July 27, 2012

Memorandum 

Subject: Conference call with The Aluminum Association

Date of Meeting: July 25, 2012

Participants:

The Aluminum Association (TAA)

Gary Barnett

Mark Volkmann

Charles Johnson

Mike Palazzolo

J.W. Vinzant

Paul Sohi

Jason Perdion, Baker Law

U.S. Environmental Protection Agency (EPA)

Rochelle Boyd, Office of Air Quality and 

Planning (OAQPS)

Scott Throwe, Office of Enforcement and 

Compliance Assessment

Chuck French, OAQPS

RTI International

Mark Bahner

David Green

Mike Laney

The purpose of the meeting was to discuss the additional data needed by EPA to evaluate TAA 

comments on the February 14, 2012 proposed amendments. See Attachment A for a summary of 

the topics discussed. Key points from the meeting are as follows:

Item #1 – According to TAA, the problem with installing temporary hooding is not due to the 

furnace type: it is a site-specific installation, taking into account, surrounding equipment and 

other physical obstructions, limited access and overhead cranes that may make it impractical to 

install hooding. TAA stated that specific work practices were not provided because they may not 

be suitable in all cases.

Item #2 – The range of $120,000 - $500,000 for the cost of temporary hooding is intended to 

cover the range of site-specific conditions.

Item #3 – TAA stated that recent tests have been conducted by Kaiser and will be submitted.

Item #4 – TAA stated that the revised draft preamble language was confusing. EPA clarified the 

intent of the proposed language.

Item #5 – TAA clarified the testing results submitted in their comments.
Attachment A

Clarifications Needed from The Aluminum Association

Item#1: We met with TAA in December 2011 and EPA was provided a list of 6 different types of furnaces. Industry

stated that all of the types of furnaces cannot have the temporary enclosure installed. I requested industry to list 

the reasons why the temporary enclosures would not work for each type of furnace and to propose alternate work 

and monitoring practices that could be done instead. We did not receive any information before proposal or 

during the comment period regarding this request. We only received information concerning safety issues and 

pictures of only 3 furnace types that may pose an installation problem. We clearly understand the difficulties with 

the round top furnaces but are not sure that the other two furnace types pose the same problems for each of 

these furnace types throughout the industry. We need additional information as previously requested for each 

type of furnace, except for the round top furnace.

Item#2: Before we proposed, industry also stated that our estimate of $57,000 per furnace for installing 

temporary hooding was too low. They gave us a cost estimate of $120,000 to $500,000. They did not follow up 

with any supporting documentation in their comments. We cannot change our numbers based on this comment 

when our numbers are based on an actual installation. Do they have additional data to support their cost 

estimate? For example, are there different estimates for different furnace types (e.g., round top versus 

reverberatory)? Do they have some sort of design description and cost breakdown into materials and labor for 

their estimates? Also, regarding the cost estimates, what are the one-time costs (such as the labor to produce the 

initial design) and what are the costs that are incurred every 5 years (such as the assembly costs)? Who produced 

the cost estimates? Is there an increase in costs due to furnace size, etc.?

Item#3: Does industry have stack test data that support the position that NaCl and KCl fluxes do not produce HCl 

emissions? 

Item#4: We are working on the language with respect to testing “at the highest production rate” and “with the 

scrap containing the highest level of contamination”. It is not our intent to change the concept of the original rule, 

but to clarify the testing requirements and make them more consistent with the April 27, 2009 stack testing 

guidance and previous applicability determinations.  Our suggested language revision for the preamble is: “We 

are clarifying the requirements for conditions under which performance tests for group 1 furnaces must be 

conducted. In general, testing must be conducted under those conditions expected to produce the highest 

expected level of HAP. In addition, performance tests must be performed under those representative (normal) 

conditions that: represent the range of combined process and control measure conditions under which the 

facility expects to operate (regardless of the frequency of the conditions); and are likely to most challenge the 

emissions control measures of the facility with regard to meeting the applicable emission standards, but without 

creating an unsafe condition. If a single test condition is not expected to produce the highest level of emissions 

for all HAPs, testing under two or more sets of conditions (for example high contamination at low throughput, 

and low contamination at high throughput) may be required”.

The revised language for the reg text for sections 1511 and 1514 will be reflective of our intent listed in the 

preamble.

Item#5: Do they have test data that indicate that the levels of HCl, D/F, and PM during the first cycle of clean 

charge are indistinguishable from the levels of HCl, D/F and PM for that furnace that has been handling clean 

charge for many cycles?  The industry provided data that indicated that the first cycle of clean charge met the 

emissions standards for HCl, D/F and PM with the first cycle of clean charge, but that does not necessarily mean all 

HAP-generating materials were “cleared” from the furnace. Supporting data that would substantiate this claim 

would be stack tests data showing that all HAP-generating materials were “cleared” from the furnace. This would 

be evident if the HCl, D/F and PM levels for the first cycle of clean charge were indistinguishable from the same 

furnace after many cycles of clean charge. Please provide supporting data.