings)? If some of the Tonolli site casing scrapis polyvinyl chloride (PVC), or polymers other thanpolypropylene, will operational or emission problems beencountered? Also, if major differences are found to occur inthe sulfur content of any hard rubber battery casings, will thiscause emission problems at the Reading smelter?

- If there are major changes in the plastic-to-rubber ratioof the Tonolli Site casing materials, is this likely to causeoperating problems?

- Is it anticipated that the slag composition will remainconsistent to that typically found from Exide's operations ifTonolli site casing materials (and/or other Superfund Sitebattery scrap materials) are fed into the furnace over a one-yearperiod (or more)? How would this aspect be impacted if batteryscraps from other Superfund Sites were to be processed atExide's/GBC's Reading facility in conjunction with the Tonollimaterials?

- Does your existing facility permit(s) require that publiccomment from the community surrounding the Reading smelter besolicited for this proposed use of Tonolli Site materials?

2) Cost Issues - When would a more detailed cost analysisfor this process be available? At present, it is not clear howyou arrived at the cost of $300.00/ton for processing the Tonollimaterials. I would like to see how you arrived at this figure,as well as how you have developed cost information to compare thecosts of processing battery casings via Exide's facility to costsassociated with RCRA landfill disposal.

3) Timing/Other Superfund Site Battery Scrap Materials - Ingeneral, I would like to know how you would handle the TonolliSite battery casings if Exide decided/received approval to takebattery scraps from one or more other Sites. Granted this is oneof those "what if" type of questions, however EPA needs to beasssured that the information we are using to evaluate thisalternative is as valid, accurate, and complete as possible.

4) Section-specific Question - The following questionspertain to individual sections of the "Field Report ForActivities Associated With The Collection and Reclamation ofMaterials From Battery Case Piles From the Tonolli CorporationSuperfund Site in Nesquehoning, Pennsylvania." (Dec. 18, 1991)

-Executive Summary, pg. 2, bullet 3 - See above commentregarding the need for additional detail on how you arrived at

this cost figure for processing the Tonolli Site casings. Thecost factors discussed in Section 4.2, page 11 should be detailedenough to provide EPA with your assumptions and calculations.

-Conclusions, Section 4.0, pg. 9, bullet 1 -Although thereport states that dusting problems are not anticipated to be aproblem, EPA would require that contingencies be provided in theevent that conditions may warrant dust-suppression measures.

-Conclusions, Section 4.0, pg.9, bullet 4- What are thevarious modifications that are mentioned here? Would thesemodifications be necessary prior to beginning the processing ofTonolli battery casings? How long would they be expected totake? Would Exide be responsible for implementing/ financingthese modifications? Would such modifications impact/requirerevision to the existing RCRA permit?

-Conclusions, Section 4.0, pg. 9, bullet 5 - Does Exidedesire to make use of the reverberatory furnaces for the purposeof processing Tonolli Site materials? Are you considering thepossibility of size reduction options for handling the TonolliSite materials?

-Conclusions, Section 4.0, pg. 9, bullet 6 - What is the"new feed system" that is referred to here?

-Viability, Section 4.1, pg.10, 2nd paragraph - Are the feedrates discussed previously in the report to be considered"optimum" feed rates at this time? Are these subject torevision, and if so, is the rate more likely to increase ordecrease?

-Viability, Section 4.1, pg.10, 3rd paragraph - What ismeant by the "processing fee" discussed here? Is this "fee"equivalent to the estimated cost for processing ($300.00/ton)?

-Economics, Section 4.2, pg.ll, bullet 3 - What is theestimated increase in slag volume and calcium sulfate sludgevolume that will result from burning Tonolli Site materials?

-Economics, Section 4.2, pg.ll, bullet 4 - Please clarifyhow the battery case scrap is displacing a substantial amount oflead production. Isn't the battery case scrap displacing coke?

This concludes EPA's questions on the submittals pertainingto Exide 's proposed processing of battery casings from theTonolli Site. Please contact me upon your receipt of this letterso that we can discuss these matters.

Sincerely,

Donna M. McCartneyProject Manager

TONOLLI CORPORATION SUPERFUND SITENESQUEHONING, PA

RECLAMATION OF BATTERY CASE MATERIALSEXIDE/GBC RESPONSES TO EPA 1/27/92 LETTER

EXIDE CORPORATIONDEPT. OF ENVIRONMENTAL RESOURCES

645 PENN STREETP.O. BOX 14205

READING, PA 19612-4205

MAY 1992

TONOLLI CORPORATION SUPERFUND SITERECLAMATION OF BATTERY CASE MATERIALS

EXIDE/GBC RESPONSES TO EPA 1/27/92 LETTER

1) Regulatory Issues - Exide indicates in both of the above-referenced submittals that "appropriate permits" are in placeto cover the handling of the battery case materials from theTonolli Site at the Exide/GBC facility in Reading, PA. Thefollowing questions are raised under this issue:

- Must the processing of Tonolli Site battery casingsdemonstrate economical viability to fit the definition of"reclamation" or "recycling"? Is such "reclamation" or"recycling" permitted to be conducted at the Exide/GBCfacility in Reading under the existing RCRA permit?

• Secondary lead recycling operations at theExide/GBC Reading, PA facility are summarized onthe diagram which is provided as Appendix 1. Thereferences to "appropriate permits" were intendedto refer to air emissions permits and to thefacility's RCRA Part B permits. The RCRA Part Bpermits issued by EPA and DER to the Exide/GBCReading facility authorize the storage of D008 leadcontaining wastes prior to reclamation.

• Exide Corporation believes that the technicalamendments to RCRA confirm EPA's position to allowsecondary lead smelters to process materials fromSuperfund sites. These technical amendments, asdiscussed below, address the operation of theindustrial furnaces (i.e., the two blast furnacesand two reverberatory furnaces at the Exide/GBCReading facility) which are housed within thefacility (e.g., within the building identified as"secondary lead smelting" on the diagram inAppendix 1) .

By way of background information and from thestandpoint of RCRA, the blast and reverberatoryfurnaces at the Exide/GBC facility are subject toEPA regulations (published February 21, 1991) thatregulate emissions from boilers and industrialfurnaces (BIFs) that burn hazardous wastes. Thefinal rule conditionally defers regulation ofsmelting, melting, and refining furnaces that burnhazardous wastes solely for legitimate metalrecovery. The final rule provides the followingthree tests for the determination of burning solelyfor legitimate metal recovery:

1. The heating value of the waste cannot exceed5,000 BTU per pound (if so, the waste isconsidered to be burned partially for energyrecovery),

2. The concentration of Appendix VIII organicconstituents in the waste cannot exceed 500ppm (if so, the waste is considered to beburned partially for destruction), and

3. The waste must have recoverable levels ofmetal.

Following issuance of the final rule in February1991, the secondary lead industry advised EPA thatthe heating value and organic constituent testswould inappropriately classify many materials thatare normally reclaimed at secondary lead smeltersas being burned for energy recovery or destructionwhen these materials are typically processed formetals recovery, absent any impetus from RCRA. Anexample is spent lead-acid battery parts thatcontain plastic or rubber that raise the heatingvalue above 5,000 BTU per pound.

In response to concerns expressed by the secondarylead industry, EPA issued technical amendments tothe BIF regulations on August 16, 1991. A copy ofexcerpts from the technical amendments is providedin Appendix 2.

The technical amendments clarify the applicabilityof the BIF provisions to the following threegeneral classes of materials which may be processedat secondary lead reclamation facilities:

l. Exemption for Lead Bearing Materials ThatContain Less Than 5,000 BTU Per Pound and LessThan 500 ppm of Total Toxic Organics.

The final regulation provides an exemption forsmelting, melting, and refining furnaces thatprocess hazardous wastes that do not have aheating value of more than 5,000 BTU perpound, that do not contain more than 500 ppmof total toxic organic constituents, and thathave recoverable levels of metal.

2. Materials that Contain More Than 5.000 BTU PerPound and More Than 500 PPM of Total ToxicOraanics.

In the technical amendments to the rule, EPAhas clarified that certain materials (i.e.,

2. (Continued)

spent materials that are listed or thatexhibit a characteristic, or listed sludges orlisted byproducts) which are generated by leadassociated industries are burned for leadrecovery even though they may exceed the 5,000BTU per pound or 500 ppra organic constituentcriteria. The materials that EPA has deemedto be burned for recovery of lead content(even though they may exceed the 5,000 BTU perpound and 500 ppm total toxic organicconstituent criteria) are listed in AppendixXI of the technical amendment to theregulations (see Appendix 2, attached).

To be eligible for the exemption, thematerials must be generated or initiallyproduced by lead associated industries(defined as lead smelters, lead-acid batterymanufacturing facilities, or lead chemicalmanufacturing facilities) and, if they exceed500 ppm of toxic organic constituents, theymust not exhibit the toxicity characteristicfor an organic constituent under the TCLP andmust not be listed as a hazardous wastebecause it contains an organic constituent.

3. Byproduct Drosses. Slags, and Scrap Lead.

Note that several lead-bearing materials thathave historically been processed in secondarylead recovery furnaces are not included on theAppendix XI list. These materials includebyproduct drosses, slags, slurry and slurryscreenings, and scrap lead and are notincluded because they are either not solidwastes when recycled or are exempt fromregulation when recycled.

As previously indicated, Exide Corporation believesthat the technical amendments to the BIFregulations confirm EPA's position to allowsecondary lead reclamation facilities to processbattery casings from Superfund sites. Exide/GBC'sRCRA permits allow materials meeting the D008characteristic to be stored prior to reclamation.Further, Exide/GBC does not intend to acceptmaterials that are not economically viable toprocess.

If the processing is not economical, is the batterycasing process considered to be "treatment" of ahazardous waste? Would existing RCRA permits allow forthe "treatment" of battery casings that may be considered"hazardous wastes"?

• Not applicable. Exide/GBC does not intend toaccept materials that are not economical viable toprocess. As part of EPA Contract CR-818199-01-0under the Emerging Technologies Program, Exide andthe Center for Hazardous Materials Research (CHMR)and investigating the economical viability ofprocessing various types of lead-containingmaterials through Exide/GBC secondary leadsmelters.

• Under the federal RCRA program, Exide/GBC does notbelieve that the processing of battery cases at asecondary lead smelter constitutes "treatment".Exide/GBC also believes that this understanding wasconfirmed with EPA and DER during the RCRA Part Bpermitting process for the facility.

• Proposed Pennsylvania DER regulations, however, maydiffer. The State of Pennsylvania originallyproposed revisions to its hazardous wasteregulations in the Pennsylvania Bulletin onJanuary 27, 1990. The 1990 proposed regulationswere primarily designed to make Pennsylvaniaregulations consistent with Federal rules adoptedpursuant to the 1984 amendments to RCRA.

On January 6, 1992, the Pennsylvania Department ofEnvironmental Resources released to the publicrecommended final regulations extensively amendingthe existing state hazardous waste regulations anddiffering substantially from the January 1990proposed regulations. Among other things, theseproposed regulations would regulate materials beingreclaimed, recycled, reused, or burned for energyrecovery.

The Pennsylvania DER has indicated that theproposed revisions would discourage "shamrecycling" by incorporating a waste hierarchy basedon definitions of "waste", "by-product", "expendedmaterial" and "co-product". The proposed finalregulations delete entirely the definition ofdiscarded material. The term "waste" will includeany by-product, expended material, material that isabandoned or disposed, or any contaminated soil,water or other residue. Co-products are notconsidered a waste, and a material is not a wasteif it is directly recycled or reused on-site in anongoing industrial manufacturing process.

Co-product is defined as any material that is"consistently equivalent to or exceeds, thephysical character and chemical composition of anintentionally manufactured product or produced rawmaterial" provided that the use of the materialpresents no greater threat of harm to human healthor the environment than the use of the product.Based on this definition, off-specificationproducts may be classified as co-products.Materials may be classified as co-products only ifthey are transferred in good faith as a commodityin trade for use in lieu of a raw material or usedas a substitute by a manufacturing or producer inlieu of a product or raw material on a routinebasis. The manufacturer, processor or user of thematerial as a co-product has the burden of proof,based on a clear and convincing evidence standardthat the material is a co-product and not a waste.

Under the final regulations, any material that isnot a product or co-product which is used off-sitein a manufacturing or production process to producea new product, is considered a waste. As a result,the manufacturing or production process which usesthe materials as feedstock may be engaged in the"treatment" of a hazardous waste and may need toobtain the appropriate storage and treatmentpermits. There are some situations where theregulations allow facilities to operate under"permit-by-rule" requirements in lieu of obtaininga RCRA Part B permit.

There has been widespread opposition to theregulations and the Independent Regulatory ReviewCommission (IRRC) recently voted not to approvethem. IRRC's official disapproval notice wasissued on Friday, May 8, 1992. The key provisionsin the regulations found objectionable by IRRCincluded: 1) definition of waste; 2) definition ofco-product and expended material; 3) off-specification material (i.e., lack of language inthe regulation); 4) definition of reclamation; 5)deletion of variance provisions; 6) specificindustry concerns (e.g. used oil provision, permitby rule, consistency with the federal RCRArequirements, regulation of lead-containingmaterials, hazardous waste manifest requirements);and 7) limited public input. IRRC received overtwo hundred letters from legislators and industryobjecting to the regulations.

Within seven days of the receipt of the May 8, 1992IRRC disapproval order, DER has three options; 1)withdraw the regulations; 2) submit the regulations

5.

(without revisions) to the General Assembly forconsideration; or 3) revise the regulations throughthe EQB. If DER decides to move forward with theoriginal regulations or to revise the regulations,DER must do so within forty days of disapproval.

The ultimate impact of the proposed DER regulationsto Exide Corporation's operations in Pennsylvaniais not clear at this time. Exide Corporation hasbeen active in this rulemaking process and hasencouraged DER to avoid the creation of newhazardous waste permit requirements upon Exide'ssecondary lead recycling operations in Reading.

The processing of Tonolli Site battery casings makes fora substantial change to the typical feed material used byExide/GBC. Does this change pose a problem to Exide'scurrent RCRA permit?

• No. With respect to the processing of materials inthe blast and reverberatory furnaces at theExide/GBC Reading, Pennsylvania facility, the RCRApermits only regulate certain storage activitiesprior to the reclamation process.

Will additional testing and characterization of TonolliSite battery casing materials be required to meet any newor additional permit requirements?

• Not to the knowledge of Exide Corporation at thistime. (Exide/GBC, however, intends to conductadditional testing during the actual full-scaleprocessing of Tonolli materials in an attempt tobetter define impact, if any, on emission controlsludge and blast furnace slag quantity andcomposition).

The Jan. 2. 1992 submlttal (Section 3.3, page 8)indicates that the results from monitoring the sulfurdioxide emissions during the test burn revealed that "theprocessing of the Tonolli material did not significantlyadversely affect sulfur emissions from the plant". Isthis anticipated to be the case if projected over a long-term scenario (i.e.. the duration of processing theTonolli Site casings)? If some of the Tonolli sitecasing scrap is polyvinyl chloride (PVC). or polymersother than polypropylene,, will operational or emissionproblems be encountered? Also, if major differences arefound to occur in the sulfur content of any hard rubberbattery casings, will this cause emission problems at theReading Smelter?

6.

Exide/GBC does not anticipate emissions problemsover a long-term scenario (i.e., the duration ofprocessing of Tonolli Site casings).

Exide/GBC does not anticipate emissions problemscaused by the processing of casing scrap containingPVC or polymers other than polypropylene.Materials other than polypropylene have beenprocessed in the past without problems and willcontinue to be processed in the future.

Sulfur oxides are scrubbed from gases at theExide/GBC facility using a lime slurry solution inthe venturi scrubbers. This process results in thegeneration of calcium sulfate slurry which issubsequently dewatered on-site prior to off-sitedisposal. Increased sulfur content in feedmaterials to the furnaces (if not adjusted throughchanges to feed rates) could result in thegeneration of additional sludge (which would not bea processing problem but, because of increasedvolume, would increase disposal costs) oradditional emissions. The sulfur content of theTonolli cases, however, is not expected to causeoperational problems at the Exide/GBC facility.Continuous SOx emissions monitoring equipment isalready in use at the Exide/GBC facility which isused to adjust furnace feed rates or operationalcontrols, if necessary.

If there are manor changes in the plastic-to-rubber ratioof the Tonolli Site casing materials, is this likely tocause operating problems?

• No. Exide/GBC's current plan is to process theTonolli casing materials in the existing furnacesystems. Processing can occur in this manner evenif the Tonolli feed material is 100% rubber or 100%polypropylene (which is unlikely given the leadcontent, other debris, etc.). Should a largeincrease in the amount of plastic occur (which isalso probably unlikely) and should the plastic beof sufficient quality (also unlikely based uponprevious examination), Exide/GBC would attempt torecycle the plastic cases for reuse.

Is it anticipated that the slag composition will remainconsistent to that typically found from Exide'soperations if Tonolli Site casing materials (and/or otherSuperfund Site battery scrap materials) are fed into thefurnace over a one-year period (or more)? How would thisaspect be impacted if battery scraps from other SuperfundSites were to be processed at Exide's/GBC's Readingfacility in conjunction with the Tonolli materials?

• Exide/GBC does not anticipate changes to slagcomposition for the duration of the processing ofthe Tonolli material or if battery cases from othersites were processed through the existing furnacesystems.

• If scrap materials (other than cases) from othersites were processed and if these materialscontained metals other than lead, it is possiblethat the metal content of slag could changeslightly. Spent lead-acid batteries have alwaysrepresented the main source of feed materials intothe furnaces. Materials other than spent batteriesare processed in smaller quantities. Thus, anychange in feed material composition could onlyresult in slight slag composition changes. sincethe time that the RCRA regulations became effectivein 1980, the Exide/GBC Reading facility has alwaysdisposed of blast furnace slag as a hazardous waste(based upon results of the EP toxicity test or theTCLP). Even if a slight slag composition changewould occur, it is unlikely that the regulatorystatus of the slag would change and it is unlikelythat Exide/GBC's management practices (i.e.,disposal as a characteristically hazardous waste)would change. Exide Corporation is currentlyproceeding with development of plans forinstallation of slag crushing and stabilizationfacilities to comply with EPA land disposalprohibitions.

Does your existing facility permitfs) require that publiccomment from the community surrounding the Readingsmelter be solicited for this proposed use of TonolliSite materials?

• Not to the knowledge of Exide Corporation. Publiccomment was solicited and public meetings were heldprior to issuance of the EPA and DER permits in1988. (If the Tonolli casing materials exhibit ahazardous waste characteristic, the characteristicwould be similar (i.e., D008 - lead concentration)to other materials which are normally reclaimed atthe Exide/GBC facility).

2) Cost Issuesthis processvou arrived

- When would a more detailed cost analysis forbe available? At present, it is not clear howat the cost of $300.00/ton for processing the

Tonolli materials. I would like to see how vou arrived atthis figure as well as how vou have developed costinformation to compare the costs of processing battery casingsvia Exide 'sdisposal..

facility to costs associated with RCRA landfill

The $121.50/yd3 processing cost at the Exide/GBC Readingfacility which has been estimated for the Tonolli batterycase materials (and which has been used in the draftTonolli FS report) is equivalent to the current fee whichis assessed on an on-going basis by the Exide/GBC Readingfacility to customers who supply materials which, whenprocessed, will result in decreased production or lowerlead recovery (e.g., materials such as plates and gridsfrom spent lead-acid batteries are high-grade feedstockmaterials which result in higher lead recovery, whereasother materials which contain lesser amounts of lead inthe feedstock result in lower lead recovery). This costis based upon operational experience and includes aconsideration of labor, operation and maintenance costs,administrative requirements, environmental controlrequirements, waste disposal costs, consideration of lossof lead production (if any), and profit. "

Exide Corporation's estimated processing cost has beencomputed as follows:

$121.50 x 1 ft3 x yd3cubic yard 30 Ibs 27 ft3

$ 0.15/lb

$300/ton

This cost is believed to be a conservative estimate basedupon experience from the trial processing. ExideCorporation believes that it will not be possible todetermine the actual cost for processing the Tonollibattery case materials until a longer term test (i.e.,daily processing for one month or more) is completed orthe actual full scale remedial program is begun.

Exide Corporation's cost evaluation of various optionsfor managing the battery case materials is provided onthe following pages. Costs which are common to eachalternative (i.e., site supervision, etc.) are notincli ded in the cost estimates. These options, and thecosts which have been estimated, are summarized asfollows:

y •>

ALTERNATIVE ESTIMATED COST

1. Processing at Exide/GBC $ 2,402,400secondary lead smelter.

2. Stabilization/off-site $ 4,750,980disposal in municipalwaste landfill.

3. Phosphate stabilization/ $ 3,242,850off-site disposal inresidual waste landfill.

4. Pozzolanic stabilization/ $ 3,735,420off-site disposal inresidual waste landfill.

5. Off-site disposal in RCRA $ 3,276,000+Subtitle C landfill inOhio, Michigan, orIllinois.

6. Off-site disposal in RCRA $ 6,052,800+Subtitle C landfill inNew York.

7. Washing/acid leaching $ 3,244,800+(Bureau of Mines process).

8. Washing (Canonie process). $ 3,540,250

Detailed breakdowns of these costs, as noted above, areprovided on the following pages.

10.

ALTERNATIVE 1

TONOLLI CORPORATION SUPERFUND SITEBATTERY CASE MANAGEMENT OPTIONS - ESTIMATED COSTS

DESCRIPTION; Processing at Exide/GBC secondary leadsmelter, Reading, PA.

BASIS FOR UNIT COSTS;

l. Loading/transportation costs estimated in draft Tonollisite FS report.

2. Processing costs based upon 5-load trial test conductedin September 1991.

TOTAL PROJECTED COSTS;

1. Loading -

15,600 cubic yards x $20/yd3 = $ 312,000.

2. Transportation -

15,600 yd3 x 1 load = 390 loads40 yd3

390 loads x $500/load = $ 195,000.

3., Processing -

15,600 cubic yards x $121.50/yd3 = $1,895,400.

Estimated Total = $2,402,400.

flR30U37.011.

ALTERNATIVE 2


DESCRIPTION; Stabilization/off-site disposal in a municipalwaste landfill in Pottstown, Pennsylvania.*


1. Unit costs used in the following calculations are basedupon information in EPA RI/FS report for Brown's BatterySite.

•2. Assume crushing is required prior to stabilization toreduce size of battery case materials.

3. Stabilization by Silica Technology Corporation at $72/yd3(from Brown's Battery RI/FS). Assume 20% volume increaseas a result of stabilization.

4. Assume landfill/DER will require TCLP analysis and totalPb, As, Cd on a per load basis. (See explanation inAlternative 3).

5. Loading cost from draft Tonolli FS report.

TOTAL PROJECTED COSTS:

1. Loading and hauling (for feeding crushing unit)

15,600 yd3 X $25/yd3 = $ 390,000.

2. Crushing (prior to stabilization,including baghouse)

15,600 yd3 x $25/yd3 = $ 390,000.

3. Stabilization

15,600 yd3 x 1.20 = 18,720 yd3

18,720 yd3 x $72/yd3 = $1,347,840.

12.

TOTAL PROJECTED COSTS (Continued)

4. Analytical

468 loads x $415/load = $ 194,220.

5. Loading

18,720 yd3 x $20/yd3 = $ 374,400.

6. Transport

468 loads x $550/load = $ 257,400.

7., Disposal

18,720 yd3 X $96/yd3 = $1,797,120.


* Note: During the public review process related to the Brown'sBattery site, the Pennsylvania DER advised EPA thatPennsylvania regulations prohibited disposal in amunicipal landfill.

13.

ALTERNATIVE 3


• DESCRIPTION; Phosphate stabilization/off-site disposal inresidual waste landfill (Grand CentralSanitation, Pen Argyl, PA).

• BASIS FOR UNIT COSTS;

1. Assume stabilization is feasible with phosphates at costof $60/yd3 (not yet proven; treatability study notconducted).

2. Assume no waste volume increase after stabilization.

3. Assume crushing is required prior to stabilization toreduce size of battery case materials.

4. Assume landfill/DER will require TCLP analysis and totalPb, As, Cd on a per load basis. (These analyticalrequirements are required on a per load basis for wastesgenerated at Exide/GBC Reading facility which have beenauthorized to be disposed at this landfill).

5. Assume DER will approve Module 1 form and authorizedisposal at site, given total lead concentrations.

6. Assume landfill is will ing/authorized to accept materialsfrom Superfund site.

7. Assume landfill disposal cost is equal to current gaterate.



15,600 yd3 x $25/yd3 (estimated) = $ 390,000.

2. Crushing, including baghouse

15,600 yd3 x $25/yd3 = $ 390,000.

3. Stabilization

15,600 yd3 x $60/yd3 = $ 936,000.

14.

• TOTAL PROJECTED COSTS (Continued)

4. Analytical

390 loads x $415/load = $ 161,850.

5. Loading (for off-site transport)

. 15,600 yd3 x $20/yd3 = $ 312,000.

6. Transport

390 loads x $500/load = $ 195,000,

7. Disposal

15,600 yd3 X $55/yd3 = $ 858,000,


J. Z3 •

ALTERNATIVE 4


DESCRIPTION: Pozzolanic stabilization/off-site disposal inresidual waste landfill (Grand CentralSanitation, Pen Argyl, PA).


1. Assume stabilization is feasible with pozzolanicmaterials (not yet proven) at cost of $60/yd3.

2. Assume minimum of 20% volume increase afterstabilization.

3. Assume landfill/DER require TCLP analysis and total Pb,As, Cd on a per load basis.

4. Other assumptions same as phosphate stabilization.



15,600 yd3 x $25/yd3 (estimated) = $ 390,000.

2. Crushing, including baghouse

15,600 yd3 x $25/yd3 = $ 390,000.

3. Stabilization (15,600 yd3 x 1.20 = 18,720 yd3)

18,720 yd3 x $60/yd3 = $1,123,200.

4. Analytical

18,720 yd3 x load/40 yd3

468 loads x $415/load ' = $ 194,220.

5. Loading (for off-site transport)

18,720 yd3 x $20/yd3 = $ 374,400.

16.

• TOTAL PROJECTED COSTS (Continued)

6. Transport

468 loads x $500/load = $ 234,000.

7. Disposal

18,720 yd3 x $55/yd3 = $1,029,600.

Estimated Costs = $3,735,420.

ALTERNATIVE 5


DESCRIPTION: Off-site disposal in RCRA Subtitle C landfill(located in Ohio, Illinois, or Michigan).


1. Solidification/stabilization not required to meet EPAland disposal prohibitions until May 8, 1993. Assume allbattery cases disposed prior to 5/8/93. (Costs higherafter 5/8/93).

2. Assume disposal at Envirosafe, Peoria, or Wayne sites atlarge-volume discount (cost ranges from $130/yd3 -$205/yd3; use lowest costs for estimates).

3. Estimated transportation costs to any of three disposalsites.

4. Assume no local/state disposal taxes.


1. Loading

15,600 cubic yards x $20/yd3 = $ 312,000.

2. Transportation

15,600 cubic yards x $60/yd3 = $ 936,000.

3. Disposal

15,600 yd3 X $130/yd3 = $2,028,000.

Estimated Costs = $3,276,000.

NOTE: Cost estimate valid only until 5/8/93 at which timestabilization is required prior to disposal.

18 .

ALTERNATIVE 6


DESCRIPTION; Off-site disposal in RCRA Subtitle C landfill(Model City, New York).


1. Solidification/stabilization not required to meet EPAland disposal prohibitions until May 8, 1993. Assume allbattery cases disposed prior to 5/8/93 (costs higherafter 5/8/93) .

2. Assume transportation and disposal at Model City, .NewYork facility. Unit rates from Tonolli FS report.


1. Loading

15,600 cubic yards x $20/yd3 = $ 312,000.

2. Transportation

390 loads x $l,200/load = $ 468,000.

3. Disposal

15,600 yd3 X $338/yd3 = $5,272,800.


NOTE; Cost estimate valid only until 5/8/93 at which timestabilization is required prior to disposal.

19.

ALTERNATIVE 7


DESCRIPTION; Washing/acid leaching (Bureau of Minesprocess).


1. Unit cost of $2 08/yd3 from Selection of ControlTechnologies for Remediation of Lead Battery RecyclingSites. EPA/540/2-91/014, July 1991.

TOTAL PROJECTED COSTS:

1, Washing/acid leaching

15,600 yd3 x $208/yd3 = $3,244,800.

NOTES;

1. Costs for other aspects of remedial option - not known.

2. Market, if any, for washed rubber cases - not known.

3. Market, if any, for washed polypropylene cases - notknown.

4. Costs for disposal of washed material as residual wastes- see previous calculations.

20.

ALTERNATIVE 8

DESCRIPTION; Washing (Canonie process).


1. Unit costs based upon treatability study conducted byCanonie as part of RI/FS for Tonolli site.

2. Unit costs as outlined in Tonolli FS report.

3. Market, if any, for washed cases - not known. Assumedisposal of washed material as residual waste in off-sitelandfill.

4., Assume landfill/DER will require TCLP analysis for metalsand total Pb, Cd, As analysis on a per load basis.

5. Assume lead concentration of feed materials to washsystem is 5,000 ppm (0.5%) and all lead is recoverable.

6. Assume no volume reduction of cases following leadremoval.

7. Assume no cost to process recovered lead (grids, lugs,dust, etc.) at secondary lead smelter.

TOTAL PROJECTED COSTS

1. Loading and hauling

15,600 yd3 x $25/yd3 = $ 390,000.

2. Washing of cases

15,600 yd3 X $104/yd3 = $1,622,400.

3. Analysis of washed cases for disposal

390 loads x $415/load = $ 161,850.

4. Loading of washed cases for disposal

15,600 yd3 x $20/yd3 = $ 312,000.

5. Transport of washed cases for disposal

390 loads x $500/load = $ 195,000.

21.

TOTAL PROJECTED COSTS (Continued)

6. Disposal (as residual waste)

15,600 yd3 x $55/yd3 = $ 858,000.

7. Transportation of recovered leadto smelter for disposal

15,600 yd3 cases x 0.4 tons/yd3 = 6,240 tons

6,240 tons x 0.5% = 32 tons lead

32 tons x load/20 tons = 2 loads

2 loads x $500/load = $ 1,000.


22

3) Timing/Other Superfund Site Battery Scrap Materials - Ingeneral. I would like to know how you would handle the TonolliSite battery casings if Exide decided/received approval totake battery scraps from one or more other Sites. Grantedthis is one of those "what if" type of questions, however, EPAneeds to be assured that the information we are using toevaluate this alternative is as valid, accurate, and completeas possible.

• As indicated in EPA's question and given that Exide/GBCdoes not know the number of Superfund sites which mightinvolve these types of materials or the quantities ofmaterials per site, this question is difficult to answerat this time.

In addition to the five-load trial test which wasconducted of the Tonolli materials, Exide/GBC has alsoconducted a two-load test of battery case materials fromthe Hebelka Superfund site as part of the CHMR/ExideEmerging Technology Program. The estimated volume ofbattery case materials at the Hebelka site iscomparatively small (estimated by EPA to be 1000 yd3)such that problems are not anticipated by Exide/GBC ifEPA opts to process the remainder of the Hebelka cases inthis manner and if the Tonolli battery case materials arebeing processed at the same time.

For other sites (i.e., Brown's Battery), largerquantities of material (66,980 cubic yards of cases andcontaminated soil at Brown's Battery, according to EPAestimates), may be involved. The exact rate of processingof materials from the Brown's Battery at the Exide/GBCReading facility is not known. GBC made an offer to EPAin 1983 to process the cases from the Brown's site. EPAopted instead to place the cases into a containment areaunder several feet of soil. Later, Exide/GBC againoffered to EPA to conduct a test program to evaluate thefeasibility of processing the Brown's material. AlthoughEPA never authorized the conduct of the test, thepresence of the landfill cap (and the presence of soilmixed with battery case materials) is expected toadversely impact the processing rate.

As part of Exide/General Battery Corporation's March 9,1992 comments on EPA's proposed remedial plan for theBrown's Battery site, Exide/General Battery Corporationproposed to investigate, design, and install a newfurnace (e.g., a fuming/gasification furnace) as part ofits secondary lead recycling operations in Reading,Pennsylvania. Support facilities (including a storagefacility (or facilities) for soil and battery cases,material sizing equipment, and material handlingequipment) were proposed to be installed as part of theproposed plan. The furnace was proposed to be tied intothe existing secondary lead recycling process at thefacility.

• s . . . . _ . - - • '

23.

During the operation of the fuming/gasification furnace,contaminants in the soil and battery casings will bepurged from the materials by the fuming process. Themetals which are fumed from the feed materials in thefurnace will subsequently be recovered in the twoexisting reverberatory furnaces and existing controlsystems equipment. Recovered lead will be returned tothe existing reverberatory furnaces for subsequentreclamation. Battery cases will be gasified for energyrecovery and subsequent utilization in the fuming processand existing reverberatory furnaces. The ash volumegenerated from the furnace is expected to beapproximately 10% of the original battery case feedvolume plus the total volume of the soil feed. It isanticipated that the chemistry of this process willenable the resulting ash to contain extremely low levelsof metals so that the material can be beneficiallyreused. Exide Corporation's proposed fuming/gasification process, shown as a flow diagram in Appendix3, is an innovative technology and requires somedevelopment work given that it combines two existingoperational technologies (e.g., fuming extraction ofmetals and gasification of solid fuels to produce gaseousproduct, both using heat as a catalyst). Other elementsof the proposed Exide/GBC plan related to the Brown'ssite are discussed as follows:

1. Site Preparation at Brown's Battery Site

Site preparation at the Brown's Battery Site willbe performed in the manner which the EPA hasaddressed in its proposed alternatives, except thatsoils containing lead levels above 1,000 mg/kg oran agreed level and battery cases will be excavatedand removed from the Brown's site. The soil andbattery casings will be excavated and transportedto Exide/GBC's secondary smelter facility locatedapproximately ten miles from the Site. Ifrequired, based upon analytical data, the soil andbattery casings will be managed as a hazardouswaste during transportation and subsequent storageat the Exide/GBC facility.

2. Development Efforts

Since the soil/battery casing mixture significantlycomplicates the processing of the Brown's Batterymaterials (e.g., when compared to the processing ofbattery casings which are not mixed with soil),Exide Corporation's initial activity related to thedevelopment of the fuming/gasification process willbe to enter into a research agreement with theMinerals Engineering Department of the Pennsylvania

2. Development Efforts (Continued)

State University (PSU). The research program isexpected to result in the development of thespecifications, operational requirements, andconstruction details of the fuming/gasificationfurnace. The evaluation will include tests onmixture feed ratios and processing rates for thefeed materials, quality and quantity of heat, andresiduals. The Exide/PSU research program scheduleis shown as part of the overall preliminary programschedule in Appendix 4.

3. Storage of Materials at Exide/GBC Secondary LeadRecycling Facility

Upon receipt of materials at the Exide/GBCsecondary lead recycling facility, materials willbe weighed, and subjected to normal receipt controlas outlined in Exide/ GBC's RCRA permit. Thematerials will be processed through sizingequipment, separated, and then stored in a pre-cast, pre-stressed concrete containment buildingwhich will also house all of the receiving andprocessing equipment. The building(s) andprocessing equipment will be sized to contain thetotal volume of battery casings and soil which isestimated to be removed from the Brown's site.

The containment building(s) will be covered with aroof, equipped with a concrete floor, and operatedto allow for dust collection and minimization offugitive emissions. Plans for receiving, sizing,and storage are shown in Appendix 5.

The containment building size will allow forexcavation, transport, and storage of Brown'sBattery materials and could be completed in lessthan one year following construction, assumingnormal weather delays or unforeseen on-siteproblems which may impact the excavation ofmaterials at the Brown's site.

Materials received at the containment building willbe segregated into soils (all material of less than1%" particle size) and casings (originally receivedin sizes greater than 1%" particle size and reducedin size by crushing prior to storage in thecontainment building). If materials (i.e., intactspent lead-acid batteries) are encountered duringthe excavation of the containment area at theBrown's site, this material would be segregated asfeed material for direct lead recovery to theexisting secondary lead smelting furnaces and willnot be processed through the fuming/gasificationfurnace (Appendix 6).

4. Processing of Materials At Exide/GBC Secondary LeadRecycling Facility

Battery casings and soil will be conveyed from thecontainment building through an enclosed system tothe fuming/gasification furnace building on a dailybasis, and accumulated in separate holding bins.An additional bin will be constructed to store theanthracite coal which will be utilized as furnacefuel supply. Battery casings, soils, and coal willbe introduced into the furnace at the mix ratioswhich are anticipated to be developed as part ofthe Exide/PSU development program. The weighedfeed materials will be pre-mixed for uniformdistribution and continuous feed into the furnace.In addition to solid materials (i.e., casings,soil, and coal), oxygen will be fed to enrich thecombustion for obtaining the required temperaturesnecessary to maximize the fuming of metals,primarily lead compounds, from the feed materials(Appendix 7).

The size and configuration of the fuming/gasification furnace will be determined during theExide/PSU development program and will be governedby utilization of the advantageous features ofexisting furnaces on the market and by pilottesting. This concept will be patented and willjoin together, for the first time, two provenoperational technologies.

5. Products Generated From Process

Several major products will be generated from thefuming/gasification furnace operations. Thesematerials include produced gas, purged soil,reclaimed lead, and an ash with potentialbeneficial use.

The produced gas which is generated will be ductedto the two existing reverberatory furnaces at thefacility. This fuel will be supplemented by thenatural gas which is currently used to fire theburners of these furnaces.

Purged soil which will contain low concentrationsof metals will be generated as a nonhazardous,solid material (ash). Exide/GBC expects todemonstrate that this material can be beneficiallyused as road bed material.

26.

5. Products Generated From Process (Continued)

Fumed or vaporized metal will be removed from thefurnace in the off-process gas stream. This gaswill be processed through existing (reverberatoryfurnace) afterburners into combinationcooling/dropout chambers prior to subsequentparticulate capture in existing baghouses and wetscrubbers at the facility (see Appendix 6).Particulate matter which is captured from thecooling/ drop-out chambers or the baghouses willsubsequently be returned in existing enclosed screwconveyors into the existing reverberatory furnacesfor subsequent reclamation.

6. Waste Generation

Sulfur oxides in the produced gas from thecombustion of the casings and coal will be conveyedin the off-process gas stream, through thefiltering media in the existing baghouse, and willsubsequently be captured in the existing venturiscrubber. In the existing scrubber, a calciumhydroxide slurry is added to chemically react withthe sulfur oxides present in the gas stream. Minoradjustments of scrubbing control equipment (i.e.,adjustment of differential pressure across theventuri, pH adjustments, etc.) will enableExide/GBC to maintain compliance with existing airpermit limits for sulfur emissions using theexisting sulfur dioxide continuous monitor tomeasure emissions. In addition, Exide/GBC does notanticipate any changes to the chemical constituentsof the resultant calcium sulfate sludge which isgenerated from the venturi scrubbers. As publishedin the May 1, 1991 Federal Register, ExideCorporation received an administrative stay of theapplicability of the K069 hazardous waste listingto the sludge generated from the existing venturiscrubbers.

7. Summary

The overall operation of the fuming/gasificationfurnace, in conjunction with the existing Exide/GBCsecondary lead smelter, is shown in Appendix 6.Exide Corporation believes that the installation ofthe fuming/ gasification furnace at the existingExide/GBC secondary lead facility represents thelowest cost and the most expeditious method forremediation at the Brown's Battery site.

27.

7. Summary (Continued)

The innovative technology proposed in thisalternative utilizes existing operational controlsand process gas management systems which arealready in place at the Exide/GBC Reading facilityand which constitute 75% of the innovative system.Exide Corporation personnel, in addition, arealready experienced in the processing and operationof high temperature furnace equipment, operationalcontrols, and required elements of risk management.PSU is also very experienced in the furnace fumingtechnology.

The development of the technology also creates amethod to facilitate the processing of residualsfrom other Superfund sites or other siteremediations without the generation of excessivewaste volumes and of hazardous wastes. Dependingupon the timing of installation of thefuming/gasification furnace and the initiation ofprocessing of the Brown's Battery materials, ascompared to the processing of the Tonollimaterials, Exide/GBC could either process theTonolli materials through the existing furnacesystem (as originally proposed) , the proposedfuming/gasification furnace system, which isplanned to be installed as part of the Brown'sBattery program, or both.

4) Section-specific Question - The following questions pertain toindividual sections of the "Field Report For ActivitiesAssociated With The Collection and Reclamation of MaterialsFrom Battery Case Piles From the Tonolli Corporation SuperfundSite in Nesguehoning. Pennsylvania". (Dec. 18, 1991)

n Executive Summary, pg. 2. bullet 3 - See above commentregarding the need for additional detail on how vouarrived at this cost figure for processing the TonolliSite casings. The cost factors discussed in Section 4.2,page 11 should be detailed enough to provide EPA withyour assumptions and calculations.

• See previous comments.

r. Conclusions, Section 4.0, pg. 9. bullet 1 - Although thereport states that dusting problems are not anticipatedto be a problem. EPA would reguire that contingencies beprovided in the event that conditions may warrant dust-suppression measures.

• No response required.

28.

Conclusions, Section 4.0, pg. 9. bullet 4 - What are thevarious modifications that are mentioned here? Wouldthese modifications be necessary prior to beginning theprocessing of Tonolli battery casings? How long wouldthey be expected to take? Would Exide be responsible forimplementing/financing these modifications? Would suchmodifications impact/require revision to the existingRCRA permit?

• The modifications which are mentioned in thissection of the report refer to Exide/GBC facilitymodifications which could be made to facilitatehandling and charging of cases into the existingfurnaces at the Exide/GBC facility. Thesemodifications could include the purchase of anadditional front end loader, a unit to crush orgrind the cases to a smaller size (to facilitatethe rate of burning in the furnaces) , a storagesilo (for storage of crushed cases), an automatedsystem to feed the furnaces, a baghouse for theproposed crusher, and building modifications tofacilitate access by a dump trailer.

• The modifications are not necessary prior toinitiation of the Tonolli battery case processingprogram. As part of the Tonolli program, it islikely that an additional front end loader would bepurchased and that modifications to the building(to facilitate dump trailer access) would be made.Other changes would be considered if the processingof large volumes of cases from other sites (i.e.,Brown's Battery) are implemented.

• Although possible facility modifications are notnecessary for processing of Tonolli materials, thetwo possible changes (e.g., front end loaderpurchase and building modifications) are able to beimplemented in less than several months.

• Design/engineering for other possible modifications(not necessary for processing of Tonolli materials)has not yet been initiated. Implementation time isnot currently known.

• If implemented, Exide/GBC would be responsible forimplementation and financing.

• Possible modifications (front-end loader andbuilding modifications for truck access) forprocessing of Tonolli materials would not beexpected to impact the RCRA permit. - _• ~

29.

If storage areas (e.g., piles within containmentbuildings) are considered as part of programs forprocessing materials from other sites,modifications to the RCRA permit could be required.

Conclusions, Section 4.0, pg. 9, bullet 5 - Does Exidedesire to make use of the reverberatory furnaces for thepurpose of processing Tonolli Site materials? Are youconsidering the possibility of size reduction options forhandling the Tonolli Site materials?

• Based upon the results of the test of Tonollimaterials, Exide/GBC currently plans to process theTonolli materials through the blast furnaces. Ifequipment is added (as part of other programs) tocrush, grind, or otherwise reduce the size of thebattery cases, Exide/GBC believes that processingof the cases in the reverberatory furnaces isfeasible. Size reduction, followed by processingin the existing blast furnaces, has beendemonstrated to be feasible based upon the trialtest of materials from the Hebelka site.

Conclusions. Section 4.0, pg. 9. bullet 6 - What is the"new feed system" that is referred to here?

• The "new feed system" refers to an automated system(discussed earlier) for feeding battery cases(after further crushing or grinding) into thefurnaces. Although not necessarily planned for theprocessing of Tonolli materials, this system (ifimplemented as part of other programs) couldfacilitate handling and processing.

Viability. Section 4.1. pg. 10. 2nd paragraph - Are thefeed rates discussed previously in the report to beconsidered "optimum" feed rates at this time? Are thesesubject to revision, and if so, is the rate more likelyto increase or decrease?

• The feed rates discussed in the report are notnecessarily intended to be optimum rates but wereestablished (based upon the five-load test) by theExide/GBC smelter manager to ensure a margin ofsafety in facility operations. That is, the ratewas established as a conservative estimate which isbelieved (based upon the five-load test) to enablethe Exide/GBC facility to process the materialswithout the need to occupy excessive amounts ofavailable storage capacity with the Tonollimaterials. These rates are subject to revision

30.

(Continued)

after a longer test program (or actualimplementation of the full scale remedial program)is implemented. If all other factors remain thesame, Exide/GBC is optimistic that the processingrate could be increased.

Viability. Section 4.1. pg. 10f 3rd paragraph - What ismeant by the "processing fee" discussed here? Is this"fee" equivalent to the estimated cost for processingr$300.00/ton)?

• Yes. The "processing fee" is intended to mean thesame as the "estimated cost for processing".

Economics, Section 4.2, pg. 11, bullet 3 - What is theestimated increase in slag volume and calcium sulfatesludge volume that will result from burning Tonolli Sitematerials?

• Due to the small volume (5 loads) of Tonollimaterials which were processed, the inherentvariability in furnace feed materials, and thecomplexity of facility operations (2 blast furnacesand 2 reverberatory furnaces), the increase in slagand sludge generation could not be accuratelyquantified. Although waste generation rateincreases could not be quantified, increased use ofiron to react with sulfur compounds in the furnaceand increased use of lime in the scrubberssuggested that generation rates of slag and sludgewill increase from processing of Tonolli materials.Facility personnel have indicated that a longerterm test (or the actual remedial program) must beconducted in order to accurately determine theincreases in waste generation rates.

Economics. Section 4.2, pq. 11, bullet 4 - Please clarifyhow the battery case scrap is displacing a substantialamount of lead production. Isn't the battery case scrapdisplacing coke?

• During routine facility operations, the blastfurnaces are charged with reverberatory furnaceslag (approximately 60% lead content), coke, andiron.

31.

(Continued)

During the test processing of battery casematerials from the Tonolli site, feed materials tothe blast furnace consisted of coke, additionaliron, and a mixture of reverberatory furnace slagand Tonolli materials. At the maximum rate ofprocessing of Tonolli materials (e.g., when thereverberatory furnace slag and Tonolli materialswere fed in equal quantities), the amount of cokedecreased slightly (16%) and the amount of ironaddition increased. In general, as the amount ofTonolli materials in the feed increased, the amountof reverberatory slag decreased. For this reason,Exide believes that the Tonolli material isdisplacing lead in the form of the reverberatoryfurnace slag which serves as the major feedmaterial to the blast furnaces.

-AR30l*232

RECEIVED

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY EnV>WASHINGTON, D.C. 20460

AUG I 6 1991office of

SOLID WASTE AND EMGRGENCV RESPONSE

MEMORANDUM

SUBJECT: Technical Amendment to the Final Rule for Boilers and Industrial FurnacesBurning Hazardous Waste

FROM: Bob Hollpway, Chief f JL /Combustion Section *

TO: Interested Persons

As you may know, EPA published on February 21, 1991, a final rule regulatingemissions from boilers and industrial furnaces (BIFs) that burn hazardous waste. The rulebecomes effective on August 21, 1991.

Since publication of the rule, we have received many questions requestingclarification of certain provisions and whether die rule as promulgated truly reflected theAgency's intent As a result of those questions and our own review, we believe itnecessary to publish a technical amendment to the rule to clarify the operation of theregulation and to correct certain unintended consequences. On August 16, 1991, DonClay, Assistant Administrator for the Office of Solid Waste and Emergency Response,signed a technical amendment to the BIF final rule that will be effective on August 21,1991.

To apprise interested persons of the amendment, we are sending a copy of thesigned amendment and an Environmental Fact Sheet mat summarizes die amendments to allcommenters on die proposed BIF rules, attendees at our implementation workshops, andpetitioners on the BIF rule.

If you need any additional information or copies of die amendment, please contactthe RCRA Hotline, Monday-Friday, 8:30 a.m. to 7:30 p.m. EST. The national, toll-freenumber is (800) 424-9346; TDD (800) 553-7672, (hearing impaired); in Washington, D.C.,the number is (703) 920-9810, TDD (703) 486-3323.

Attachments

Recycled Paper

8/15/91

and operators must clearly note die use of alternative methods in die certification ofprecompliance, die notification of compliance testing and test protocol, die certification ofcompliance, and recertifications of compliance. The Director may reject die use of analternative mernod because, at his/her sole discretion, it may not meet or exceed die SW-846 performance capabilities.

8. Methods Are Recommended for Determining Chlorine Levels inFeedstreams and the Heating Value of Solid Feedstreams. EPA realized afterpublication of die final rule that Test Methods for Evaluating Solid Waste.Physical/Chemical Mediods. SW-846, third edition, does not include methods fordetermining total chlorine levels in feedstreams or heating values of solid feedstreams.Until methods for chlorine and die heating value of solids are finalized and included inSW-846, EPA recommends die following methods. EPA currcndy recommends diatowners and operators of hazardous waste incinerators use these methods to comply withdie requirements of Subpart O of Parts 264 and 265.9

Total chlorine may be determined by first combusting die sample according toproposed SW-846, Mediod 5050 or die combustion step in ASTM D80810, followed byanalyzing for chloride according to existing SW-846 mediods 9250,9251,9252, orproposed SW-846 mediod 9253. The final gravimetric step described in ASTM D808 isnot recommended because of poor sensitivity. An option for determining total chlorine inaqueous feedstreams is to analyze for both total organic halogens according to SW-846mediods 9020 or 9022, and inorganic chloride according to die mediods listed above.

For heating value of solid feedstreams, EPA recommends use of me AmericanSociety of Testing and Materials metiiods D-2015-77, D-3286-77, or D-808-81 prescribedin die "Annual Book of ASTM Standards", Philadelphia, Pennsylvania, or mediod A006prescribed in "Sampling and Analysis Mediods for Hazardous Waste Combustion", EPA-600/8-84-002, PB84-155845, February 1984.

To implement the use of these methods, EPA is revising §§266.100(c)(l)(ii) and266.102(b) to require die owner or operator to use the best available mediod if SW-846does not prescribe a method for a particular determination. EPA would expect diat ownersand operators would use die mediods recommended above, or mediods that meet orexceed die performance capabilities of die recommended mediods. The Director may rejectdie use of an alternative mediod because, at his/her sole discretion, it may not meet orexceed die performance capabilities of die recommended mediods.

9. Certain Metal-Bearing Wastes Are Conditionally Exempt from theDemonstration of Burning Solely for Metal Recovery when Burned in aMetal Recovery Furnace. The final rule conditionally defers regulation of smelting,melting, and refining furnaces diat bum hazardous waste solely for legitimate metalrecovery. See|266.100(c)at56FR72p8. The rule provides diree tests for diedetermination of burning solely for legitimate metal recovery. The heating value of diewaste cannot exceed 5,000 Btu/lb (if so, die waste is considered to be burned partially forenergy recovery), die concentration of Appendix VTU organic constituents in die wastecannot exceed 500 ppm (if so, die waste is considered to be burned partially fordestruction), and die waste must have recoverable levels of metal.

° See U.S. EPA, HaTaixious Waste Incineration Measurement Guidance Manual.EPA/625/6-89/021, June 1989.!0 See "Annual Book of ASTM Standards", Philadelphia, Pennsylvania.

8/15/91

As we explained at 56 FR 7143, die Agency placed most of its efforts on issuingdie mandated portion of die regulations (i.e., burning of hazardous waste fuels) as soon aspossible, and has not resolved die questions of whether and how to regulate smeltingfurnaces under RCRA given die new air toxics provisions in die Clean Air ActAmendments of 1990. At die same time, however, EPA was concerned diat die deferralnot become a license for sham recycling activities or for operations motivated byconventional treatment objectives radier than recovery purposes. Consequently, die finalrule established limits on die heating value and concentration of toxic organic constituentsin a waste diat is burned for metal recovery.

The secondary lead smelting industry and die secondary nickel-chromium smeltingindustry however, have informed EPA diat die heating value and organic constituent testwould inappropriately classify many wastes (Le., spent materials that are listed or diatexhibit a characteristic, and byproducts and sludges diat are listed in §§261.31 and 261.32- see §261.2(c)(3)) as being burned partially for energy recovery or destruction whensuch lead, nickel, or chromium-bearing materials are typically processed in metal recoveryfurnaces (absent any impetus from RCRA).11 Examples are spent lead acid battery partsdiat can contain pieces of plastic or rubber diat raise die heating value above 5,000 Btu/lb,and baghouse bags used to capture metallic dusts (including recoverable levels of nickeland chromium) emitted by steel manufacturing mat have a heating value above 5,000Btu/lb. As discussed at proposal in the context of lead-bearing materials, we do notbelieve diat such matfrjajs are burned either for sham recycling or for conventionaltreatment. See 54 FR at 43732 (Oct 26,1989).

Accordingly, EPA is revising die BIF rule to conditionally exclude certainhazardous wastes from die provisions of §266.100(c)(2) published at 56 FR 7208. Thoseprovisions are intended to identify when a waste is not processed solely for metal recovery(i.e., die 5,000 Btu/lb limit on heating value, and die 500 ppm limit on concentration ofAppendix VTU, Part 261, toxic organic constituents). As discussed above, EPA believesdiat those criteria may not be appropriate to determine when certain wastes (i.e., a spentmaterial diat is listed or diat exhibits a characteristic, or a listed sludge or by-product, see§261.2(c)(3)) are burned in a furnace for metal recovery. Those wastes diat are deemed tobe burned for recovery of lead are listed in Appendix XI to Part 266 in today'samendments, which largely parallels the list proposed at 54 FR 43732. Those wastes diat

1 * See comments of RSR Corp., Dec. 26,1989, pp. 8-14; comments of SLSA, Dec.26,1989; comments of Exide Corp., Dec. 22,1989, pp. 1-5; correspondence from RobertN. Steinwurtzel, Esq., et aL, Andrews & Kurdi, counsel for Association of BatteryRecyclers, Inc., to Steven Silverman, Esq., EPA, May 21,1991; correspondence fromRobert N. Steinwurtzel, Esq., et al., Andrews & Kurth, counsel for Association ofBattery Recyclers, Inc., to Steven Silverman, Esq., EPA, July 1,1991; correspondencefrom Robert N. Steinwurtzel, Esq., et al., Andrews & Kurth, counsel for Association ofBattery Recyclers, Inc., to Honorable William K. Reilly, EPA, July 1,1991;correspondence from Neil Jay King, Esq., Wilmer, Cutler & Picketing, counsel for TheInternational Metals Reclamation Company, Inc., to Richard Kinch, EPA, July 26,1991;correspondence from William A. Sonntag, Jr., Esq., National Association of MetalFinishers, to Richard Kinch, EPA, July 27,1991; correspondence from John L.Wittenbom, Esq., and William M. Guerry, Jr., Esq., Collier, Shannon & Scott, counselfor die Specialty Steel Industry of die United States, to Docket aerie, EPA, July 29, 1991;and correspondence from John L. Wittenbom, Esq., and William M. Guerry, Jr., Esq.,Collier, Shannon & Scott, counsel for die Steel Manufacturing Association, to DocketClerk, EPA, July 29, 1991.

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are deemed to be burned for recovery of nickel or chromium are listed in Appendix XTI toPart 266. In addition, baghouse bags used to capture metallic dusts emitted by steelmanufacturing are exempt when burned for metal recovery in any metal recovery furnace.Although baghouse bags may have a heating value exceeding 5,000 Btu/lb, they may haverecoverable levels of metals and have historically been burned for metal recovery in asteelmaking or odier furnace.

To ensure diat die wastes listed in Appendices XI and XTJ are, in fact, burned formetal recovery even though diey may have a heating value exceeding 5,000 Btu/lb andmay contain more man 500 ppm of toxic organic constituents, die exemption isconditioned on two requirements. First, die lead-bearing wastes must be generated orinitially produced by the 'lead industry" (except as discussed below) to help ensure diatthese wastes are normally burned in a lead smelter, and die nickel or chromium-bearingwastes must be generated by manufacturers or users of nickel, chromium, or iron (exceptas discussed below) to help ensure diat these wastes are normally burned in a nickel-chromium recovery furnace. Today's amendment defines die lead industry as leadsmelting operations (both primary and secondary), lead-acid battery manufacturing, andlead chemical manufacturing (i.e., producers of lead compounds). Second, if die wastecontains more than 500 ppm of toxic organic constituents, it must not exhibit die ToxicityCharacteristic (TC) of §261.24 for an organic constituent and it must not be listed as ahazardous waste in Subpart D of Part 261 because it contains an organic constituent asidentified in Appendix VII of Part 261.12 This will help ensure diat die waste is notburned partially for destruction of toxic organics. EPA believes diat a waste on die exemptlists provided by Appendices XI and Xn, Part 266, of die BIF rule diat containsrecoverable levels of lead or nickel-cliromium is burned solely for metal recovery in afurnace even if it contains more than 500 ppm of toxic organics provided diat die wastedoes not exhibit TC for an organic constituent and is not listed as hazardous for an organicconstituent The presence of toxic organics in a waste listed on Appendices XI or XII isincidental to die decision to burn die waste for metal recovery.

Persons claiming diat materials listed in Appendices XI or XTJ meet therequirements of §266.100(a)(3Xi-iii) and so are exempt from die 5,000 Btu/lb and 500ppm toxic organics tests must retain for three years documentation supporting die claim,including data from sampling and analysis or odier information. In addition, such personsmust include in die one-time notice (see §266.100(c)(3)) claiming that die metal recoveryfurnace is exempt from die requirements of §§266.102 - 266.111 a certification diatsampling and analysis will be conducted or other information will be obtained as necessaryto ensure continued compliance witii die requirements of §266.100(aX3)(i-iii).

Most of die materials in Appendix XI were proposed in die October, 1989supplemental proposal, and consist of materials generated by, or initially produced by,lead-associated industries, Le., lead smelters, lead-acid battery manufacturing, or leadchemical manufacturing. Examples are batteries and dieir component parts (Le., plates andgroups, grids, posts and separators, and casings), and process wastes from theseindustries. However, there are also certain lead-bearing materials diat are legitimatelyrecycled for metal value by secondary smelters diat are not from lead related industries --lead-based paints, fluff from lead wire and cable casings, platen abrasive (from lead print

12 We note diat die restrictions diat die waste cannot exhibit die TC for an organicconstituent and cannot be listed for an organic constituent apply only to materials onAppendices XI and XH diat are exempt from die <5,000 Btu/lb and <500 ppm toxicorganics tests. Those restrictions do not apply to odier wastes burned by (exempt) smeltersbecause those wastes are subject to die 500 ppm limit on toxic organic constituents.

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linotyping), and spent jumper cables ~ which die Agency is also including. (EPA notes,however, diat all of these materials must actually contain recoverable amounts of lead to bedeemed burned for metal recovery. See new §266.100(c)(3).) Similarly, we haveincluded in Appendix XII a list of nickel or chromium-bearing materials diat are legitimatelyrecycled for metal value by nickel-chromium recovery furnaces diat are not generated bymanufacturers or users of nickel, chromium, or iron (e.g., electroplating wastewatertreatment sludges, and nickel-cadmium and nickel-iron batteries).

In addition, we note diat several lead-bearing materials diat have been historicallyprocessed in lead recovery furnaces have not been included on die Appendix XI list: by-product drosses, slurry and slurry screenings, slags, and scrap lead. We did not includethese materials because they are eitiier not solid wastes when recycled or are exempt fromregulation when recycled. See §§261.2(c)(3) and 261.6(a)(3)(iv).

Finally, we note diat die Agency may determine diat a material on Appendices XI orXTJ burned at a particular metal recovery furnace may have levels of toxic organicconstituents substantially higher than a total of 500 ppm. (The Agency could make thisdetermination because owners and operators claiming die exemption must notify dieAgency. The Agency may then obtain waste analysis data or odier information from diefacility record or from EPA sampling diat indicates die presence of high levels of toxicorganic constituents.) The amended rule enables die Agency to determine on a case-by-case basis diat die material may pose a hazard to human health and die environment whenburned in a metal recovery furnace due to presence of toxic organic constituents at levelsexceeding a total of 500 ppm, and to order diat die burning either cease or be conducted incompliance witii the BIF rule. The Agency is adopting this extra safeguard even though dierule already provides diat, to be exempt from die <5,000 Btu/lb and <500 ppm toxicorganics tests, die material cannot be listed for a toxic organic constituent or fail dieTpxicity Characteristic (TC) for a toxic organic constituent. The waste might still containhigh levels of toxic organic constituents diat are not included in die TC or die material'smatrix may not readily leach toxic organic constituents during die TC extraction procedurebut would be liberated during burning in die furnace. In making die determination, EPAwould consider die concentration and toxicity of toxic organic constituents in die material,die level of destruction of toxic organic constituents provided by die furnace, and whetherdie acceptable ambient levels established in Appendices IV and V of Part 266 may beexceeded for any toxic organic compound diat may be emitted (Le., including products ofincomplete combustion) based on dispersion modeling to predict die maximum annualaverage off-site (unless a person resides on-site) ground level concentration.

Should die Director determine diat burning particular wastes with organiccontaminants in a metal recovery furnace poses a hazard to human health and dieenvironment, as explained above, die Agency would issue a notice to die company burningdie waste indicating the basis for du's tentative determination. The company would have anopportunity to respond to die determination but could not burn die waste in die interim.The Director would tiicn make a final determination and document die basis for hisconclusion. If die conclusion is diat die waste would pose a hazard, then further burningwould be illegal unless performed in compliance with die BIF rules. (It also may bepossible to pretreat die waste to remove or destroy organics, and then bum it safely.) Thedetermination would only apply to subsequent burning, however. There would be noenforcement penalties for burning occurring before die Director's tentative determination.

10. Precious Metal Recovery Furnaces Engaged in Legitimate MetalRecovery Are Not Regulated by the BIF Rule. EPA has been asked about dieregulatory status of precious metal recovery operations under die BIF rules. Suchoperations are generally exempt from subtitle C regulation (with die exception of certain

10

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11. Appendix XI to Part 266 is added to read as follows:

APPENDIX XL - LEAD-BEARING MATERIALS THAT MAY BE PROCESSED INEXEMPT LEAD SMELTERS

A. Exempt Lead-Bearing Materials 'When Generated or Originally Produced By Lead-Associated Industries*

Acid dump/fill solidsSump mudMaterials from laboratory analysesAcid filtersBaghouse bagsClothing (e.g., coveralls, aprons shoes, hats, gloves)SweepingsAir filter bags and cartridgesRespiratory cartridge filtersShop abrasivesStacking boardsWaste shipping containers (e.g., cartons, bags, drums, cardboard)Paper hand towelsWiping rags and spongesContaminated palletsWater treatment sludges, filter cakes, residues, and solidsEmission control dusts, sludges, filter cakes, residues, and solids from lead-associated

industries (e.g., K069 and D008 wastes)Spent grids, posts, and separatorsSpent batteriesLead oxide and lead oxide residuesLead plates and groupsSpent battery cases, covers, and ventsPasting beltsWater filter mediaCheeseclodi from pasting rollersPasting additive bagsAsphalt paving materials

* Lead-associated industries are lead smelters, lead-acid battery manufacturing, and leadchemical manufacturing (e.g., manufacturing of lead oxide or other lead compounds).

B. Exempt Lead-Bearing Materials When Generated or Originally Produced By AnyIndustry

Charging jumpers and clipsPlaten abrasiveFluff from lead wire and cable casingsLead-based pigments and compounding pigment dust

33

FLOW PIAflBAMIFUMINO/OASIFICATION

EXCAVATEI

TRUCK TO SMELTERI

RECEIVE, SIZE, STORAGE

TRANSPORT TO FURNACE MATERIAL BINS

COAL

CONTROLLED FEED TO WEIGH/BLENDING I

CONTROLLED FEED TO FURNACE |

iOXYGEN WATER

, ___________ , .I FUM1NG/GA8IFIER FURNACE > —————— | VAPORIZER |

METAL FUMES/PRODUCED GAS I ASH(POSSIBLE ROADWAY MAT'

REVERB #1 I REVERB *2

I SOLIDS |

AFTERBURNER

COOLERzr:DUST COLLECTOR

I SOLIDS

IAFTEHBUHNER——-——I COOLER |-±

I OUST COLLECTOR

LIME SLURRY |---SCRUBBER!—————*—————H SCRUBBER |

SLUDGE H

~i TO ATMO i>HERE | ' | TO ATMOSPHERE I

FIGURE 4

IMPLEMENTATION SCHEDULE

DATE OF COMPLqTfON

Initial PSU Proposal APR '92Review/Revise PSU Proposal MAY »92Engineer Containment Building/Equipment JUN '92Literature Review by PSU1 JUL '92Local Containment Building Approval2 SEP '92Issue Containment Building Contract OCT '92Start Waste Removal MAY '93Pilot Furnace Review PSU MAY '93Complete Waste Removal APR '94Site Restoration Completion JUN '94Furnace Conceptional Engineering APR '94Permit Preparation/Submission PSU MAY '94Permit Review/Revision/Issuance SEP '94Furnace Detail Engineering SEP '94Equipment Purchase OCT '94Equipment Delivery/Installation JUN '95Equipment Start Up/Testing AUG '95Completion of Fuming/Gasification OCT '98

May require review of facility Air Quality permit to assess net emissionincrease.

May require RCRA permit prior to construction as an RCRA waste pile.Recently proposed EPA regulations could reclassify this unit as acontainment building and eliminate the need for RCRA permitting.

flR30l*405

FIGURE 5

TOIT.JTMl

I TRUCK PROM SITE |i I DUST COLLECTOR

I TRUCK WEIGH | ————————————

iiuaiJLija ^

A •••.-.•.•

..'.'

' :•.. 'in !•.•.•.•.'.•.•.•.-.•.•••.•.•.•••.•.••'.••'.'•'.••'.••'.••'.'•'.••'.••'.••'.••.••.••.••.••.••.'•.••.••.'•.••.'•• . . • . . • . . * . • . . • . . • . . • . . • - . • . , •

PNEUMATIC 1t ,______L

| PNEUMATIC CONVEYOR | . | PHEUKATIC CONVEYOR"ZE t.

SOIL BIN AT CASINGS BIN ATFUMING/GASIFIER FURNACE FUlilNG/QABIFIgR FURNACE

1—

- -__;i*S I

9 ^

Mm&

Bi*E7L %itefe3

FIGURE 7

TYPHCAL INTBBNAL ENACTION SONBg «DIPMIBTAL

COALGASIFICATION ZONE CASINGS

ENDOTHERMIC SOILCO, + C—CO (—500 BTU/FT.') |CO * H,0—CO, + Ha (FUEL GAS)

OXTGIN

f_t GASIFICATION ZONEWATER '""l

BUMM ZONE3,000* F. MAX.

'—WATIL^ ~ CINDER ZONE

EXOTHERMICC +• 0,- COt ASH

STEAM/OXYGEN

•EXIDE CORPORATION · -Viability, Section 4.1, pg.10, 3rd paragraph - What is meant by the...

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