■ ■ ■ ■ m Hi ■ ■ i ■ ,o- *<2* ^ v . ^ ** -*w w #fe ^/^life- w ••^ v \-^-.V /^^^°o y..^i:-X /^^% /.c- : v ; s • ° ^ ^ •* C> - o « » * ^ O *o„o' .0-' V "oK fl H<^ •^o* ^ ^ »^°. ^ *• • * * o- aV ^ ,^ V % V ■ -o 'o . * * A r > 'V^ J* \. 'X o . » • .0 V \5. "'TIT* ' A ^0^ ^o^ A^ ^ ° *-U^ s A, * V V * *bP ^ %<• J <*, .*« •, **b. * » » » ° ^ ./% 4?^ **'^ a^'V .^ ^ J .w. ! ^ y ^ of Bureau off Mines Information Circular/1 987 Domestic Secondary Lead Industry Production and Regulatory Compliance Costs By R. Craig Smith and Michael R. Daley UNITED STATES DEPARTMENT OF THE INTERIOR / Information Circular 91 56 Domestic Secondary Lead Industry: Production and Regulatory Compliance Costs By R. Craig Smith and Michael R. Daley UNITED STATES DEPARTMENT OF THE INTERIOR Donald Paul Hodel, Secretary BUREAU OF MINES Robert C. Norton, Director As the Nation's principal conservation agency, the Department of the Interior has responsibility for most of our nationally owned public lands and natural resources. This includes fostering the wisest use of our land and water resources, protecting our fish and wildlife, preserving the environment and cultural values of our national parks and historical places, and providing for the enjoyment of life through outdoor recreation. The Department assesses our energy and mineral resources and works to assure that their development is in the best interests of all our people. The Department also has a major responsibility for American Indian reservation communities and for people who live in island territories under U.S. administration. __.. . Library of Congress Cataloging-in-Publication Data Smith, R. Craig. - Domestic secondary lead industry. (Information circular; Bibliography: p. Supt. of Docs, no.: I 28.27: 1. Lead industry and trade — United States — Costs. 2. Lead — Recycling — Costs. 3. Lead industry and trade — Environmental aspects — United States. 4. Lead industry and trade — Law and legislation — United States — Compliance costs. I. Daley, Michael R. II. Title. III. Series: Information circular (United States. Bureau of Mines); -^FN295:U4 [HD9539.L42U5] 622 s [338.2'3] 87-600137 For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C. 20402 Ill CONTENTS Page Page Abstract 1 Operating costs 8 Introduction 2 Variations in operating costs due to size 8 Acknowledgments 2 Factors affecting operating costs 10 Methodology 2 Environmental legislation and compliance costs 10 Domestic secondary lead industry 3 Costs of compliance 11 Secondary lead processing 4 Compliance capability 12 Battery breaking 5 Conclusions 12 Smelting methods 5 References 13 Refining methods 6 Bibliography 13 Waste disposal 7 Appendix A. — Example of capital and operating Sulfuric acid 8 cost estimates for environmental regulatory Dust, organics, slags, and drosses 8 compliance 14 ILLUSTRATIONS Page 1. Generalized secondary lead flow 3 2. Secondary lead smelting and refining process composite _, 4 3. Cross section of a typical blast furnace 5 4. Cross sections of a typical stationary reverberatory furnace 6 5. Cross section of a typical short-rotary reverberatory furnace 6 6. Cross section of a typical refining kettle 6 7. Operating cost estimates for present, pending, and proposed environmental regulatory compliance 11 8. Capital cost estimates for pending and proposed environmental regulatory compliance . . . .' 12 A-l. Original smelter facilities 14 A-2. Additional smelter facilities for CWA 14 A-3. Additional process emissions control equipment and ductwork for PEL 15 A-4. Additional downcast ventilation and ductwork for PEL 15 A-5. Original smelter process emissions control equipment, ductwork, and building enclosure 16 A-6. Additional building enclosures for NAAQS 16 A-7. Additional process emissions control equipment and ductwork for NAAQS 17 A-8. Additional building enclosures for RCRA 17 TABLES Page 1. U.S. regional average price variations for scrap batteries in 1985 3 2. Historical refined lead statistics 4 3. Lead refining: Elements removed and reagents used 7 4. Average operating cost estimates for smelter size ranges 9 5. Current regulatory compliance operating costs 11 6. Pending and proposed regulatory compliance cost estimates for secondary lead smelters 11 A-l. CWA capital cost estimate 15 A-2. CWA annual operating cost estimate 15 A-3. OSHA's PEL capital cost estimate 16 A-4. OSHA's annual operating cost estimate 16 A-5. NAAQS capital cost estimate for the current regulation of 1.5 ptg/m 3 17 A-6. NAAQS annual operating cost estimate for the current regulation of 1.5 M-g/m 3 1/7 A-7. RCRA capital cost estimate 18 A-8. RCRA annual operating cost estimate 18 UNIT OF MEASURE ABBREVIATIONS USED IN THIS REPORT A ampere km kilometer °C degree Celsius kWh kilowatt hour cm centimeter lb pound eVKWh cent per kilowatt hour m meter c/lb cent per pound mt metric ton (2/mt-km cent per metric ton kilometer mt/yr metric ton per year d/yr day per year **g microgram op degree Fahrenheit ixg/m 3 • microgram per cubic meter ft foot |xm micrometer ft 2 square foot min/d minute per day ft7min cubic foot per minute Mmt million metric tons g gram pet percent ga gauge ppm part per million h hour spd shift per day h/d hour per day st short ton hp horsepower V volt in inch yr year kg kilogram DOMESTIC SECONDARY LEAD INDUSTRY: PRODUCTION AND REGULATORY COMPLIANCE COSTS By R. Craig Smith 1 and Michael R. Daley 2 ABSTRACT The Bureau of Mines conducted a study of production costs for the secondary lead industry and determined costs for present, pending, and proposed environmental legislation. Operating costs for smelters by capacity groups range from 16.8 to 19.6 cTlb of refined lead. Present regulatory compliance costs for these groups range from 2.2 to 2.4 tf/lb. Pending compliance costs could add 3.5 cTlb of refined lead, and proposed regulations could add another 1.3 cVlb. The individual capital costs necessary to comply with pending environmental regulations are estimated to be $1.8 million for small smelters and $10.4 million for large smelters. Proposed regulations could require additional expenditures from $1.9 million for small smelters to $4.9 million for large smelters. These cost estimates, based on average 1985 dollars, indicate that pending and proposed legislation could add significantly to capital and operating costs of the secondary lead industry. These regulatory compliance costs may result in a loss of up to 40 pet of secondary lead production capacity. 'Physical scientist. 'Mineral specialist. _ Intermountain Field Operations Center, Bureau of Mines, Denver, CO. INTRODUCTION The purpose of this report is to assess the economics of producing lead by the domestic secondary lead industry 3 and to evaluate the costs and impacts for present, pending, and proposed environmental regulatory compliance. Be- cause the industry produces approximately 50 pet of the refined lead in the United States, the resource of scrap material becomes a significant commodity, which should be considered in Federal minerals policy. The Bureau of Mines conducted this study as part of the Minerals Availability Program (MAP), which evaluates the avail- ability of commodities. The production capability and economic assessment of each operation is an integral part of this program. The scope of this study includes an economic assessment of the domestic secondary lead industry and an estimation of the costs and impacts to the industry from regulatory compliance. At the time this study was begun, in January 1986, there were approximately 24 operating smelters with production capacity greater than 3,000 mt/yr. Smelters with capacity less than 3,000 mt/yr were not included in the study because they represented less than 1 pet of total production capacity. Over the past several years, there have been many reports published by consulting firms on the cost and implications of environmental regulatory compliance (2 -4). 4 In general, the findings in this report support their cost estimates. The following are the major differences: 1. The Bureau's capital cost estimate for compliance with all of the environmental regulations affecting the secondary lead industry is less than some industry estimates, but is also based on fewer operating smelters, due to recent closures. At the time this study was conducted, there were 24 operating smelters with capaci- ties greater than 3,000 mt/yr. 2. Published operating cost estimates, updated to average 1985 dollars for comparison, indicate that the Bureau's cost estimate is higher by approximately 2 eflb refined lead. This is because the Bureau's estimate includes transportation charges and more regulatory compliance costs. 3. The Bureau's estimate for present regulatory com- pliance operating costs is higher than updated published estimates by approximately 1.5 0lb. The difference can be attributed to the additional compliance presently being performed compared with that actually being performed several years ago. Assuming that this accounts for the higher operating cost, then the net total operating cost difference between previously published sources and the Bureau's estimate is approximately 0.5 0lb refined lead. 4. The Bureau's estimate for proposed regulatory compliance costs is approximately 1 0/lb less than updated published estimates. 5. The Bureau's estimate of lost production capacity because of shutdowns is less than half of previously published estimates. However, the secondary lead indus- try has lost aproximately 35 pet of production capacity since those estimates were made. ACKNOWLEDGMENTS The authors would like to thank William D. Wood- bury, lead commodity specialist, Bureau of Mines, Washington, DC, for guidance and technical assistance. In addition, the authors would like to thank the following companies: Alco Pacific Inc., Gardena, CA; Bergsoe Metal Corp., St. Helens, OR; Chloride Metals Inc., Tampa, FL; Dixie Metals Co., Dallas. TX; East Penn Manufacturing Co., Lyon Station, PA; GNB Inc., St. Paul, MN; General Battery Corp., Reading, PA; Murmur Corp., Dallas, TX; Ross Metals Inc., Rossville, TN; Schuylkill Metals Corp., Baton Rouge, LA; and Standard Industries, San Antonio, TX; for providing technical assistance and operating information. METHODOLOGY The secondary lead industry is extremely variable with respect to degree of integration, market conditions, production capacity, and products. To assess the econo- mics of the industry, operating costs had to be standard- ized to reflect only those costs associated with acquiring and converting scrap lead into refined metal. 5 For ^The secondary lead industry refers to companies involved in the recycling of scrap lead materials by smelting and refining the lead into reuseable products. Presently (1986), approximately 80 pet of the scrap lead is in the form of spent automotive batteries. 4 Underlined numbers in parentheses refer to items in the list of references at the end of this report. 5 Refined metal is considered to be antimonial lead, soft lead, oxide lead, and calcium lead. Other types of refined lead are actually produced but are an insignificant amount of production and are not considered to affect operating costs. example, some fully integrated smelter complexes pur- chase scrap, smelt and refine it, and use the refined lead to fabricate new storage batteries. The costs associated with making new batteries, beyond the refining stage, are not included in this study. The battery fabrication costs include labor, materials and supplies, administration, and a percentage of property taxes, insurance, and deprecia- tion. Procedures to obtain data for estimating operating costs included site visits to several smelters considered to be representative of the industry, industry canvassing to obtain specific operating details, and engineering studies of smelting and refining practices. Twelve companies responded to the canvass and supplied detailed cost data. These companies represented approximately 67 pet of the 1985 domestic secondary lead production. Operating costs have been consolidated and averaged to conceal company- proprietary data. All costs are presented in average 1985 dollars. For this study, initial capital costs have been excluded. Ongoing capital expenditures for improve- ments, modifications, and regulatory compliance have been identified, and a percentage of these costs are included as depreciation. The purpose of this procedure is to show net operating costs for current market conditions so that future profits or losses for environmental compliance expenditures can be estimated. DOMESTIC SECONDARY LEAD INDUSTRY The secondary lead industry primarily recycles new and old scrap. New scrap is a waste product of fabrication, casting plants, purchased drosses, and other residues. Old scrap is a product of wornout equipment and materials, such as batteries, cable, and type metal. Most recycled scrap lead is in the form of spent automotive batteries. Availability of lead scrap is contingent on the amount of prior production, durability of lead-bearing goods, and incentive to recycle (1). In 1984, battery scrap accounted for 76 pet of recycled lead (5). In the first quarter of 1986, an estimated 80 pet of recycled scrap was in the form of spent batteries. Most scrap is reprocessed into storage battery materials, although a variety of other commod- ities are produced. There are approximately 70 companies producing some form of secondary lead, but in 1985, 23 companies operating 30 smelters produced 98 pet of the total (6). A generalized process flow is presented in figure 1. Slag and new scrap c Old scrap Slag > Smelling turnaces ^ __ f Smelting \ reagents J c <* Specialty alloy Market Market Market Market Figure 1 . — Generalized secondary lead flow. Most secondary lead smelters have contracts with battery producers, other secondary smelters, and indepen- dent manufacturers. Secondary smelters, especially the large-capacity plants, have long-term contracts with battery producers. This is the most economical arrange- ment because these smelters supply lead to the battery producers and then back-haul spent batteries. However, this arrangement does not necessarily supply the majority of scrap lead, resulting in a competitive scrap lead recycling industry. Transportation distances up to 1,600 km are not uncommon, and scrap prices vary by region. The primary reason for scrap price variations is demand. The Northeast has competition with Canada and Brazil for scrap, and the west coast has competition with Asia, Brazil, and Mexico. The South currently has the least competition and the lowest price for scrap (table 1). Exports have been increasing to southeast Asia and Mexico for the last several years and have made the entire west coast a very competitive market (6-7). Foreign smelters can afford to bid a higher price for scrap because their capital, labor, and environmental costs are lower than U.S. producers. This puts west coast smelters in a low profitability position because of the high price of scrap. TABLE 1.— U.S. Regional average price variations for scrap batteries in 1985, cents per pound Area West Northeast South .... Whole batteries Lead content 3.85 3.00 2.65 8.0 6.2 5.5 Production capacity in 1981 was estimated to be 1.2 Mmt, but because of oversupply, weak demand, high prices for scrap, and environmental regulatory costs, several smelters have been shut down and dismantled. This represents a permanent loss of production capacity. Domestic installed production capacity is now estimated to be 900,000 mt. In 1985, due to permanent and temporary smelter closures, operating companies had a combined capacity of 800,000 mt, of which approximately 600,000 mt of refined lead was produced. More closures and resultant loss of capacity can be expected if current market conditions and proposed environmental regula- tions go into effect. In 1984 and 1985, battery scrap as a percentage of recycled secondary lead has been increasing (table 2). Secondary lead production has also increased as a percentage of total lead production. Strikes at the domestic lead mines in 1984 and low primary production, because of poor economic forecasts for 1985, were the main reasons for the increases (6). Capacity utilization for operating secondary smelters was 75 pet for 1984 and 1985, and worse in the preceding years due to significant overcapacity. TABLE 2.— Historical refined lead statistics, thousands of metric tons of contained lead Production 1981 1982 1983 1984 1985 Domestic ores 440.2 459.9 459.3 330.2 416.1 Foreign ores 55.1 52.3 55.2 65.4 71 .4 Secondary lead, new and old scrap 641.1 571.3 503.5 633.4 594.2 Batteries, pet of secondary lead 75 77 74 77 78 Secondary lead, pet of total refined lead 56 53 49 62 55 Source: Woodbury (2). The average 1985 price for refined lead was 19.2 eVlb. This represents a 25 pet decrease from 1984 and the lowest price this century in terms of constant 1985 dollars (8). The average price of refined lead for the first quarter of 1986 was 18.4 Refractory lining Side tapping ^7 Combustion air fans Figure 4.— Cross sections of a typical stationary reverbera- tory furnace. (Courtesy Tolltreck International Ltd.) A) Interior, exhaust end and B) Exterior, combustion end. Because the throughput rate of a stationary rever- beratory furnace is relatively slower than the rate of a blast furnace, refining within the reverberatory furnace is possible. In particular, high lead-content drosses may be formed and recovered, as well as slags with high lead and antimony content. These materials may be returned to the blast furnace for further lead recovery. The rotary reverberatory furnace has some similar- ities with both the stationary reverberatory and the blast furnace. The rotary, like a blast, may handle a wider variety of feed materials because most charges are handled in batches. This allows the flux component to be adjusted to the specific assay of the material to be reduced. Like the stationary reverberatory furnace, it has an external fuel source so that after the reduction reaction has been carried out, it may retain the melt for drossing. The primary advantage of this system is the thorough mixing action, which optimizes the reduction recovery and rate. The mixing action also allows optimum reaction time for drossing. Rotary reverberatory furnaces have a relatively simple design. They are barrel shaped, from 1.8 to 4.5 m in diameter, and 2.5 to 6.8 m long, with gas jets fixed in a stationary plate at one end and an attached charging door at the other end (fig. 5). One of the primary problem areas for rotaries in the United States has been a premature failure of the refractory linings within the furnace barrel. Burner Drive train Figure 5. — Cross section of a typical short-rotary reverbera- tory furnace. (Courtesy Tolltreck International Ltd.) These problems have been gradually remedied over the past few years, and now rotaries are being received more favorably in the United States. The rotary design is a compromise between the operating flexibility of the blast furnace for smelting and the refining capability of the stationary reverberatory furnace. REFINING METHODS Refining is the final step in the chemical purification process of secondary lead recycling. It is accomplished in open-topped containers, called refining kettles, that are usually semispherical in shape and are constructed of cast iron or steel. Kettles range in depth from 1 to 2.2 m, with capacities of 25 st or more. All are heated from below, with the kettle seated in a specially constructed, refractory- lined, steel-sheathed furnace (fig. 6). Melt agitation is accomplished by mechanical impellers or by specially designed air jets, which impart a stirring motion. Mixer drive Fume hood Figure 6.— Cross section of a typical refining kettle. (Cour- tesy Tolltreck International Ltd.) The refining process upgrades lead bullion to soft lead (pure lead) or alloys. It is in this stage that reaction rates, and selective reactivity, become critical. If a particular reagent is added at the wrong time, a potentially toxic substance may be formed or a beneficial metal may be prematurely removed. In some cases, a potentially valuable byproduct may even be lost in the process and require additional processing to recover it. Table 3 is a summarized listing of the alloy metals that may need removal and some of the reagents commonly used for that purpose. TABLE 3. — Lead refining: Elements removed and reagents used Element removed Principle used Temp, 1 °C Basic reagent Other alloying elements affected Ag Intermetallic . . . 675 As do 675 ..do 675 Oxidation 620 . .do 455 Bi Intermetallic . . . 675 Cu do 675 Limited 400 solubility. Chemical 330 . .do 330 Fe Intermetallic . . . 675 Chemical 400 Limited 400 solubility. Ni do 400 Sb Sn Zn Chemical 330 . Intermetallic . . . 675 Oxidation 620 .do. . .do . . . . . .do . . . . ...do.... ..do... ..do.... ..do.... . Limited solubility. ..do.... . .do . . . . Fine solids do ..do 620 565 425 620 620 480 425 600 400 400 400 400 Zn None. Al Sb.Cu. Zn None. Air Sb, Sn. K 2 C0 3 Sn. Ca, Mg None. Al As, Sb. Pitch or Ni, Fe, Zn. sawdust. S Sn. NaOH with S .. .. .. 2 Sn. Al None. S Cu, Sb, Ni. Pitch or Cu, Ni, Zn. sawdust. Pitch or Cu, Fe, Zn. sawdust. S Cu, Sn. Al As, Cu. Pb 3 4 Sn. Air Sn, As. NaOH, NaN0 3 Sn. NaOH, NaN0 3 Sn. Pb 3 4 None. Air Sb, As. NaOH, NaN0 3 As, Sb. NaOH, NaN0 3 None. Vacuum None. distillation. NH4CI with NaOH.. None. Pitch or Cu, Ni, Fe. sawdust. Steam Finely divided Natural Gas metallic solids. 1 All temperatures are at or near upper range for the particular reactions listed. 2 Sn interferes with the chemical reaction promoted by the NaOH, therefore, this reaction cannot be used when Sn is present in the melt. Source: Modified from Hudson (10). Antimonial lead is the most common product of secondary lead operations, primarily because most pro- duction is derived from, and recycled into, lead-acid batteries. The initial step in the refining process is to decopperize the melt. If the sulfur method is to be used, the lead temperature is dropped from the smelting temperature to around 320° to 330° C and then elemental sulfur is mixed into the kettle. For the dry drossing method, the temperature is held at 400° C and pitch or sawdust is used instead of sulfur. These processes produce a copper sulfide dross, which can then be returned to the smelting furnace for lead recovery. The softening process normally used to remove arsenic and tin is the bubbled air method. With the melt at a temperature of 620° C, air is bubbled through the molten lead, and the dry dross is skimmed off. Some operations will use sodium hydroxide to form sodium stannates and arsenates in a dross. If a fully softened lead is needed (lead which contains no antimony, arsenic, or tin) then sodium nitrate (niter) can be used in conjunction with air. The niter speeds up the oxidation rate and acts as a catalyst so that all three impurities are removed at the same time. For those operations where the feed stock contains no arsenic, aluminum may be used to remove copper, antimony, and nickel. This procedure will remove copper and nickel to acceptable levels. If the melt has appreciable zinc values that must be removed, then the sulfur method will be used to remove the copper. The pitch-sawdust method removes copper and zinc at the same time and produces a combined copper-zinc dross that is not as readily marketable as either copper or zinc drosses. Zinc is considered to be a very detrimental alloying agent in lead products. For those operations that treat scrap with appreciably large zinc assays, a vacuum distilled zinc process is generally used. This is accom- plished by heating the melt to 600° C in a kettle with a specially fitted vacuum hood, which maintains a very low vacuum pressure to boil off the zinc. The hood has its own cooling system, which causes the zinc to condense and crystallize on the inside of the hood. This method requires no further processing to produce a marketable zinc byproduct. When producing calcium alloys, the calcium is added to a mixed kettle of softened lead. Calcium is added in its metallic form or as a reactive carbide. Because of the susceptibility of the calcium to oxidation during this process, it is normal to have a layer of nonreactive material on the surface of the melt. Lead oxide is made from softened lead or primary lead, commonly by the Barton process. Lead is melted in a melting pot, continuously fed into a Barton pot (reactor), and atomized. The atomization process involves rotating mixer blades just at the molten lead surface, which produces particles of Pb of 5 u-m or less. As the lead is oxidized to PbO, it is entrained in the air stream and conveyed to the air pollution control system. Approx- imately 60 pet of the product is recovered in the settling chamber and 15 to 20 pet in the cyclone. The remaining product is collected in the baghouse. The product is then augered to storage bins or to a hammer mill. The hammer mill is primarily used to insure a uniform product and to meet specifications. After refining and alloying, the metal is pumped to casting machines. The final cast form can range in weight from special-order 20-lb bars to 2,000-lb blocks. Forms may be rounds, bars, ingots, pigs, hogs, billets, or any of a number of different speciality shapes. Standard practice is to cast 65-lb ingots or 2000-lb hogs. The ingot casting chain is water cooled and usually requires personnel for skimming off the oxidized layer. For small custom operations, ingot casting may be done by hand with long-handled lead dippers used to pour the lead into single, twin, or five-cavity molds. WASTE DISPOSAL Because of the hazardous nature of the materials being handled at secondary lead operations, special precautions are necessary to prevent air, water, and land contamination. Waste disposal is therefore an important aspect of secondary lead recycling. The primary waste products are sulfuric acid, dust, organics, slags, and drosses. These wastes are either neutralized, recycled, or transported to hazardous waste-dump sites. SULFURIC ACID Acid neutralization is the most involved and costly aspect of waste disposal. Presently, there are three chemical processes being employed within the industry: lime neutralization, soda ash neutralization, and anhy- drous ammonia neutralization. The Environmental Pro- tection Agency (EPA) has determined that the lime neutralization method is the best available technology (BAT), and compliance with this standard is scheduled for March 1987. Lime neutralization involves mixing lime with acid, resulting in the formation of gypsum and water. The gypsum is placed in settling bins or is filtered to reduce the moisture content. It is then transported to hazardous waste dumps because it generally exceeds the EPA limit of 5.0 ppm lead or the variable state limits. This method of acid neutralization produces large quantities of gypsum. An average recycled battery produces about 0.6 kg of dry-weight gypsum. Disposal, therefore, becomes a very expensive operating cost item. Neutralization with soda ash is a more expensive neutralization and monitoring process, but there are no waste product transportation costs. This process mixes the soda ash with the acid to form a weak sodium sulfate solution. Filtration and pH adjustment are required to keep lead levels at a minimum, and then the solution is pumped into the sewer system. The solution is generally alkaline (pH 7-10), which actually helps the water treatment plants because they can have serious problems with acidic solutions. This neutralization process is not as effective as the lime neutralization process for removing lead and also produces a large amount of dissolved solids in the waste stream. The ammonia neutralization process produces ammo- nium sulfate, which is water soluble, nontoxic, and biodegradable. If the waste stream is low in metals (lead, arsenic, antimony, selenium, and cadmium), then ammo- nium sulfate crystals can be produced for use as a fertilizer. The process also allows for pumping the solution into the sewer system, but most sanitation departments do not permit it because of the high biological oxygen demand (BOD) and the large amount of dissolved solids. This neutralization process is not considered to be BAT because the Clean Water Act (CWA) classifies ammonia compounds as "nonconventional pollutants." The regula- tion requires that 90 pet of nonconventional pollutants be removed from waste water discharges. Because of the regulation, this acid neutralization process is no longer considered to be a viable alternative. DUST, ORGANICS, SLAGS, AND DROSSES Dust, organics, slags, and drosses are additional waste products from lead processing. Several smelting and refining stages produce significant quantities of offgases, which contain lead particulates. To meet emission standards, it is common practice to use baghouses to filter the lead particulates from the offgas. Baghouse dusts are recycled as furnace feed until other elemental accumula- tions, primarily cadmium and chlorine, reach assay levels requiring other methods of processing. When this occurs, the dust is usually sold to smelters that can process the material. Disposal of the organics (rubber, PVC, and battery- casing plastic) is handled in several ways. Some opera- tions burn the rubber, plastic, and PVC in the smelting furnace and realize some energy savings. The most common method is to dispose of the rubber and PVC in hazardous waste dumps, and sell the plastic to battery- casing manufacturers. Almost all slag is disposed of in hazardous waste dumps because it cannot meet structural integrity tests, or the leachable lead content is too high. Slags are usually hauled by contractors to State-approved disposal sites. Drosses are reprocessed onsite to reduce the lead content until the impurity metals reach a level that cannot be handled by the smelter. The drosses are then sold to other smelters that can process the material. Copper drosses and arsenic-tin drosses are the most common drosses produced. OPERATING COSTS To evaluate smelters on a common basis, all dollar values were adjusted to average 1985 dollars, and only those costs associated with producing refined metal were considered. For example, a fully integrated smelter complex with an end product of packaged batteries would be evaluated only from battery breaking through refining. All additional costs for labor, utilities, materials, supplies, maintenance, and overhead associated with battery production are excluded. Cost items such as property taxes, insurance, and some general office charges are proportionally allocated. The operating costs have been separated into conver- sion costs, lead supply costs, and miscellaneous costs for clarity and comparison. Conversion costs represent the cost of converting scrap lead into refined lead and lead alloys. Included in these costs are materials and utilities, maintenance, general services, labor, administration, environmental, property taxes, and insurance. Lead supply costs represent the cost of purchasing delivered scrap lead. Miscellaneous costs represent cost items that affect individual operating economics, such as credits, transportation, and depreciation. VARIATIONS IN OPERATING COSTS DUE TO SIZE Table 4 presents the operating cost breakdowns for smelters grouped into size ranges. Grouping by size serves the purpose of disguising individual company-proprietary data and shows relative economies of scale for the size ranges. The table shows an economy of scale for the medium size range smelters over the smaller smelters, but a diseconomy between medium and large smelters. This diseconomy is primarily a result of under utilization of capacity for the large smelters. If the large smelters were 805,020 1 ,704,360 3,847,470 109,960 75,140 42,340 139,970 185,650 184,560 542,160 285,300 176,580 227,440 510,180 1,004,040 TABLE 4. — Average operating cost estimates for smelter size ranges, average 1985 dollars Capacity mt/yr. . 1 5,000-15,000 2 1 5,000-40,000 3 40,000-85,00o" ANNUAL COSTS Materials and utilities: Electricity 124,570 215,540 587,800 Natural gas 140,310 326,530 955,360 Fuel 11,620 18,820 67,500 Coke 165,470 450,510 456,880 Scrap iron 30,130 130,860 190,300 Limestone 9,060 7,210 8,040 Arsenic 23,500 27,200 81,320 Antimony 83,130 123,600 468,840 Tin 81,330 44,980 100,090 Calcium 8,790 Selenium 1,130 10,800 Oxygen 28,200 128,910 76,830 Zinc-aluminum 5,480 Hydrated lime 400 11,580 69,560 Caustic soda 28,570 20,200 31,800 Caustic potash 500 4,470 2,660 Sodaash 12,410 2,500 397,630 Miscellaneous materials 64,690 177,180 342,060 Subtotal Maintenance materials: Repair parts, mechanical Repair parts, consumable ... Purchased and rental service Subtotal Labor: Production labor 329,160 687,830 1,197,290 Supervision 80,170 190,350 285,740 Maintenance labor 55,300 118,680 347,160 Supervision 65,730 45,840 78,070 Administrative 91,430 338,990 638,280 Payroll overhead 176,130 522,800 811,360 Subtotal 797,920 1,904,490 3,357,900 Indirect costs: General office 70,510 313,320 299,210 Environmental (partial) 108,280 553,360 1,158,900 Property taxes 4,350 86,140 146,590 Insurance 43,470 74,570 41,540 Subtotal 226,610 1,027,390 1,646,240 Scrap lead supply: Batteries 552,130 2,395,030 5,077,820 Primary lead 184,960 616,660 Scrap and dross 195,270 213,770 445,990 Subtotal 932,360 2,608,800 6,140,470 MiscsllsnGous' Recycled plastic credit -107,120 -263,300 -616,790 Transportation 320,190 378,320 983,040 Depreciation 4 -5,850 -192,620 -520,310 Subtotal 207,220 -77,600 -154,060 Net operating cost 5 3,196,570 7,677,620 15,842,060 COST PER POUND REFINED LEAD Materials and utilities 0.049 0.037 0.043 Maintenance materials 014 .01 1 .01 1 Labor 049 .042 .037 Indirect costs 014 .022 .018 Scrap lead supply .057 .057 .068 Miscellaneous .013 -.002 -.002 Total 196 .168 .176 1 Average 1985 production is 7,384 mt refined lead. 2 Average 1985 production is 20,751 mt refined lead. 3 Average 1985 production is 40,869 mt refined lead. 4 Depreciation is a percentage of 1985 identified capital expenditures and estimates of past capital expenditures based on the ACRS. 5 Data may not add to total shown because of independent rounding. operating near capacity, then the economy of scale would be consistent through the size ranges. In 1985, the larger smelters' average production was approximately 64 pet of capacity, whereas the medium size smelters were utilizing 91 pet of capacity. Economy of scale is consistent for production and maintenance labor throughout the size ranges because the labor force can be scheduled according to production requirements. Regula- tory compliance costs indicate a reverse economy of scale for the smaller smelters for several reasons: they are generally compact and require less capital for enclosure and retrofit, they are more capable of varying furnace operations for particulates emissions compliance, and they have been generally less regulated than the larger smelter complexes. The amount of depreciation varies from smelter to smelter. In general, most of the small smelters and many of the medium size smelters were built in the 1940's and 1950's and are essentially depreciated, although many have rebuilt or replaced furnaces. Depreciable costs for these smelters are' primarily attributable to capital expenditures for environmental compliance. Several of the medium and larger smelters are newer and, therefore, have a larger depreciation value for capital costs, but a smaller amount of depreciable environmental compliance costs. This is primarily because of better control technolo- gy incorporated within these newer smelters. In an attempt to account for after-tax economics, individual smelters were evaluated for recent capital expenditures for regulatory compliance and original capital cost recapture. Capital costs for regulatory compliance were depreciated based on the Accelerated Cost Recovery System (ACRS). This schedule, based on 1985 tax laws, is anticipated to be the most advantageous tax schedule, which may come close to actual company accounting practices. As a common basis of depreciation, the second year rate of 22 pet was used for identified capital expenditures. Smelter capital costs are depreciated over a 30-yr period or 3.33 pet per year. These depreciable items are included in the operating costs for comparison purposes. There are several cost items that are relatively inflexible to scale. The most significant conversion cost items are electricity, natural gas, coke, and antimony. These supplies are basic to the conversion of scrap lead into refined lead and lead alloys. Battery supply is a significant cost item and is probably the single most important item for determining refined lead profitability. In general, smelting practices have probably reached optimum efficiency, thereby reducing conversion costs to a minimum; therefore, the margin between conversion costs plus lead supply costs and the sale price of refined lead determines profitability. In 1985, the "ask" price for soft lead was 19.0 to 19.5 eTlb. The "bid" price was probably closer to 18.5 0/lb. The 1985 average contract price for soft lead was approximate- ly 19.2 e71b (8). If the secondaries all produced soft lead as their only product, then the net profitabilities would be very low, and some smelters would have a negative cash flow. However, this is not the case because the secondary lead smelters products incorporate a "value-added," which commands a higher price. Value-added represents the additional value to a product for further refinement, metal alloying, or casting. The smelter operating costs presented in table 4 exclude the processing costs for value-added, and do not reflect the actual sale price or value of the products. The value of products sold has not been included because of the variability of products produced from each smelter, the degree of integration for each, and individual company contract prices. For example, the smaller smelters generally produce products according to customer orders or internal de- mands. Customer orders may vary from special alloys to sailing vessel keels. The value-added is incorporated in the form of additional refining and metal content to fabrication of keels. Therefore, the sale of these products will include a profit margin for additional metal content or 10 fabrication. The bottom line would show a profit on production, but not per pound of refined lead. Degree of integration has essentially the same effect. A plant that converts scrap lead into marketable batteries has passed the profit along to the final product. The profit is, therefore, in terms of profit per battery and not profit or loss per pound of lead produced. FACTORS AFFECTING OPERATING COSTS Within the secondary lead industry, each smelter has some relative operating advantages and disadvantages. Size and age of the smelter are important factors because economies of scale do exist and some fully depreciated smelters are more economical, on an after tax basis, than partially depreciated smelters. Degree of integration and product diversity also have distinct advantages. Most of the smaller smelters cater to orders for small lots of various products and are able to include an added value to these products. The smaller smelters also show a greater degree of integration, some through battery marketing. This allows for the largest amount of added value to the product. Smelter location is probably the most important factor affecting direct operating costs. Regional variations in prices for electricity, natural gas, scrap lead, coke, and labor significantly affect operating costs. Proximity to suppliers and consumers affects transportation costs. Truck transportation rates vary from 9.2 e7mt-km for local hauls up to 100 km, to 3.1 0/mt-km for long hauls. An increasingly significant cost factor is environmental cost. State and local regulations are quite variable. States such as California and Oregon are very strict and compliance is very costly, whereas most southern States are less strict. Local governments can even shut down smelters if actions are contrary to city planning and administration policies. Waste disposal is also becoming a very significant expense and is often a difficult task to perform. For example, smelters are required to test slag to see if it is classified as "hazardous." If tests indicate the material is hazardous, then special hazardous waste dumps must be used. There are very few dumps that can accept hazardous waste and, in some cases, they may be hundreds of kilometers from the smelters. California charges $29.76/mt of hazardous waste as an additional tax. The total cost for testing, hauling, and dumping these wastes can be as high as $105/mt. ENVIRONMENTAL LEGISLATION AND COMPLIANCE COSTS Over the past two decades, the EPA nas been charged by Congress to enforce numerous laws intended to protect the environment, to reduce the amount of pollutants introduced into the environment, and to clean up the environment. All of these laws have impacted the secondary lead industry to varying extent. The Clean Air Act (CAA) and National Ambient Air Quality Standard (NAAQS) have resulted in lower lead emissions released into the atmosphere and lower exposure levels of lead for the industry labor force. The CWA and Solid Waste Disposal Act (SWDA) have insured monitoring of ground water for possible contamination around lead processing facilities and proper handling and disposal of hazardous wastes. The Resource Conservation and Recovery Act (RCRA), SWDA, and Hazardous and Solid Waste Amend- ments Act have helped to insure public health and decrease environmental degradation by setting disposal and monitoring standards for solid and hazardous wastes. The Comprehensive Environmental Response, Compensa- tion, and Liability Act "Superfund" levies a tax of $4.56/mt of lead oxide produced to generate funds to clean up polluted waste disposal sites. In addition, several Superfund reauthorization bills introduced in Congress propose a tax on all lead but, at the time of this report, the legislation has not been passed. The NAAQS is also being reviewed for possible reduction to 1.0 or 0.5 p-g/m 3 of lead in ambient air at fenceline. The most important Federal regulations affecting the secondary lead industry are: 1. The EPA's CWA of 1977, as amended. This governs effluent limits based on type of smelter production or consumption of metal and the BAT, and became effective July 1, 1984. For current operations already indirectly discharging through publicly owned water treatment facilities, BAT pretreatment standards must be complied with by March 1987. 2. The Occupational Safety and Health Administra- tion's (OSHA) inplant maximum permissible exposure limit (PEL) standard of 50 jxg/m 3 of lead in air. Final compliance plans must have been filed by August 1, 1984, with full implementation of the plans completed by June 29, 1986. An interim standard PEL of 100 \x.g was allowed during the interval between these two dates. Variable combinations of engineering controls, administrative controls, and worker self-protection were allowed during the interim period and in the final compliance plan, but plans were negotiated on a plant-by-plant basis with OSHA and, where applicable, with the union. This negotiation process, known as Cooperative Assessment Program (CAP), has been made available to all lead processors. The program allows for greater flexibility by mutually agreed plans for compliance. 3. Public Law (PL) 98-616, the Hazardous and Solid Waste Amendments Act, enacted November 8, 1984, amending the SWDA of 1965 and its amendments, the RCRA of 1976, and the SWDA amendments of 1980. This law classifies as hazardous waste all effluents that have lead or lead compound concentrations of 500 ppm or greater with a pH of less than or equal to 2.0. 4. The OSHA's 1979 blood-lead standard. The final phase of that regulation became effective on March 1, 1983, with full implementation of the maximum allowable blood concentration of 50 |xg of lead per 100 g of blood. At or above that level, an employee must be immediately removed to a nonexposure job site or furloughed with pay until the blood-lead level has been reduced to no more than 40 |xg per 100 g of blood. 5. The CAA of 1963, (PL 88-206), with its amendments of 1970 (PL 91-604) and 1977 (PL 95-294), and the EPA established NAAQS of 1978. This standard is to be fully implemented by January 1, 1988. During the interim, the existing operations can operate under temporary, renew- able variances, which are allowing for phased imple- mentation of the statutes. Although interim compliance can be met by periodic curtailment of production, final compliance cannot. 11 COSTS OF COMPLIANCE The capital and operating costs for environmental regulatory compliance are extremely variable from smelter to smelter. Variables such as smelter capacity, state regulations, plant technology, type of products, age, and degree of integration all affect the costs. In general, an industry average for present regulatory compliance costs is 2.3 cTlb of refined lead (table 5). Included in this cost are four general categories comprising employee health and safety, equipment operation and maintenance, supplementary labor, and hazardous materials handling and disposal. There appears to be a diseconomy of scale for the large smelters, but this is not the case. These costs are based on actual production at the time of the study. If the costs were based on rated smelter capacity, then the economy of scale would be consistent. TABLE 5.— Current regulatory compliance operating costs, average 1985 dollars Smelter Operating costs, capacity, mt/yr c/lb refined lead 5,000 to 15,000 23 15,000 to 40,000 2.2 40,000 to 85,000 2.4 Employee health and safety includes costs for clothes, shoes, respirators, safety glasses, hard hats, shower time, laundry, blood-lead monitoring, administration, and medical removal for high blood-lead levels. Equipment operation and maintenance includes costs associated with running and maintaining equipment installed specifically to meet environmental regulations. Equipment items include baghouses, negative pressure atmosphere sys- tems, floor scrubber machines, supplementary work- station ventilation, flue mufflers, scrubbers, and miscel- laneous equipment. Supplementary labor costs consist of people required to operate and maintain pollution control equipment as well as administrative requirements. Hazardous materials handling and disposal costs include acid neutralization, precipitation and transportation, water treatment, slag analysis and transportation, per- mits, and other disposal costs. Also included in this category are well and air monitoring and water effluent monitoring. Additional capital and operating costs for compliance with pending and proposed regulations are presented in table 6. The operating cost items represent only the costs associated with operations and maintenance. They do not include costs for interest on borrowed capital, deprecia- tion, taxes, and insurance. The actual costs to the companies would, in all likelihood, be higher than the presented values. The costs are based on actual costs for installed systems or for smelters that have already engineered systems and have obtained cost estimates from contractors for installing the systems. The costs, there- fore, represent actual site-specific industry costs for the various systems. Scaling these costs to a specific size smelter complex is not recommended because of the variability in size, design, and technology employed at each site. All of these costs do not necessarily apply to each smelter, because each smelter is in various stages of environmental compliance. The bureau's estimate for the average pending regulatory compliance operating cost is 3.5 eYlb of refined lead. This estimate is based on the present NAAQS standard of 1.5 |xg/m 3 ambient lead plus an estimated average for additional standards. If the standard is TABLE 6. — Pending and proposed regulatory compliance cost estimates for secondary lead smelters' Regulation Cost items or standards Operating cost, Capital Smelter capa- e/lb refined lead cost, ICPS city, 2 10 3 mt/yr CERCLA' 31 Liability insurance w NAp NAp Estimated proposed tax on lead . ^l NAp NAp CWA . 80 ppm Pb in water 0.19-0.75 $175-760 13-41 MRP 161 .. Removal from lead exposure at 50 M-g per 1 00 g blood and return at 40n.g per 100 g blood (?) NAp NAp PEL' 81 (PEL): 50 M-g/m 3 Current: 1.5 M-g/m 3 Pb 0.64 1,085 18 NAAQS .. 1.20 9 5,750 36 Proposed: 1 .0 p.g/m 3 Pb 0.72 1,500 12.5 Proposed: 0.5 ng/m 3 Pb 1.13 3,050 12.5 Annual mean of 80 ng/m 3 SO? and 24-h mean of 365 ng/m* . 0.21 500-1 ,000 22.5-66 RCRA Hazardous waste handling, transportation, and disposal ,0 0.34-1.6' 113-1,000 4.5-87 NAp Not applicable. ' All costs are not necesssarily applicable to every smelter because each may already be in compliance with one or several of the regulations. 2 Used as basis for estimating costs. 3 Comprehensive Environmental Response, Compensation, and Liability Act (Superfund). ' Undetermined cost. Industry sources indicate that this type of insurance is not available and if it were made available, they could not afford the insurance premiums. 5 Based on current tax rate for lead oxide. 6 Medical Removal Program. 7 Not determined because of too many variables, such as individual's ability to metabolize lead. Can be a significant cost item at some smelters. 9 MRP and PEL are regulations promulgated by OSHA. 9 Cost based on information developed from TRC report (11). Proposed standards are cumulative to the current standard. 10 Costs based on smelter capacities from 6,500 mt/yr to 87,000 mt/yr. " Costs are extremely variable because of different requirements under the State Implementation Plans (SIP). Costs based on smelter capacities from 4,500 to 60,000 mt/yr. amended to 1.0 (xg/m 3 ambient lead, then the average industry compliance cost is estimated to be an additional 0.5 c71b of refined lead. If the NAAQS standard is amended to 0.5 |xg/m 3 ambient lead, then the average industry compliance cost is estimated to be an additional 1.3 cYlb of refined lead. These cost estimates are considered to have an accuracy of ±25 pet (fig. 7). KEY Proposed Pending Present Direct operating costs Environmental compliance costs 1985 a v price per pound refined lead 5-15 15-40 40-85 SMELTER CAPACITY, 10 3 mt/yr refined lead Figure 7.— Operating cost estimates for present, pending, and proposed environmental regulatory compliance. 12 The capital costs necessary to comply with these environmental regulations are presented in figure 8. The costs are grouped by smelter size and include estimates at the proposed NAAQS levels of 1.0 |xg/m 3 and 0.5 |xg/m\ because meeting this standard is the most significant cost item. Although the costs account for all of the environ- mental regulations, the total cost is not necessarily applicable to every smelter because of individual degree of environmental compliance. The capital cost estimates are considered to have a ±25 pet accuracy. 16 15 ~ 14 u> 13 oo S> 12 (O o Q. < O 11 10 9 8 7 6 5 4 3 2 1 KEY Proposed costs Pending costs 5-15 15-40 40-85 SMELTER CAPACITY, 10 3 mt/yr refined lead Figure 8. — Capital cost estimates for pending and proposed environmental regulatory compliance. COMPLIANCE CAPABILITY The ability of the secondary lead industry to comply with the environmental regulations and remain profitable is questionable. On a direct cost per pound of lead basis, the industry would be losing money. The vertically integrated smelters, especially those that make high value-added specialty products, may be able to absorb the additional compliance costs, but profit margins will be severely reduced. •In addition, if current economic conditions continue and proposed environmental regulations become effective, many smelters will be forced to shut down. This will occur because some companies cannot afford the capital costs for compliance and also because many smelters' "book values" would be less than the capital expenditures. Companies would therefore consider alternative investments rather than risk capital expenditures into a business that offered a poor rate of return. Loss of production capacity is speculative, but could be as high as 350,000 mt/yr. This represents approximately 40 pet of the current industry production capacity. In general, the ability of the industry to survive is a function of size, degree of integration, efficiency, and ability to market products with value- added. The cost of regulatory compliance and the resultant effects on the industry could create this particular long-term chain of events: The smelter closures will lower demand for battery scrap, which will create an oversupply of scrap. With low demand and large supply, the price for scrap will decrease. This will dampen the incentive to recycle because of reduced profit margins. In some areas of the country, the price for scrap is already approaching the break-even cost for recycling. Continued downward price pressure will begin breaking down the recycling industry, especially the independents, which account for approx- imately 50 pet of the industry. The net effect is a loss of battery scrap supply because of a lack of recycling. The effect of a breakdown of the recycling industry will probably result in a serious environmental problem (12). Batteries will probably be dumped in inadequate land fills, along back roads, and in ditches. Because of the hazardous nature of batteries, the effect on the environ- ment would be the introduction of lead and sulfuric acid into the soil and possibly the water table, and the introduction of rubber and plastic into the soil. The primary lead industry should also be considered, assuming that the environmental regulations apply equally to the primaries. The primaries will be faced with significantly higher compliance costs (13), which may result in loss of production capacity through plant closures. If this occurs, production from the secondary lead industry may increase although fewer secondary smelters will be operating. CONCLUSIONS The continued depressed price of lead and the additional costs for environmental regulatory compliance have severely impacted the secondary lead industry. Since 1980, plant closures have accounted for approximately 200,000 mt of lost production capacity and 200,000 mt of temporary shutdown capacity. Current potential domestic capacity is 900,000 mt/yr of refined lead. More plant closures can be expected if stricter environmental regula- tions become effective. Resultant loss of capacity could be as high as 350,000 mt/yr or 40 pet of remaining domestic production capacity. Based on 1985 operating parameters and average 1985 dollars, the average operating costs varied from 16.8 to 19.6 c/lb of refined lead. The 1985 average sale price per pound of refined lead was approximately 19.2 c71b. Industry profitability for 1985 was very low and for many companies, it was close to break-even. Profit was mostly achieved by vertically integrated companies capable of producing value-added products. Present regulatory compliance costs, as an industry average, are 2.3 c71b of refined lead. Pending environmen- tal regulations could cost the industry an additional 3.5 <2/lb of refined lead. It is estimated that proposed environmental regulations, assuming the NAAQS of 0.5 (xg/m 3 , would cost an additional 1.3 eYlb of refined lead. This cost is in addition to the cost for pending regulatory compliance. These costs do not include discounted cash flow rate of return (DCFROR) analysis. 13 Capital costs necessary to comply with environmental regulations are estimated to be approximately $1.8 million for smelters with capacities between 5,000 and 15,000 mt/yr, $7.6 million for smelters between 15,000 and 40,000 mt/yr, and $10.4 million for smelters between 40,000 and 85,000 mt/yr. Proposed regulations could add an additional $1.9 million for smelters with capacities between 5,000 to 15,000 mt/yr, $3.6 million for smelters between 15,000 to 40,000 mt/yr, and $4.9 million for smelters between 40,000 and 85,000 mt/yr. These cost estimates indicate that pending and proposed environmental legislation could add significant- ly to capital and operating costs of the secondary lead industry, thereby reducing its capacity to recycle lead as marginal plants shut down. Ramifications could impact the recycling industry. The net result could be less scrap lead recycling, which could result in hazardous wastes, primarily batteries, being introduced into the environ- ment. If this legislation significantly affects the primary lead industry, the result may be a loss of both primary and secondary production capacity, however, the remaining smelters' actual production would increase. REFERENCES 1. Charles River Associates Inc. (Cambridge, MA). Economic Impact of the Proposed EPA National Ambient Air Quality Standard for Lead: Background Support Document. Mar. 1978, 127 pp. 2. Economic and Environmental Analysis of the Current OSHA Lead Standard. CRA Project 536.60, 1982, 153 pp. 3. CRU Consultants, Inc. (New York). The Costs of Producing Primary and Secondary Lead. Implications for Prices, Competi- tiveness, Environmental Standards, and New Technology. Com- modities Res. Unit LTD, New York, 1984, 340 pp. 4. Putnam, Hayes and Bartlett, Inc. The Impacts of Lead Industry Economics on Battery Recycling. Prepared for Office of Policy Analysis, EPA. June 13, 1986, 32 pp. 5. Woodbury, W. D. Lead. Ch. in BuMines Minerals Yearbook 1984, v. 1, pp. 563-594. 6. U.S. Bureau of Mines. Minerals Yearbooks 1970, 1975, 1980-1985. Chapter on Lead. 7. American Metal Market. Export Mart Still Strong. V. 94, No. 49, Mar. 12. 1986, p. 13A. 8. Zelms, J. L. Lead: Hope For Modest Recovery. Eng. and Min. J., v. 187, No. 3, 1986, pp. 32-34. 9. Murph, D. B., and J. L. Pinkston. Current Blast Furnace Practice at Murph Metals' Southern Lead Company Smelter. Metall. Soc. AIME paper A70-41, 1970, 13 pp. 10. Hudson, E. K. (Lake Eng. and Dev., Inc., Atlanta, GA). Personal correspondence, 1986; available upon request from M. R. Daley, BuMines, Denver, CO. 11. Hoffnagle, G. F., and W. A. Klinger. Exposure to Airborne Lead From Stationary Sources: An Evaluation of Proposed National Ambient Air Quality Standards for Lead. (Lead Ind. Assoc, project 3220-J51, TRC Environ. Consultants, Inc., East Hartford, CT,). Mar. 1986, 48 pp. 12. Palmer, J. G., and M. L. Sappington. An Impending Crisis? What Would be the Impact on the Nation's Environment if 70 Million Spent Lead Acid Batteries Each Year Were Not Recycled? April 1986, 24 pp.; available from J. G. Palmer, GNB Incorporated, St. Paul, MN, or M. L. Sappington, Lake Engineering and Development, Inc., Atlanta, GA. 13. Smith, R. D., O. A. Kiehn, D. R. Wilburn, and R. C. Bowyer. Lead Reduction in Ambient Air: Technical Feasibility and Cost Analysis at Domestic Primary Lead Smelters and Refineries. BuMines OFR 67-86, 1986, 52 pp.; NTIS PB 86-216447. BIBLIOGRAPHY Anderson, C. W., P. Behum, and F. Miller. Environmental and Occupational Health Regulations in the U.S. Lead Industry. BuMines OFR 3-86, 1986, 76 pp.; NTIS PB 86-155686. Everest Consulting Associates, Inc. (Princeton Jet., NJ), and CRU Consultants, Inc. (New York). The International Competi- tiveness of the U.S. Non-Ferrous Smelting Industry and the Clean Air Act. Ch. 4, 6, Apr. 1982. Gill, C. B. Nonferrous Extractive Metallurgy. Wiley, 1980, 346 pp. Kilgore, C. C, S. J. Arbelbide, and A. A. Soja. Lead and Zinc Availability — Domestic. A Minerals Availability Program Appraisal. BuMines IC 8962, 1983, 30 pp. Kohn, A. F., Jr. The Recovery of Soft and Antimonial Lead From Secondary Sources. Pres. at 1963 AIME Annu. Meet., Dallas, TX, Feb. 24-28, 1963, Metall. Soc. AIME preprint #47-M, 1963, 12 pp. Peterson, G. R., K. E. Porter and A. A. Soja. Primary Lead and Zinc Availability — Market Economy Countries. A Minerals Availability Program Appraisal. BuMines IC 9026, 1985, 44 pp. Raymond Kaiser Engineers. Capital and Operating Cost Esti- mating System Handbook for Lead Smelting and Refining Facilities (contract JO245003). BuMines OFR 81-86, 1986, 282 pp.; NTIS PB 86-246592. Sealey, C.J. Secondary Lead Smelter and Refinery. Tolltreck Limited, Droitwich, Worcestershire, England, Feb. 10, 1981, 15 pp. Tolltreck International Limited (Englewood, CO). General information brochures, 1985, 70 pp. 14 APPENDIX A.— EXAMPLE OF CAPITAL AND OPERATING COST ESTIMATES FOR ENVIRONMENTAL REGULATORY COMPLIANCE An example of costing methodology has been included for a fictitious smelter with a 40,000 mt/yr refined lead capacity. It is assumed that this smelter approximates the industry's average level of compliance (fig. A-l). There- fore, the costs presented for each regulation reflect the additional costs necessary for compliance. Costs associ- 9. Smelter is partially enclosed 10. Existing process emissions control includes one baghouse: 11. Small oxide plant 120,000 ftVrnin capacity Materials supply and maintenance Administration Change room Lunch room Security Battery » | — | r breaker L XJt f t t Raw material storage area- Blast furnace charge bin Blast lurnace Reverberatory furnace Control room Fan room Exhaust stack- Process dust collectors -Afterbum and cooling towers Finished lead storage -j I Refining kettlea > ooo _j I Casting line area Oxide plan t Figure A-1. — Original smelter facilities. ated with these regulations should be interpreted with caution and with a complete understanding of the level of compliance for the example smelter. The components comprising the costs for each regulation are presented in this appendix. Contingencies for each regulation vary according to degree of confidence. These costs do not necessarily equal or approximate the costs presented in table 6 of the main text. The costs for each smelter are extremely variable because of smelter layout, existing technology incorporated at the smelter, and degree of environmental compliance. Smelter statistics are pre- sented below in order to better understand cost estimates for this example: 1. Production capacity: 2. Primary feed material: 3. Operating parameters: 4. Average hourly wage: 5. Payroll overhead: 6. Limestone: 7. Electricity: 8. Current acid neutralization process is not BAT 40,000 mt/yr refined lead 85 pet batteries 3 spd, 290 d/yr $9.30/h 35 pet $30/mt delivered $0.05/kW-h CWA The costs associated with the CWA are based on the use of lime and settle technology. This technology incorporates acid neutralization, heavy metal precipita- tion and sedimentation, and multiple stage pH control. All battery acid, process water, and water introduced onto the property requires treatment by lime and settle technolo- gy. For this example, it was assumed that lime and settle technology was not being used. The capital costs therefore include an acid neutralization and water treatment plant with a 3-stage settling pond system (fig. A-2). The cost items are presented in table A-l. Settling ponds- Acid neutralization and water r^vtreatment •a Materials supply and maintenance Administration Change room Lunch room Security Battery » | 1 . breaker L XJt t f Raw material storage Blast lurnace charge bin LZJ Blast furnace Reverberatory furnace — t J area— 1 D Control room Fan room Exhaust stack - Process dust collectors - Afterbum and cooling towers Finished lead storage m A I Refining kettlea — > OOO lo I Casting line area I Oxide plan t Figure A-2.— Additional smelter facilities for CWA. The operating costs associated with the CWA include utilities, supplies, labor, payroll overhead, and general office charges. Lime is the primary supply used for neutralization, but coagulants and flocculants may also be added to enhance settling properties. Coagulants and flocculants were not added to this cost model because the parameters requiring these reagents are not identified for this example. Much of the labor associated with operating this treatment plant is not required on a full-time basis. It 15 TABLE A-1. — CWA capital cost estimate Cost item Unit cost plus installation, $ Number Total cost, 1 $ Acid sump pump 1 5,000 Acid transfer pump 8,000 Lime storage bin 6,000 Lime hopper & transfer system 11 0,000 Neutralization tanks 1 2,000 Clarifier 46,000 Thickener 24,000 pH control tanks 4,500 PH monitor system 14,000 ilter system 135,000 Grounds sump pumps 9,000 Grounds piping and electrical 2 1 8.00 Pond recycle sump pumps 11 ,000 Residue ponds 60,000 Recycle pond 60,000 Subtotal Contingency @ 15 pet Total installed cost 3 890 3 2 1 15,000 8,000 6,000 110,000 24,000 46,000 24,000 9,000 14,000 135,000 27,000 16,000 33,000 120,000 60,000 647,000 97,000 744,000 1 Values rounded to the nearest $100. 2 Per foot. has therefore been partitioned as a percentage of time required by labor category and average wage or salary category. Administration is considered to be one full-time "environmental specialist" to deal with all regulations affecting this smelter. The salary has been equally partitioned to each regulation. General office charges for all regulations are considered to include phones, utilities, office supplies, vehicles, public relations, and miscel- laneous expenses. These costs are presented in table A-2. ~n 1 - Settling ponds Acid neutralization and water O treatment AD O 5 Materiala aupply and maintenance Administration Change room Lunch room Security TABLE A-2. — CWA annual operating cost estimate, dollars Cost item Total cost 1 Utilities and supplies: Lime 100,800 Electricity (200 hp @ 5c/kWh) 13,800 Repair parts e 6,600 Labor: General labor (2.5 people @ 2 $1 5,000) 37,500 Maintenance labor (0.5 person @ 2 $1 8,000) 9,000 Supervision (0.3 person @ 2 $24,000) 7,200 Laboratory-labor (0.3 person <& 2 $14,000/yr/person) . . . 4,200 Laboratory-skilled (2 people @ .3 @ 2 $24,000) 14,400 Administration (0.25 person @ 2 $34,000) 8,500 Payroll overhead (35 pet of all listed personnel) 28,300 General office charges "2,000 Subtotal 232,300 Contingency (10 pet) 23,200 Total annual cost 255,500 NOTE. — Cost per pound refined lead based on a production rate of 40,000 mt/yr refined lead: 0.29 Control room Blast furnec charge bin / LG erlal storage area ~7~ Blast lurnace V- Finished | lead storage I Fan room L> Exhaust stack - Process dust collectors ReverberatoryC furnace C Refining kettles — -Afterburn and cooling towers i Caating line area q Oxide plan t o _L Oxide atorage Figure A-4.— Additional downcast ventilation and ductwork for PEL. 16 TABLE A-3.— OSHA's PEL capital cost estimate 1 , dollars ^t item £g_ Boor sweepers (2 @ $27,000 each) 54,000 Ventilation dust collector (450 hp fan; 460 V, 495 A, 100,000 f^/min) 307,000 Ductwork (14 ga, gasket and flange connection, 1 ,020 lineal ft @ $300/lineal ft) 306,000 Downcast ventilation (fan, 6 workstations, 480 lineal ft @ $70/lineal ft) 33,600 Subtotal 700,600 Contingency (15 pet) 105,100 Total capital cost 805,700 1 Smelter assumed to be in partial compliance with PEL. Therefore, costs do not represent the total cost for compliance. 2 Values rounded to the nearest $100. Total cost includes purchase, freight, and installation where applicable. The operating costs associated with PEL are pre- sented in table A-4. Safety equipment items include hard hats, respirators, earplugs, gloves, and uniforms. Laundry service includes daily washing of uniforms. The other cost items are described in the table. TABLE A-4. — OSHA's annual operating cost estimate 1 rv«»item Annual cost Number Total v ' OSITOm per employee, $ of people cost 2 , $ Safety equipment 240 78 18,700 Laundry service 210 78 16,400 Medical examinations 240 92 22,100 Personal hygiene 3 440 78 34,300 Floor sweeping NAp 4 1 .3 32,800 Maintenance NAp *2A 105,000 Utilities 6 NAp NAp 62,000 Baghouse liners 7 NAp NAp 19,300 Administration 45,900 0.25 1 1 ,500 General office (estimated) . . 1,500 Subtotal 323,600 Contingency (10 pet) 32,400 Total cost "356,000 NAp Not applicable. 1 Costs based on a 92-employee labor force. 2 Values rounded to the nearest $100. 3 Costs include overtime pay for shower time @ 7.5 min/d @ an average wage of $9.30/h @ time and one-half pay. 4 Costs include 3 h/shift, 3 spd, 290 d/yr @ $9.30/h plus payroll overhead @ 35 pet. 5 Costs include labor, maintenance supplies, administrative, and indirect costs. 8 Cost for electricity based on 178.2 kWh draw @ 24 h/d, 290 d/yr, and 5c/kWh. 7 Replacement of baghouse liners is $38,600. The liners are replaced every other year so one-half of the cost ($19,300) is charged on an annual basis. 8 Cost per pound refined lead based on a production rate of 40,000 mt/yr refined lead: 0.40e/lb. 1 r- Settling ponds I I Administration Acid neutralization and water Change room Lunch room •—■■.treatment 0/\D O I Materials supply and maintenance Security Battery _ breaker " -igr Exhaust stack- Process dust collectors Afterburn and cooling towers Oxide pian t Oxide storage Figure A-5. — Original smelter process emissions control equipment, ductwork, and building enclosure. 1 1 Settling ponda 1 1 Administration Acid neutralization and water Change room Lunch room ^-Ntreatment 0/\D o § Materials aupply and maintenance Security Battery _ breaker ~ Jczir^ NAAQS In estimating the costs associated with the NAAQS, it is assumed that the smelter can achieve the 1.5 n,g/m 3 Pb standard, the annual mean of 80 (ig/m 3 S0 2 , and the 24-h mean of 365 u-g/m 3 S0 2 . The proposed process controls are considered BAT, but in reality, it is not known whether these process controls can meet the standards. The capital costs include smelter enclosure, installa- tion of an additional baghouse, ductwork, air monitoring systems for lead and S0 2 , installation of an S0 2 gas scrubber, enclosure and surfacing of the entire yard area including sump stations for water runoff collection, a wheel washing station at the primary materials handling access, and an agglomerating system at the process dust collectors. Figures A-5 to A-7 show the smelter layout with the specific costing items highlighted. The most important items assumed to be already installed for this example smelter are the partial plant enclosure and the ^Additional building enclosure Scale, ft Figure A-6— Additional building enclosures for NAAQS. 17 J 1 - Settling ponds _J L_ Acid neutralization and water Otreatmant /\D o o O Materials aupply and maintenance Administration Chang* room Lunch room Security Load material atorag* Figure A-7 — Additional process merit and ductwork for NAAQS. emissions control equip- process emissions controls at the blast furnace, reverbera- tory furnace, refining kettles, and oxide kettles (fig. A-5). Also, this smelter has an afterburner and cooling towers, which are probably not standard level of compliance items for the lead industry. The capital costs are presented in table A-5. The operating costs associated with the NAAQS are presented in table A-6 and are based on the operation and maintenance of the previously mentioned process controls. TABLE A-5.— NAAQS capital cost estimate for the current regulation of 1.5u.g/m 31 Cost item Total cost 2 , $ Plant enclosure: Strip doors (5 doors; 1,216 ft 2 @ $1 5.50/ft 2 ) 18,800 Plant enclosure (25,500 ft 2 @ $8.30/ft 2 ) 21 1 ,700 Foundation (350 lineal ft @ $26.00/lineal ft) 9,100 Air monitoring: Lead monitor (photometer system) 51 ,000 S0 2 monitor (fluorescent system) 32,000 S0 2 gas scrubber 53,300 Yard paving (2 in asphalt, 4 in aggregate, 96,000 ft 2 @ $0.82/ft 2 , plus mobilization) 79,800 Curb (6 in by 9 in with 8 in subgrade, 2,1 00 lineal ft @ $7.25/lineal ft) 15,200 Baghouse (100,000 frVmin system; 450 hp fan, 460 V, 495 A) 307,000 Ductwork (14 ga, gasket and flange connection, 520 lineal ft @ $300/lineal ft) 156,000 Electrical system airflow monitor, fan restart system 50,000 Aqglomerator system 34,000 Wheel washing station 16,000 Subtotal 1 ,033,900 Contingency (1 5 pet) 155,100 Total cost 1,189,000 1 Smelter assumed to be in partial compliance with NAAQS. Therefore, costs do not represent the total cost for compliance. 2 Values rounded to the nearest $1 00. Total cost includes purchase, ^ freight, and installation where applicable. 2o O c? TABLE A-6. — NAAQS annual operating cost estimate for the current regulation of 1.5u.g/m 3 Cost item Total cost 1 , $ Materials and utilities: Electricity 86,800 General supplies (10 pet of electricity) 8,700 Maintenance materials (60 pet of labor and supervision) . . . 54,800 Baghouse liners 38,500 Labor: General labor (2 people @ 2 $15,000) 30,000 Maintenance labor (1 .5 people @ 2 $1 8,000) 27,000 Supervision (.4 person @ 2 $14,000) 9,600 Laboratory-labor (.4 person @ 2 $14,000) 5,600 Laboratory-skilled (2 people @ .4"@ 2 $24,000) 19,200 Administration (.25 person @ 2 $34,000) 8,500 Payroll overhead (35 pet of above personnel) 35,000 General office (estimated) 3,500 Subtotal 327,200 Contingency (20 pet) 65,400 Total cost 392,600 Cost per lb refined lead based on a production rate of 40,000 mt/yr refined lead: 0,45c/lb. 1 Values rounded to the nearest $100. 2 Annual cost per person. RCRA Capital costs associated with RCRA include the "part B" permit, the ground water monitoring system, and the material testing laboratory and equipment. For this example, the well monitoring system includes eight wells (each 80-ft deep), well casing, pumps, pipe, electrical hardware, caps, and well-site paving. Material testing equipment includes an atomic-absorption spectrophoto- meter, multiple and single element tubes, and miscel- laneous equipment for wet- and dry-test methods. The part B permit costs between $30,000 and $50,000 and generally varies because of smelter size. For this example, the cost is assumed to be $42,000. Also included is the battery breaker enclosure. The ventilation and ductwork has been charged to the PEL regulation (fig. A-8). The capital costs for RCRA are presented in table A-7. Settling ponds _! L_ Acid neutralization and water streatment Administration Chang* room Lunch room Security Figure A-8.— Additional building enclosures for RCRA. 18 TABLE A-7— RCRA capital cost estimate Cost item Total cost 1 , $ Well monitoring: Drilling (1 wells, 80 ft deep, $1 2/ft to drill and case) 9,600 Pumps (10 @ $400 each) 4,000 Pipe and electrical (10 sites @ $450/site) 1,500 Overhead electrical (10 sites @ $450/site) 4,500 Cap and pave (10 sites @ $250/site) 2,500 Installation (10 wells @ $250/well) 2,500 Contingency (10 sites @ $150/site) 1,500 Drill rig mobilization 600 Subtotal 26,700 Battery breaker enclosure: Foundation (432 ft @ $11/lineal ft) 4,800 Siding and roofing (13,340 ft 2 @ $8.30/1f) 110,700 Strip doors (4 doors; 928 ft 2 @ $15.50/f^) 14,400 Contingency (15 pet of above items) 19,500 Subtotal 149,400 Miscellaneous costs: RCRA part B permit 42,000 Atomic absorption spectrometer 55,000 Support equipment, lab supplies 8,000 General office (estimated) 1,500 Subtotal 106,500 ~ Total capital cost 282,600 1 Values rounded to the nearest $100. Total cost includes purchase, freight, and installation where applicable. The operating costs for RCRA compliance include well monitoring and testing, and material testing. The costs are composed of labor, equipment operation and TABLE A-8.— RCRA annual operating cost estimate Cost item Total cost 1 , $ Well monitoring: General labor (.3 person @ 2 $14,000) 4,200 Laboratory-labor (.3 person @ 2 $1 4,000) 4,200 Laboratory-skilled (2 people @ .3 @ 2 $24,000) 14,400 Supervision (.3 person @ 2 $30,000) 9,000 Payroll overhead (35 pet of above personnel) 1 1 ,100 Materials and utilities (1 pet of labor & supervision) 3,200 General office "2,000 Subtotal 48,100 Waste disposal: Contract haulage 173,000 Disposal fees 108,500 RCRA administration (.25 person @ 2 $34,000) 8,500 Payroll overhead (35 pet of administration) 3,000 Subtotal 293,000 Contingency 3 (15 pet) 51 ,200 Total cost 392,300 Cost per lb refined lead based on a production rate of 40,000 mt/yr refined lead: 0.44 e/lb. 1 Values rounded to the nearest $100. 2 Annual cost per person. 3 For well monitoring and waste disposal. 8 Estimated. maintenance, laboratory supplies, and supervision (table A-8). Waste disposal is based on a 100-mile one-way haul distance by contract carrier. The dump site is considered to be a class II or better hazardous waste disposal site. ♦U.S. GOVERNMENT PRINTING OFFICE: 1987-190-U1U Region 3. ■V iV-^, ^ ^ * o. V *^ s * A o ^'.C^,\. c°*.«^V*°o 4**^/** / - ^t. 6^ ° o V J ^^- • rf5^v^'. o ^ ^ ^ v v%>"i- ^ y^^&^% * v ^i'i-. %. V c b \/ **o« ■4* vv * «y • +*<* O * ♦ -!^af , y V • -ft - * 'bV v l \^ V '/ \'tt % \f c 1 '^ "MM' A^^ ^0^ ./\ - A V -^ V A* , &- -it -\6* *o --.ft.\ v ^ ^/^/ \.*'ft'\^ % 6 -! ^ , > ', *o NOV.-DEC. 1987 •A ^ fcK o ^ LIBRARY OF CONGRESS 002 951 030 1 HW B ■ra