### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Name Address City State Zip

Name Address City State Zip

a. Address b. City c. State d. Zip e. County

a. Address b. City c. State d. Zip

a. Name (First Name, Last Name) b. Title c. Telephone number and extension d. Fax number e. E-mail

(Print Name) (Title) (Signature of Responsible Official) (Date)

a. Primary NAICS code b. Other facility NAICS codes

≤50 51–100 101–500 501–750 751–1000 >1000

≤50 51–100 101–500 501–750 751–1000 >1000

Yes No

Subpart RRR (Secondary Aluminum)

Diecasting Operations Foundry Extruder 

### Information Collection Request for Secondary Aluminum Production

11. Federal and State rule/permit coverage. (X all that apply to this facility) f. If the facility is permanently closed or is not subject to 40 CFR part 63, subpart RRR, please complete this page, sign below and send this page certified mail to the non-CBI address listed on the instruction sheet by XXX,

A Responsible Official can be the president, vice president, secretary, or treasurer of the company that owns the facility, owner of the facility, plant manager, plant engineer or supervisor.

8. Company Size (X one cell) Note: Aproximate number of all employees (worldwide) of the business enterprise that owns this facility, including where applicable, the parent company and all subsidiaries, branches, and unrelated establishments owned by the parent company: If your company has a primary NAICS code that does not begin with "331---," please also include your average annual sales receipts $____________________ (How to calculate average annual receipts and average employment of a firm can be found in 13 CFR § 121.104 and 13 CFR §121.106, respectively). 4. Provide mailing address of the facility if different from physical location:



### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP) Part A. Facility Information 1. Name and address of legal OWNER of the facility:

7. Facility NAICS codes Note: The primary NAICS code represents the line of business that generates the most income for the facility. 5. Facility contact able to answer technical questions about the completed survey:

I certify that this facility is permanently closed or is not subject to the National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production as defined in 40 CFR part 63, subpart RRR. 2. Name and address of legal OPERATOR of the facility, if different from the legal OWNER:

3. Complete street address of facility (physical location):

9. Facility Size (X one cell) Note: Approximate number of all employees at facility in location identified in question #3 above.

10. Is the legal owner a small entity as defined by the Regulatory Flexibility Act? (X one cell) Note: For private businesses, small entity is defined for each NAICS of the owning entity based on number of employees and/or company revenue. The NAICS codes used for Secondary Aluminum Production are 331312, 331314, 331315, 331319, 331521, 331524, and various codes used for operations with Sweat Furnaces. The small business size standards for NAICS subsectors are located at the following link: http://www.sba.gov/contractingopportunities/officials/size/ table/index.html. 6. What is the facility size classification for hazardous air pollutant (HAP) emissions? (X one cell)
EPA Area source (Synthetic Minor) of HAP EPA Major Source of Hazardous Air Pollutants (HAP) EPA Area source (based on potential to emit) of HAP



### Page 1 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Subpart LL (Primary Aluminum)

Other (SPECIFY rule name and subpart) Other (SPECIFY rule name and subpart) (SPECIFY rule name and (SPECIFY rule name and (SPECIFY the basis for your Title V permit) (SPECIFY rule name and (SPECIFY rule name and Other MACT(e.g., Metal Coil Surface Coatings MACT): Other MACT: (SPECIFY emission unit and rule)

Hours/day: Shifts/day: Days/week: Weeks/year:

Aluminum Scrap Shredder Thermal Chip Dryer Scrap Dryer/ Delacquering/Decoating Kiln Group 1 Furnace

—Clean charge only** Group 1 Furnace

— Handling other than clean charge** Group 2 Furnace** In-line Fluxer Dross-only Furnace Rotary Dross Cooler Sweat Furnace

Type Device ID No. For purposes of this section, "Maximum Capacity" of a unit is defined as the unit's potential to process charge or produce aluminum at its maximum rate on mass/time basis. If your permit limits the throughput or output of the unit, then that permitted amount may be used to calculate the maximum capacity. State Air Toxics:

12. Normal Facility Production Hours New Source Performance Standards (NSPS):

Title V:

13. Total amount of aluminum produced in 2009. If 2009 is not representative of normal operations, please provide information for a representative year (2004 or later) and specify the year.

14. Amount of total charge to the facility used to produce the amount of aluminum reported in question #13: Tons of charge: Tons of aluminum produced: Year:

16. Please provide a copy of a schematic of the plant layout for equipment subject to subpart RRR, control devices, and discharge stacks associated with these units. Label the schematic with the unit IDs, control device IDs, and stack IDs, which should also match the unit IDs, control device IDs, and stack IDs used to respond to later questions. Please properly identify units that are permanently "out of service" or not yet installed.
17. Please provide all of the pertinent information listed below. Please provide electronic copies, if available, and indicate items provided below. (X all that apply)

Notice(s) of air operating permit violations for the past 3 years Startup, shutdown, and malfunction (SSM) plan Title V permit

19. For Each Scrap Shredder Most recent Consent decree or order for air related issues

* Please complete this column if ID numbers used in this form are different from those in the permit.

Part C. Charge Rates and Controls Used for MajorSources Subpart RRR MACT Please provide the information below for all regulated equipment at your facility; use information for this section from whichever year (2004 or later) is representative of the highest emissions per ton of production (please specify year): Emission inventory reports (reporting years should be the same as the years selected for this survey)

18. Related Equipment List Part B. Facility Equipment Regulated under Subpart RRR (Secondary Aluminum NESHAP) See “Definitions” in Attachment 1 at the end of this survey for explanation of these terms. For the purposes of this survey, scrap wells and wells of similar function as the side well shall be considered a sidewell. Please provide the information below for all equipment at your facility. Operating, maintenance, and monitoring plan (OM&M) State Air Operating permit Pending air permit applications (except for state and Title V renewal applications) Performance test reports (submit most recent test reports for each subpart RRR related process) . This includes any test data on air emission sources, e.g., HF testing, bag hosue dust analyses, etc., not previously submitted to our office under a section 114 request. 15. Approximately what percentage of the facility's total charge (in #14 above) is considered clean charge?

** Please indicate which of the Group 1 or Group 2 furnaces listed above that have side wells or scrap wells. Unit Identification Numbers (Unit ID No.) Unit ID No. as Designated in Title V or State Operating

Permit* Subpart RRR Equipment Do You Have This Equipment at the Facility? (Y or N) Add-on Controls (Y or N) Operating in 2009? (Y or N) If "No," list last year of operation Percent (%):

Amount of Charge (tons/yr) Maximum Capacity of Unit (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)* Unit ID No. Control Device



### Page 2 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Type Device ID No.

Type Device ID No.

Type Device ID No.

Type Device ID No.

Type Device ID No.

Type Device ID No.

Type Device ID No.

Type Device ID No. * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. Charge Rate During Most Recent Performance Test (lbs/hr)* Maximum Capacity of

Unit (tons/yr)

Amount of Charge (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)* Control Device

27. For Each Sweat Furnace Amount of Charge (tons/yr) * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. 20. For Each Thermal Chip Dryer * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.

Unit ID No. Amount of Dross Charged (tons/yr) Unit ID No. Amount of Chips Charged (tons/yr)

21. For Each Scrap Dryer/Delacquering Kiln/Decoating Kiln

Unit ID No. Amount of Charge (tons/yr)

** If the kiln is equipped with an afterburner operated at a minimum of 760°C (1400 °F), with a design residence time of 1 second minimum, enter the control device ID Nos. here:

22. For Each Dross Only Furnace Control Device Control Device** Control Device

Charge Rate During Most Recent Performance Test (lbs/hr)* Maximum Capacity of

Unit (tons chips/yr) Charge Rate During Most Recent Performance Test (lbs/hr)*

Maximum Capacity of

Unit (tons/yr)

Unit ID No. Amount of Charge (tons/yr) Control Device Only Clean Charge (yes/no) Charge Rate During Most Recent Performance Test (lbs/hr)*

24. For Each Group 1 Furnace Maximum Capacity of Unit (tons dross/yr) Charge Rate During Most Recent Performance Test (lbs/hr)*

25. For Each Group 2 Furnace

26. For Each In-Line Fluxer

Unit ID No. Amount of Charge (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)* Control Device

Charge Rate During Most Recent Performance Test (lbs/hr)* Maximum Capacity of

Unit (tons/yr)

Unit ID No. Unit ID No.

Maximum Capacity of Unit (tons/yr) Maximum Number of Times the Unit Can Run in a 24-hr Period

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.

Control Device** Maximum Capacity of

Unit (tons/yr) Control Device 23. For Each Rotary Dross Cooler

Unit ID No. Amount of Dross Charged (tons/yr) Maximum Capacity of Unit (tons dross/yr)



### Page 3 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

PM (lbs/ton) D/F** (grain/ton) HCl (lbs/ton) Total Hydrocarbons (THC) (lbs/ton) Device Type* Unit ID No.

Equipment/Process Description Unit ID No. List Each Individual HAP CAS# Emission Rate (lbs/yr) Maximum Allowable (lbs/yr) Maximum Allowable (lbs/hr) Emission Factor Type*

Equipment/Process Description Unit ID No. List Each Individual HAP* CAS# Emission Rate* (lbs/yr) Maximum Allowable (lbs/yr) Maximum Allowable (lbs/hr) Emission Factor Type** * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.

28. For Each Secondary Aluminum Processing Unit (SAPU) Using Emissions Averaging (as per section 63.1505(k)) a. Complete this table if your facility chose to measure compliance using the weight of the feed/charge .
SAPU Unit ID No. ** If the sweat furnace is equipped with an afterburner operated at a minimum of 1600°F, with a design residence time of 0.8 second minimum, enter the control device ID here:

Unit Nos. from Questions #24 and #26 Making Up the

SAPU(s) SAPU Type? N = New E = Existing Amount of Feed/Charge (tons/yr) Percent Clean Charge (approximate)

Part E. Emissions and Limits for Subpart RRR Sources and Non-Subpart RRR Sources Please provide the information below for all equipment at your facility; use information for this section from 2004 or later, whichever year is representative of the highest emissions per ton of production. (please specify year): SAPU Unit ID No. Unit Nos. from Questions #24 and #26 Making Up the

SAPU(s) SAPU Type? N = New E = Existing Amount of Aluminum Produced (tons/yr) Percent Clean Charge (approximate)

For purposes of this section, "Maximum Capacity or Maximum Allowable" of a unit is defined as the unit's potential to process charge or produce aluminum at its maximum rate on mass/time basis. If your permit limits the throughput or output of the unit, then that permitted amount may be used to calculate the maximum capacity.

37.b. Add-on air pollution control devices (use multiple lines if the same control device is used to control more than one pollutant). (Do not include Primary Aluminum Sources.) Units Controlled Control Device (from Part C or D above)

Units Controlled ** Emission Factor Type: 1 = Emissions calculated based on source test or other emissions measurements. 2 = Emissions calculated based on material balance using engineering knowledge of the process. 3= Emissions calculated based on AP-42 or EPA 450/2-90-011 or other EPA emission factor. 4 = Emissions calculated by engineering judgment. (Approved by the State agency) 5 = Emissions calculated based on a state or local agency emission factor.

Control Device Efficiency (if known) (percent) 37.a. Add-on air pollution control devices (use multiple lines if the same control device is used to control more than one pollutant). Part F. Detailed Control Device and Emission Release Information for Subpart RRR MACT Sources and Other Collocated Sources Emitting Hazardous Air Pollutants (HAP) Use information for this section from 2004 or later, whichever year is representative of the highest emissions per ton of production. (please specify year):

Control Devices

* For example, afterburner, lime coated fabric filter, etc. ** Control & Capture Efficiency a = Testing (specify method) b = Manufacturer's Specifications c = Engineering Estimate Please provide any additional information concerning the Control Devices: Pollutant Controlled Capture Efficiency (if known) (percent) Overall Efficiency (if known) (percent) Methods Used for Determining Capture & Control Efficiencies** (a–c) Type(s) of Unit Unit ID No. Device Type* Device ID No. 36.a. Please list all regulated pollutant emissionsfrom equipment subject to 40 CFR 63, subpart RRR.

* If you comply with subpart RRR requirements for sweat furnaces by controlling your afterburner residence time, enter “AB/RT” in the table. ** Please include dioxin/furan congeners. Use additional lines to break these out, if necessary.

* Emission Factor Type: 1 = Emissions calculated based on source test or other emissions measurements. 2 = Emissions calculated based on material balance using engineering knowledge of the process. 3= Emissions calculated based on AP-42 or EPA 450/2-90-011 or other EPA emission factor. 4 = Emissions calculated by engineering judgment. (Approved by the State agency) 5 = Emissions calculated based on a state or local agency emission factor.

* Copies of test data reports for your HAP emissions from non-subpart RRR sources are not required. HAP emissions data previously submitted for Primary Aluminum is not required. Please include all other HAP emissions. Unit ID No. Emissions Unit Name Emissions of Regulated RRR Pollutants Based on Performance Tests

36.b. Please list all other HAPemissions from equipment subject to 40 CFR 63, subpart RRR.(please include fugitive emissions.)

36.c. Please list estimated HAP emissions from collocated sources that are not regulated under 40 CFR 63, subpart RRR. (Please include fugitive emissions.) Do not include Primary Aluminum Sources. Gas fired equipment (such as preheater boxes and annealing furnaces, etc.) not regulated under 40 CFR 63, subpart RRR may be combined into a single entry. List Dates of the Applicable Compliance Tests* b. Complete this table if your facility chose to measure compliance using the weight of the aluminum produced .

Please provide the information below for subpart RRR MACT sources .

Please provide the information below for sources not subject to subpart RRR MACT sources . Control Devices



### Page 4 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Unit Name Unit ID No.

Was the level of molten metal maintained above the top of the passage between the sidewell and hearth during periods of reactive fluxing? Was the level of molten metal maintained above the top of the passage between the sidewell and hearth continuously?

How was the molten metal level monitored?

c. For each Group 1 furnace that is not ducted to a control device : Was reactive flux used in the sidewell, hearth, both, or neither? Please provide any additional information concerning the Control Devices:

Furnace ID b. For each sidewell (scrapwell) furnace * For example, afterburner, lime coated fabric filter, etc. ** Control & Capture Efficiency a = Testing (specify method) b = Manufacturer's Specifications c = Engineering Estimate Methods Used for Determining Capture & Control Efficiencies** (a–c) Type(s) of Unit Unit ID No. Device Type* Device ID No. Overall Efficiency (if known) (percent)

Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature (degrees F) Flow Rate (SCFM) 38.a. For each stack/control device exhaust point, please provide the following information, if known, related to the information in Item #37a above. (Subpart RRR MACT Sources)

Unit ID No. What Control Devices are Vented at this Point? * Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. Pollutant Controlled Capture Efficiency (if known) (percent) Control Device Efficiency (if known) (percent)

Pollutant(s) Tested Emissions (specify units) 40. For each affected source listed in [Section B, above], identify the date(s) of latest NESHAP compliance testing. Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature (degrees F)

Discharge Exit Gas Temperature (degrees F)

ID of other furnaces for which this test was used to determine representative emission rates. Is this furnace operated continuously or batch-by-batch? Does the furnace process metal other than clean charge? Longitude* Flow Rate (SCFM) 38.b. For each stack/control device exhaust point, please provide the following information, if known, related to the information in Item #37b above. (Non-Subpart RRR MACT Sources) Do not include Primary Aluminum Sources. If emissions from gas fired equipment were combined in question #36c and discharged through different stacks, please estimate the fraction of the discharge emitted through each stack.

* Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations.

Date Tested Emission Unit Test Method Used Exit Gas Temperature (degrees F)

What period of time during each run was metal tapped from the furnace? Is this a sidewell (scrapwell) furnace? Is this a melting or holding furnace? Furnace ID*

How many runs were included in the test? What was the length of each performance test run? How many minutes during each run was the charging door open? What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.?

Furnace ID Is the furnace equipped with a hood or other type of enclosure as part of the emissions collection system? * Where two or more co-controlled furnaces were tested simultaneously, list all furnace IDs. a. For each Group 1 furnace for which a performance test was conducted:

If yes, please describe. What steps were taken during the test to minimize emissions from the furnace doors, etc.? Latitude* Longitude* Flow Rate (SCFM) Latitude* Latitude* Longitude*

Latitude* Longitude* Flow Rate (SCFM) 39.a. For each exhaust point/stack not associated with a control device for Subpart RRR MACT Sources, please provide the following information:
Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge

* Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. 39.b. For each exhaust point/stack not associated with a control device for Non-Subpart RRR MACT Sources, please provide the following information: (Do not include Primary Aluminum Sources) Height of Stack or Discharge (ft)

* Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations.



### Page 5 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Flux Identification Flux Still in Use? (Y or N) Reactive = R Non-reactive = N Mass Used (lbs/yr) Furnace or In-line Fluxer ID in which Flux was Used Purpose (e.g., cover, degassing, demagging,

etc.) Is the furnace equipped with a capture system to limit fugitive emissions? If yes, please describe. Were visible emissions monitored during the performance test? Were visible emissions observed during the performance test?

d. For each Group 1 furnace that is ducted to a control device : Furnace ID

Are visible emissions present during charging? What, if any, monitoring and inspection is conducted to minimize leakage from the duct leading to the control device? What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.?
e. For each thermal chip dryer, scrap dryer/delacquering kiln/decoating kiln, sweat furnace, dross only furnace and rotary dross cooler:

Were visible emissions observed during the performance test? Equipment ID & Type Is this unit equipped with a hood or other capture devices as part of the emissions collection system? If yes, please describe. Were visible emissions monitored during the performance test?

a. What type of pretreatment (including, but not limited to, air drying, centrifugal drying, etc.) takes place to get the charge ready for processing? b. Do you track the amount of aluminum produced as well as the amount of charge? c. Could you develop and report your emission rates in terms of amount of emissions per unit of aluminum produced? If not, what prevents you from doing so?

a. What fluxes were used during the representative year used in Part F? Please attach MSDS for each flux: 43. Fluxing for Subpart RRR MACT Sources

44. Alternative controls, monitoring, or operating conditions for Subpart RRR MACT Sources

Base Year for For the control technologies identified in question 44a above, please provide cost information: Control Device Total Capital Total Annual Operating and Are visible emissions present during loading and unloading of the unit? What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.?

c. What, if any, modifications to the capture systems of existing sources were made to demonstrate compliance with this standard (e.g., extending hoods, increasing exhaust rate, modifying operating procedures, etc.)?

d. Were there any problems that were encountered during the permitting process or operation of your facility due ot the way the rule is written in subpart RRR?

Part G. Facility Operations 41. For affected sources at your facility subject to subpart RRR that are ducted to add-on control devices:

b. What design parameters were measured to confirm this?

d. How do you ensure that the molten metal in the sidewell furnace remains above the top of the passage between the sidewell and the hearth during reactive fluxing?

a. Please provide details for any alternative control devices(i.e., control devices other than fabric filters, lime-coated fabric filters, or afterburners), monitoring(including particulate matter or HCI continuous emissions monitors), or operating conditionsat this facility for equipment regulated under 40 CFR 63, subpart RRR. 42. General Questions for Subpart RRR MACT Sources

c. Do you use different types or quantities of flux for different flux applications? If so, how do the procedures differ?
d. What are your flux rate operating and monitoring procedures? b. If you have sidewell (scrapwell) furnaces, did you use reactive flux in the sidewell and the hearth? If so, did you test emissions from both sources? a. Are these sources equipped with capture systems designed and installed in accordance with the standard (i.e., sections 3 and 5 of the ACGIH manual)?

Maximum lbs/hr of hydrogen fluoride emitted What fraction of the fluoride contentof the flux used was emitted as either HF, F2, or particulate fluoride (%)? Pounds of hydrogen fluoride emitted per ton of charge (lbs HF/ton charge) e. Do you have any hydrogen fluoride emissions data for Subpart RRR MACT Sources? If so, please provide the data reports or other supporting data for the following:

Maximum tons/yr of hydrogen fluoride emissions



### Page 6 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Type/Description Device ID. No.

Startup/Shutdown* Description of the event, including identification of the emissions source or sources [unit ID(s)] associated with the startup or shutdown. Was any permit condition was exceeded and, if so, what permit condition was exceeded? Was the event covered by any contingency plan for controlling emissions during startup or shutdown events and, if so, whether the plan was followed; if the plan was not followed, why not? Typical duration of an event. Actions taken to minimize emissions during the event, including the use of any backup control systems. Estimates or measurements, if any, of emissions during the event; if you did not have the ability to quantify emissions during the event, please explain why. For affected sources ducted to afterburners, did any startups or shutdowns take place while the afterburner was not oeprating, or operating outside of the operating temperature established during the performance test? For affected sources ducted to control devices and monitored by continuous opacity monitors, did opacity exceed 10% during any startup or shutdown events? List performance test data collected during each period of startup or shutdown, the test method used for each event; when the testing was conducted and why; the test conditions at the time of testing; and whether the tests were associated with a routine startup or shutdown.

Lead VOC PM PM10 PM2.5 CO SOx NOx

Unit ID No.

d. Do you have any plans to install any new higher efficiency rated control devices or have any pending applications to add on any new controls? If so, please specify and include any copies of pending permit applications as requested in Part A, item #17. Operating Costs Investment

c. Do you use catalytic filters for dioxin control (e.g., http://www.donaldson.com/en/industrialair/literature/051754.pdf)?

45. Pollution Prevention for Subpart RRR MACT Sources

Other (specify): Maintenance Costs

e. Do you have any plans to use any alternative monitoring or operating conditions? If so, please provide details:

A. Describe any procedures or work practice standards used at your facility to prevent or reduce emissions of Hazardous Air Pollutants (HAP). (As opposed to controlling pollution after it is formed).

ID No. CAP Emissions* (tons per year) Emission Unit Part I. Criteria Air Pollutants (CAP) for Subpart RRR MACT Sources and Non-Subpart RRR MACT Sources Please provide the information below for all regulated equipment at your facility; use information for this section from 2004 or later, whichever year has the highest production rate. (please specify year):
49.a. CAP emissions by unit for each emission unit subject to 40 CFR 63, subpart RRR MACT sources. (Please include fugitive emissions.) 48. Optional: Please recommend a standard that would apply during startup and/or shutdown.Describe the type of event (e;g., defining the beginning and duration of a start-up period and similarly for a shutdown) to which the standard would apply; the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would minimize emissions during the event; and how compliance would be determined and/or monitored.

* Please provide any test data along with this section for sources subject to 40 CFR 63, subpart RRR MACT sources. b. Have you injected activated carbon or other tpe of carbon for HAP control (excluding research efforts)? What barriers do you envision to adding carbon injection to fabric filters for HAP control? (X all that apply.)

Cost of activated carbon Creates problems with disposal of material collected by baghouse

46. For each startup and shutdown event for which you did not follow your Startup/Shutdown plan or that resulted in an exceedance of any applicable emission limitation during the past 2 years, please provide the requested information in the table below. If this information is contained in periodic and immediate SSM reports (either stand-alone or contained within the periodic excess emissions report) submitted to your permitting authority, you may submit copies of those reports instead. Please provide anyemissions data during startup or shutdown, if available. Part H. Startup and Shutdown for Subpart RRR MACT Sources

47. Are there any types of startup or shutdown events that you have been able to eliminate; if so, please describe the type of event and explain how these events were eliminated. * Startup : the commencement of operation of an affected source or portion of an affected source for any purpose. Shutdown : the cessation of operation of an affected source or portion of an affected source for any purpose



### Page 7 of 18

### Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Lead VOC PM PM10 PM2.5 CO SOx NOx

Control Device ID Type of Device ID(s) of Units Controlled Pollutants Controlled Control Efficiency (%)

Usage: (specify units) Hours

Used per Year Higher

Heating Value (HHV) Usage:

(specify units) Hours

Used per Year Higher

Heating Value (HHV) Usage:

(specify units) Hours

Used per Year Higher

Heating Value (HHV)

Normal Operating Annual Electricity Usage Year Total Facility Usage (specify unit of measurement) *Process unit usage information can be grouped only if individual unit information is not known or cannot be reasonably calculated. 50. Control devices used for CAP emission control for Subpart RRR MACT Sources and Non-Subpart RRR MACT Sources (excluding Primary Aluminum).

51. Please list total annual energy consumption. (Exclude emergency combustion equipment.) Part J. Energy Usage

52. Are any Cogeneration units listed above; if so, please list the unit and describe the process for each.

Part K. Miscellaneous Information 54. What specific improvements or rule changes would you like to see that would help your facility with compliance or better rule interpretation? Number of Operating Hours per Year Design Capacity (Heat Input) (MMBtu/hr) Emission Unit CAP Emissions (tons per year)

Is the Unit Subject to NSPS (if yes, indicate year)? Heat Release Rate (Btu/scf) Fuel Type 49.b. PLease list estimated CAP emissions from collocated sources at your facility that are not regulated under 40 CFR 63, subpart RRR MACT sources. (Please include fugitive emissions, but not emissions from Primary Aluminum sources.)Test reports are not required to be submitted for sources not subject to 40 CFR 63, subpart RRR.

ID No.

Start-up Fuel Type of Combustion Equipment Fuels Combusted during Production (solid, liquid, and gaseous fuels, including waste streams)

53. Electricity Usage Fuel #1 Fuel #2 Fuel #3

Process Unit ID No.(s):* Start-up Fuel Higher Heating Value (HHV) Typical Length of Time for Start-up (hours) Typical Start-up Fuel Amount (specify units) Type of Combustion Equipment



### Page 8 of 18Name Address City State Zip

Name Address City State Zip

a. Address b. City c. State d. Zip e. County

a. Address b. City c. State d. Zip

a. Name (First Name, Last Name) b. Title c. Telephone number and extension d. Fax number e. E-mail

(Print Name) (Title) (Signature of Responsible Official) (Date)

a. Primary NAICS code b. Other facility NAICS codes

≤50 51–100 101–500 501–750 751–1000 >1000

≤50 51–100 101–500 501–750 751–1000 >1000

Yes No

Subpart RRR (Secondary Aluminum) Diecastin Foundry Extruder Subpart LL (Primary Aluminum)Other (SPECIF Other (SPECIF (SPECIF (SPECIF (SPECIF Y the (SPECIF (SPECIF Other MACT

(e.g., Metal Coil Surface Coatings MACT): Other MACT: (SPECIFY emission unit and rule)

Hours/day: Shifts/day: Days/week: Weeks/year:

Aluminum Scrap Shredder Thermal Chip Dryer Scrap Dryer/ Delacquering/Decoating Kiln Group 1 Furnace

—Clean charge only** Group 1 Furnace

— Handling other than clean charge** Group 2 Furnace** In-line Fluxer Dross-only Furnace Rotary Dross Cooler Sweat Furnace

Type Device ID No.

Type* Device ID No.

Type Device ID No.

Type Device ID

Type Device ID No.

Diameter (ft) Area (sq ft) Longitude** Maximum Minimu m

PM (lbs/ton) D/F** (grain/ton) HCl (lbs/ton) Total Hydrocarbons (THC) (lbs/ton) Device Type* Unit ID No.

Equipment/Process Description Unit ID No. List Each Individual HAP CAS# Emission Rate (lbs/yr) Maximum Allowable (lbs/yr) Maximum Allowable (lbs/hr) Emission Factor Type* Information Collection Request for Secondary Aluminum Production

Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP) Part A. Facility Information 1. Name and address of legal OWNER of the facility:

2. Name and address of legal OPERATOR of the facility, if different from the legal OWNER:

3. Complete street address of facility (physical location):

5. Facility contact able to answer technical questions about the completed survey: 4. Provide mailing address of the facility if different from physical location:

f. If the facility is permanently closed or is not subject to 40 CFR part 63, subpart RRR, please complete this page, sign below and send this page certified mail to the non-CBI address listed on the instruction sheet by XXX,
I certify that this facility is permanently closed or is not subject to the National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production as defined in 40 CFR part 63, subpart RRR.

A Responsible Official can be the president, vice president, secretary, or treasurer of the company that owns the facility, owner of the facility, plant manager, plant engineer or supervisor.
6. What is the facility size classification for hazardous air pollutant (HAP) emissions? (X one cell)

8. Company Size (X one cell) Note: Aproximate number of all employees (worldwide) of the business enterprise that owns this facility, including where applicable, the parent company and all subsidiaries, branches, and unrelated establishments owned by the parent company: If your company has a primary NAICS code that does not begin with "331--- ," please also include your average annual sales receipts $____________________ (How to calculate average annual receipts and average employment of a firm can be found in 13 CFR §121.104 and 13 CFR

9. Facility Size (X one cell) Note: Approximate number of all employees at facility in location identified in question #3 above. EPA Major Source of Hazardous Air Pollutants (HAP) EPA Area source (based on potential to emit) of HAP EPA Area source (Synthetic Minor) of HAP
7. Facility NAICS codes Note: The primary NAICS code represents the line of business that generates the most income for the facility.

10. Is the legal owner a small entity as defined by the Regulatory Flexibility Act? (X one cell) Note: For private businesses, small entity is defined for each NAICS of the owning entity based on number of employees and/or company revenue. The NAICS codes used for Secondary Aluminum Production are 331312, 331314, 331315, 331319, 331521, 331524, and various codes used for operations with Sweat Furnaces. The small business size standards for NAICS subsectors are located at the following link: http://www.sba.gov/contractingopportunities/officials/size/

11. Federal and State rule/permit coverage. (X all that apply to this facility)

Title V:

State Air Toxics: New Source Performance Standards (NSPS):

12. Normal Facility Production Hours

Tons of charge:
15. Approximately what percentage of the facility's total charge (in #14 above) is considered clean charge? Percent (%):
16. Please provide a copy of a schematic of the plant layout for equipment subject to subpart RRR, control devices, and discharge stacks associated with these units. Label the schematic with the unit IDs, control device IDs, and stack IDs, which should also match the unit IDs, control device IDs, and stack IDs used to respond to later questions. Please properly identify units that are permanently "out of service" or not yet installed. 13. Total amount of aluminum produced in 2009. If 2009 is not representative of normal operations, please provide information for a representative year (2004 or later) and specify the year. Year: Tons of aluminum produced:
14. Amount of total charge to the facility used to produce the amount of aluminum reported in question #13:

17. Please provide all of the pertinent information listed below. Please provide electronic copies, if available, and indicate items provided below. (X all that apply)

Operating, maintenance, and monitoring plan (OM&M)
Part B. Facility Equipment Regulated under Subpart RRR (Secondary Aluminum NESHAP) See “Definitions” in Attachment 1 at the end of this survey for explanation of these terms. For the purposes of this survey, scrap wells and wells of similar function as the side well shall be considered a sidewell. Please provide the information below for all equipment at your facility. Title V permit State Air Operating permit Pending air permit applications (except for state and Title V renewal applications) Performance test reports (submit most recent test reports for each subpart RRR related process) . This includes any test data on air emission sources, e.g., HF testing, bag hosue dust analyses, etc., not previously submitted to our office under a section 114 request. Emission inventory reports (reporting years should be the same as the years selected for this survey) Most recent Consent decree or order for air related issues

Part D. Charge Rates and Controls Used for AreaSources Subpart RRR MACT Please provide the information below for all regulated equipment at your facility; use information for this section from 2004 or later, whichever year is representative of the highest emissions per ton of production: (please specify year) * Please complete this column if ID numbers used in this form are different from those in the permit. ** Please indicate which of the Group 1 or Group 2 furnaces listed above that have side wells or scrap wells. 18. Related Equipment List
Unit Identification Numbers (Unit ID No.) Unit ID No. as Designated in Title V or State Operating

Permit* Subpart RRR Equipment Do You Have This Equipment at the Facility? (Y or N) Add-on Controls (Y or N) Operating in 2009? (Y or N) If "No," list last year of operation Notice(s) of air operating permit violations for the past 3 years Startup, shutdown, and malfunction (SSM) plan

Control Device** Maximum Capacity of

Unit (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)* For purposes of this section, "Maximum Capacity" of a unit is defined as the unit's potential to process charge or produce aluminum at its maximum rate on mass/time basis. If your permit limits the throughput or output of the unit, then that permitted amount may be used to calculate the maximum capacity. 29. For Each Thermal Chip Dryer Control Device Unit ID No. Amount of Chips Charged (tons/yr)

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. ** If the kiln is equipped with an afterburner operated at a minimum of 760°C (1400 °F), with a design residence time of 1 second minimum, enter the control device ID Nos. here:

31. For Each Group 1 Furnace * If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units.
30. For Each Scrap Dryer/Delacquering Kiln/Decoating Kiln

Unit ID No. Amount of Charge (tons/yr) Maximum Capacity of Unit (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)*

Charge Rate During Most Recent Performance Test (lbs/hr)* Control Device

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. Unit ID No. Amount of Charge (tons/yr) Only Clean Charge (yes/no) Maximum Capacity of Unit (tons/yr)

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. ** If the sweat furnace is equipped with an afterburner operated at a minimum of 1600°F, with a design residence time of 0.8 second minimum, enter the control device ID

33. For Each In-Line Fluxer 32. For Each Sweat Furnace

Unit ID No. Amount of Charge (tons/yr) Maximum Capacity of Unit (tons/yr) Charge Rate During Most Recent Performance Test (lbs/hr)* Control Device**

Charge Rate During Most Recent Performance Test Control Device

* If more than one performance test was conducted to demonstrate operation with different types of charge, please enter the maximum charge rate. If a test on a representative unit was conducted to demonstrate compliance for similar units, please enter the charge rate during the test used to demonstrate compliance for untested units. 34. Each Secondary Aluminum Processing Unit (SAPU) Using Emissions Averaging (as per section 63.1505(k)) Unit ID No. Amount of Charge (tons/yr) Maximum Capacity of Unit (tons/yr) Maximum Number of Times the Unit Can Run in a 24-hr Period

a. Complete this table if your facility chose to measure compliance using the weight of the feed/charge.
SAPU Unit ID No. Unit Nos. from Questions #31 and #33 Making Up the SAPU Type? N = New Amount of Feed/Charge Percent Clean Charge (approximate)

Discharge Exit Gas Temperature (degrees F) Latitude** Flow Rate (SCFM b. Complete this table if your facility chose to measure compliance using the weight of the aluminum produced .
SAPU Unit ID No. Unit Nos. from Questions #31 and #33 Making Up the SAPU Type? N = New Amount of Aluminum Produced Percent Clean Charge (approximate)

* For purposes of this section, "Maximum Capacity" of a unit is defined as the unit's potential to process or produce aluminum at its maximum rate on mass/time basis. If your permit limits the throughput or output of the unit, then that permitted amount may be used to calculate the maxiumum capacity. ** Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram, with a latitude/longitude reference point, indicating stack locations. Part E. Emissions and Limits for Subpart RRR Sources and Non-Subpart RRR Sources Please provide the information below for all equipment at your facility; use information for this section from 2004 or later, whichever year is representative of the highest emissions per ton of production: (please specify year) 35. Please complete this table for any scrap shredder, group 2 furnace, in-line fluxer, dross-only furnace, or rotary dross cooler present at your facility.

Unit ID No. Type of Equipment Maximum Capactity* (tons/yr) What Type of Control Device, if Any is Used? Height of Stack or Discharge (ft)

For purposes of this section, "Maximum Capacity or Maximum Allowable" of a unit is defined as the unit's potential to process charge or produce aluminum at its maximum rate on mass/time basis. If your permit limits the throughput or output of the unit, then that permitted amount may be used to calculate the maximum capacity.

36.a. Please list all regulated pollutant emissionsfrom equipment subject to 40 CFR 63, subpart RRR.

Unit ID No. Emissions Unit Name Emissions of Regulated RRR Pollutants Based on Performance Tests Control Device (from Part C or D above) List Dates of the Applicable Compliance Tests*

* If you comply with subpart RRR requirements for sweat furnaces by controlling your afterburner residence time, enter “AB/RT” in the table. ** Please include dioxin/furan congeners. Use additional lines to break these out, if necessary.

36.b. Please list all other HAPemissions from equipment subject to 40 CFR 63, subpart RRR.(please include fugitive emissions.)Information Collection Request for Secondary Aluminum Production Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP)

Equipment/Process Description Unit ID No. List Each Individual HAP* CAS# Emission Rate* (lbs/yr) Maximum Allowable (lbs/yr) Maximum Allowable (lbs/hr) Emission Factor Type**

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Diameter (ft) Area (sq ft) Maximum Minimum

Unit Name Unit ID No.

Flux Identification Flux Still in Use? (Y or N) Reactive = R Non-reactive = N Mass Used (lbs/yr) Furnace or In-line Fluxer ID in which Flux was Used Purpose (e.g., cover, degassing, demagging, etc.)

Type/Description Device ID. No.

Startup/Shutdown* Description of the event, including identification of the emissions source or sources [unit ID(s)] associated with the startup or shutdown. Was any permit condition was exceeded and, if so, what permit condition was exceeded? Was the event covered by any contingency plan for controlling emissions during startup or shutdown events and, if so, whether the plan was followed; if the plan was not followed, Typical duration of an event. Actions taken to minimize emissions during the event, including the use of any backup control systems. Estimates or measurements, if any, of emissions during the event; if you did not have the ability to quantify emissions during the event, please Control Devices Units Controlled * Emission Factor Type: 1 = Emissions calculated based on source test or other emissions measurements. 2 = Emissions calculated based on material balance using engineering knowledge of the process. 3= Emissions calculated based on AP-42 or EPA 450/2-90-011 or other EPA emission factor. 4 = Emissions calculated by engineering judgment. (Approved by the State agency) 5 = Emissions calculated based on a state or local agency emission factor.
36.c. Please list estimated HAP emissions from collocated sources that are not regulated under 40 CFR 63, subpart RRR. (Please include fugitive emissions.) Do not include Primary Aluminum Sources. Gas fired equipment (such as preheater boxes and annealing furnaces, etc.) not regulated under 40 CFR 63, subpart RRR may be combined into a single entry.

Please provide the information below for subpart RRR MACT sources .

Unit ID No.

* For example, afterburner, lime coated fabric filter, etc. ** Control & Capture Efficiency a = Testing (specify method) b = Manufacturer's Specifications c = Engineering Estimate * Copies of test data reports for your HAP emissions from non-subpart RRR sources are not required. HAP emissions data previously submitted for Primary Aluminum is not required. Please include all other HAP emissions. ** Emission Factor Type: 1 = Emissions calculated based on source test or other emissions measurements. 2 = Emissions calculated based on material balance using engineering knowledge of the process. 3= Emissions calculated based on AP-42 or EPA 450/2-90-011 or other EPA emission factor. 4 = Emissions calculated by engineering judgment. (Approved by the State agency) 5 = Emissions calculated based on a state or local agency emission factor.

Control Device Efficiency (if known) (percent) Overall Efficiency (if known) (percent) Part F. Detailed Control Device and Emission Release Information for Subpart RRR MACT Sources and Other Collocated Sources Emitting Hazardous Air Pollutants (HAP) Use information for this section from 2004 or later, whichever year is representative of the highest emissions per ton of production: (please specify year)

37.a. Add-on air pollution control devices (use multiple lines if the same control device is used to control more than one pollutant).

Device Type* Device ID No. Pollutant Controlled Capture Efficiency (if known) (percent) Methods Used for Determining Capture & Control Efficiencies** Type(s) of Unit

Pollutant Controlled Capture Efficiency (if known) (percent) Control Device Efficiency (if known) (percent) Overall Efficiency (if known) (percent) Methods Used for Determining Capture & Control Efficiencies** Please provide any additional information concerning the Control Devices:

Please provide the information below for sources not subject to subpart RRR MACT sources .

Flow Rate (SCFM) Type(s) of Unit Unit ID No.

* For example, afterburner, lime coated fabric filter, etc. ** Control & Capture Efficiency a = Testing (specify method) b = Manufacturer's Specifications c = Engineering Estimate Please provide any additional information concerning the Control Devices: 37.b. Add-on air pollution control devices (use multiple lines if the same control device is used to control more than one pollutant). (Do not include Primary Aluminum Sources.) Control Devices Units Controlled

Device Type* Device ID No.

Flow Rate (SCFM) 38.a. For each stack/control device exhaust point, please provide the following information, if known, related to the information in Item #37a above. (Subpart RRR MACT Sources)
Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature Latitude* Longitude*

Flow Rate (SCFM) * Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. 38.b. For each stack/control device exhaust point, please provide the following information, if known, related to the information in Item #37b above. (Non-Subpart RRR MACT Sources) Do not include Primary Aluminum Sources. If emissions from gas fired equipment were combined in question #36c and discharged through different stacks, please estimate the fraction of the discharge emitted through each stack.
Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature (degrees F) Latitude* Longitude*

Flow Rate (SCFM) * Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. 39.a. For each exhaust point/stack not associated with a control device for Subpart RRR MACT Sources, please provide the following information:

Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature Latitude* Longitude*

Emissions (specify units) * Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. 39.b. For each exhaust point/stack not associated with a control device for Non-Subpart RRR MACT Sources, please provide the following information: (Do not include Primary Aluminum Sources)

Unit ID No. What Control Devices are Vented at this Point? Height of Stack or Discharge (ft) Discharge Exit Gas Temperature (degrees F) Latitude* Longitude*

a. For each Group 1 furnace for which a performance test was conducted: Furnace ID* ID of other furnaces for which this test was used to determine representative emission rates. Is this furnace operated continuously or batch-by-batch? * Longitude and Latitude should be specified out to 6 decimal places. If coordinates are not known, please provide a scaled site diagram with a latitude/longitude reference point, indicating stack locations. 40. For each affected source listed in [Section B, above], identify the date(s) of latest NESHAP compliance testing. Date Tested Emission Unit Test Method Used Pollutant(s) Tested

What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.? What period of time during each run was metal tapped from the furnace? Is this a sidewell (scrapwell) furnace? Is this a melting or holding furnace? Does the furnace process metal other than clean charge? How many runs were included in the test? What was the length of each performance test run? How many minutes during each run was the charging door open?

Was the level of molten metal maintained above the top of the passage between the sidewell and hearth continuously? Was the level of molten metal maintained above the top of the passage between the sidewell and hearth during periods of reactive fluxing? How was the molten metal level monitored?

c. For each Group 1 furnace that is not ducted to a control device : * Where two or more co-controlled furnaces were tested simultaneously, list all furnace IDs. b. For each sidewell (scrapwell) furnace Furnace ID Was reactive flux used in the sidewell, hearth, both, or neither?

Were visible emissions monitored during the performance test? Were visible emissions observed during the performance test?

d. For each Group 1 furnace that is ducted to a control device: Furnace ID Furnace ID Is the furnace equipped with a hood or other type of enclosure as part of the emissions collection system? If yes, please describe. What steps were taken during the test to minimize emissions from the furnace doors, etc.?

What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.?
e. For each thermal chip dryer, scrap dryer/delacquering kiln/decoating kiln, sweat furnace, dross only furnace and rotary dross cooler: Equipment ID & Type Is this unit equipped with a hood or other capture devices as part of the emissions collection system? Is the furnace equipped with a capture system to limit fugitive emissions? If yes, please describe. Are visible emissions present during charging? What, if any, monitoring and inspection is conducted to minimize leakage from the duct leading to the control device?

What steps were taken during the test to minimize air emissions escaping from the furnace doors, etc.?
41. For affected sources at your facility subject to subpart RRR that are ducted to add-on control devices: a. Are these sources equipped with capture systems designed and installed in accordance with the standard (i.e., sections 3 and 5 of the ACGIH manual)? If yes, please describe. Were visible emissions monitored during the performance test? Were visible emissions observed during the performance test? Are visible emissions present during loading and unloading of the unit?

d. Were there any problems that were encountered during the permitting process or operation of your facility due ot the way the rule is written in subpart RRR?

Part G. Facility Operations b. What design parameters were measured to confirm this? c. What, if any, modifications to the capture systems of existing sources were made to demonstrate compliance with this standard (e.g., extending hoods, increasing exhaust rate, modifying operating procedures, etc.)?

c. Could you develop and report your emission rates in terms of amount of emissions per unit of aluminum produced? If not, what prevents you from doing so?
d. How do you ensure that the molten metal in the sidewell furnace remains above the top of the passage between the sidewell and the hearth during reactive fluxing? 42. General Questions for Subpart RRR MACT Sources a. What type of pretreatment (including, but not limited to, air drying, centrifugal drying, etc.) takes place to get the charge ready for processing?
b. Do you track the amount of aluminum produced as well as the amount of charge?

b. If you have sidewell (scrapwell) furnaces, did you use reactive flux in the sidewell and the hearth? If so, did you test emissions from both sources?
c. Do you use different types or quantities of flux for different flux applications? If so, how do the procedures differ? 43. Fluxing for Subpart RRR MACT Sources a. What fluxes were used during the representative year used in Part F? Please attach MSDS for each flux:

Pounds of hydrogen fluoride emitted per ton of charge (lbs HF/ton charge) Maximum lbs/hr of hydrogen fluoride emitted d. What are your flux rate operating and monitoring procedures?

e. Do you have any hydrogen fluoride emissions data for Subpart RRR MACT Sources? If so, please provide the data reports or other supporting data for the following: Maximum tons/yr of hydrogen fluoride emissions

a. Please provide details for any alternative control devices(i.e., control devices other than fabric filters, lime-coated fabric filters, or afterburners), monitoring(including particulate matter or HCI continuous emissions monitors), or operating conditionsat this facility for equipment regulated under 40 CFR 63, subpart RRR. What fraction of the fluoride contentof the flux used was emitted as either HF, F2, or particulate fluoride (%)?

44. Alternative controls, monitoring, or operating conditions for Subpart RRR MACT Sources

For the control technologies identified in question 44a above, please provide cost information:

Unit ID No. Control Device Total Capital Investment Total Annual Operating and Maintenance Costs Base Year for Operating Costs

Other (specify):
c. Do you use catalytic filters for dioxin control (e.g., http://www.donaldson.com/en/industrialair/literature/051754.pdf)? b. Have you injected activated carbon or other tpe of carbon for HAP control (excluding research efforts)? What barriers do you envision to adding carbon injection to fabric filters for HAP control? (X all that apply.) Cost of activated carbon Creates problems with disposal of material collected by baghouse

e. Do you have any plans to use any alternative monitoring or operating conditions? If so, please provide details:

45. Pollution Prevention for Subpart RRR MACT Sources d. Do you have any plans to install any new higher efficiency rated control devices or have any pending applications to add on any new controls? If so, please specify and include any copies of pending permit applications as requested in Part A, item #17.

46. For each startup and shutdown event for which you did not follow your Startup/Shutdown plan or that resulted in an exceedance of any applicable emission limitation during the past 2 years, please provide the requested information in the table below. If this information is contained in periodic and immediate SSM reports (either stand-alone or contained within the periodic excess emissions report) submitted to your permitting authority, you may submit copies of those reports instead. Please provide any emissions data during startup or shutdown, if available. A. Describe any procedures or work practice standards used at your facility to prevent or reduce emissions of Hazardous Air Pollutants (HAP). (As opposed to controlling pollution after it is formed).

Part H. Startup and Shutdown for Subpart RRR MACT SourcesInformation Collection Request for Secondary Aluminum Production Secondary Aluminum (40 CFR part 63, subpart RRR) National Emission Standards for Hazardous Air Pollutants (NESHAP) For affected sources ducted to afterburners, did any startups or shutdowns take place while the afterburner was not oeprating, or operating outside of the operating temperature established during the For affected sources ducted to control devices and monitored by continuous opacity monitors, did opacity exceed 10% during any startup or shutdown List performance test data collected during each period of startup or shutdown, the test method used for each event; when the testing was conducted and why; the test conditions at the time of testing; and whether the tests were associated with a routine startup or shutdown.

Lead VOC PM PM10 PM2.5 CO SOx NOx

Lead VOC PM PM10 PM2.5 CO SOx NOx

Control Device ID Type of Device ID(s) of Units Controlled Pollutants Controlled Control Efficiency (%)

Usage: (specify units) Hours

Used per Year Higher

Heating Value (HHV) Usage:

(specify units) Hours

Used per Year Higher

Heating Value (HHV) Usage:

(specify units) Hours

Used per Year Higher

Heating Value (HHV)

Normal Operating Annual Electricity Usage Year Total Facility Usage (specify unit of measurement) *Process unit usage information can be grouped only if individual unit information is not known or cannot be reasonably calculated. * Startup : the commencement of operation of an affected source or portion of an affected source for any purpose. Shutdown : the cessation of operation of an affected source or portion of an affected source for any purpose
47. Are there any types of startup or shutdown events that you have been able to eliminate; if so, please describe the type of event and explain how these events were eliminated.

Emission Unit Part I. Criteria Air Pollutants (CAP) for Subpart RRR MACT Sources and Non-Subpart RRR MACT Sources Please provide the information below for all regulated equipment at your facility; use information for this section from 2004 or later, whichever year has the highest production rate (please specify year):
49.a. CAP emissions by unit for each emission unit subject to 40 CFR 63, subpart RRR MACT sources. (Please include fugitive emissions.) 48. Optional: Please recommend a standard that would apply during startup and/or shutdown.Describe the type of event (e;g., defining the beginning and duration of a start-up period and similarly for a shutdown) to which the standard would apply; the recommended standard (this could be an emission limitation, work practice, or operational standard) that would apply during the period; the basis for the recommended standard; why and how the standard would minimize emissions during the event; and how compliance would be determined and/or monitored.

Design Capacity (Heat Input) (MMBtu/hr) 50. Control devices used for CAP emission control for Subpart RRR MACT Sources and Non-Subpart RRR MACT Sources (excluding Primary Aluminum).

Part J. Energy Usage

Typical Start-up Fuel Amount (specify units) ID No. Emission Unit CAP Emissions* (tons per year)

* Please provide any test data along with this section for sources subject to 40 CFR 63, subpart RRR MACT sources. 49.b. PLease list estimated CAP emissions from collocated sources at your facility that are not regulated under 40 CFR 63, subpart RRR MACT sources. (Please include fugitive emissions, but not emissions from Primary Aluminum sources.)Test reports are not required to be submitted for sources not subject to 40 CFR 63, subpart RRR.

ID No.

Is the Unit Subject to NSPS (if yes, indicate year)? CAP Emissions (tons per year)

Typical Length of Time for Start-up (hours) Start-up Fuel Higher Heating Value (HHV) 51. Please list total annual energy consumption. (Exclude emergency combustion equipment.)

Process Unit ID No.(s):* Type of Combustion Equipment Type of Combustion Equipment Number of Operating Hours per Year Fuel Type Fuels Combusted during Production (solid, liquid, and gaseous fuels, including waste streams) Fuel #1 Fuel #2 Fuel #3

52. Are any Cogeneration units listed above; if so, please list the unit and describe the process for each. Heat Release Rate (Btu/scf) Start-up Fuel

53. Electricity Usage

Part K. Miscellaneous Information 54. What specific improvements or rule changes would you like to see that would help your facility with compliance or better rule interpretation?

# Attachment A Definitions for subpart RRR MACT sources Afterburner

means an air pollution control device that uses controlled flame combustion to convert combustible materials to noncombustible gases; also known as an incinerator or a thermal oxidizer. Aluminum scrap means fragments of aluminum stock removed during manufacturing (i.e., machining), manufactured aluminum articles or parts rejected or discarded and useful only as material for reprocessing, and waste and discarded material made of aluminum. Aluminum scrap shredder means a unit that crushes, grinds, or breaks aluminum scrap into a more uniform size prior to processing or charging to a scrap dryer/delacquering kiln/decoating kiln, or furnace. A bale breaker is not an aluminum scrap shredder. Clean charge means furnace charge materials, including molten aluminum; T-bar; sow; ingot; billet; pig; alloying elements; aluminum scrap known by the owner or operator to be entirely free of paints, coatings, and lubricants; uncoated/unpainted aluminum chips that have been thermally dried or treated by a centrifugal cleaner; aluminum scrap dried at 343 °C (650 °F) or higher; aluminum scrap delacquered/decoated at 482 °C (900 °F) or higher, and runaround scrap. Cover flux means salt added to the surface of molten aluminum in a group 1 or group 2 furnace, without agitation of the molten aluminum, for the purpose of preventing oxidation. Dross-only furnacemeans a furnace, typically of rotary barrel design, dedicated to the reclamation of aluminum from dross formed during melting, holding, fluxing, or alloying operations carried out in other process units. Dross and salt flux are the sole feedstocks to this type of furnace. Group 1 furnacemeans a furnace of any design that melts, holds, or processes aluminum that contains paint, lubricants, coatings, or other foreign materials with or without reactive fluxing, or processes clean charge with reactive fluxing. Group 2 furnacemeans a furnace of any design that melts, holds, or processes only clean charge and that performs no fluxing or performs fluxing using only nonreactive, non-HAP-containing/non-HAP-generating gases or agents. In-line fluxer

means a device exterior to a furnace, located in a transfer line from a furnace, used to refine (flux) molten aluminum; also known as a flux box, degassing box, or demagging box. Melting/holding furnace, or melter/holder, means a group 1 furnace that processes only clean charge, performs melting, holding, and fluxing functions, and does not transfer molten aluminum to or from another furnace. Rotary dross cooler

means a water-cooled rotary barrel device that accelerates cooling of dross. Runaround scrapmeans scrap materials generated on-site by aluminum casting, extruding, rolling, scalping, forging, forming/stamping, cutting, and trimming operations and that do not contain paint or solid coatings. Uncoated/unpainted aluminum chips generated by turning, boring, milling, and similar machining operations may be clean charge if they have been thermally dried or treated by a centrifugal cleaner, but are not considered to be runaround scrap. Scrap dryer/delacquering kiln/decoating kilnmeans a unit used primarily to remove various organic contaminants such as oil, paint, lacquer, ink, plastic, and/or rubber from aluminum scrap (including used beverage containers) prior to melting. Secondary aluminum processing unit (SAPU):an existing SAPU means all existing group 1 furnaces and all existing in-line fluxers within a secondary aluminum production facility. Each existing group 1 furnace or existing in-line fluxer is considered an emission unit within a secondary aluminum processing unit. A new SAPU means any combination of group 1 furnaces and in-line fluxers which are simultaneously constructed after February 11, 1999. Each of the group 1 furnaces or in-line fluxers within a new SAPU is considered an emission unit within that secondary aluminum processing unit. Sidewellmeans an open well adjacent to the hearth of a furnace with connecting arches between the hearth and the open well through which molten aluminum is circulated between the hearth, where heat is applied by burners, and the open well, which is used for charging scrap and solid flux or salt to the furnace, injecting fluxing agents, and skimming dross. Sweat furnacemeans a furnace used exclusively to reclaim aluminum from scrap that contains substantial quantities of iron by using heat to separate the low-melting point aluminum from the scrap while the higher melting-point iron remains in solid form. Thermal chip dryer

means a device that uses heat to evaporate water, oil, or oil/water mixtures from unpainted/uncoated aluminum chips.



# A-12

# CAS Number Chemical Name

75070 Acetaldehyde 60355 Acetamide 75058 Acetonitrile 98862 Acetophenone 53963 2-Acetylaminofluorene 107028 Acrolein 79061 Acrylamide 79107 Acrylic acid 107131 Acrylonitrile 107051 Allyl chloride 92671 4-Aminobiphenyl 62533 Aniline 90040 o-Anisidine 1332214 Asbestos 71432 Benzene (including benzene from gasoline) 92875 Benzidine 98077 Benzotrichloride 100447 Benzyl chloride 92524 Biphenyl 117817 Bis(2-ethylhexyl)phthalate (DEHP) 542881 Bis(chloromethyl)ether 75252 Bromoform 106990 1,3-Butadiene 156627 Calcium cyanamide 133062 Captan 63252 Carbaryl 75150 Carbon disulfide 56235 Carbon tetrachloride 463581 Carbonyl sulfide 120809 Catechol 133904 Chloramben 57749 Chlordane 7782505 Chlorine 79118 Chloroacetic acid 532274 2-Chloroacetophenone 108907 Chlorobenzene 510156 Chlorobenzilate 67663 Chloroform 107302 Chloromethyl methyl ether 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412



# B-13

# CAS Number Chemical Name 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412
126998 Chloroprene 1319773 Cresols/Cresylic acid (isomers and mixture) 95487 o-Cresol 108394 m-Cresol 106445 p-Cresol 98828 Cumene 94757 2,4-D, salts and esters 3547044 DDE 334883 Diazomethane 132649 Dibenzofurans 96128 1,2-Dibromo-3-chloropropane 84742 Dibutylphthalate 106467 1,4-Dichlorobenzene(p) 91941 3,3-Dichlorobenzidene 111444 Dichloroethyl ether (Bis(2-chloroethyl)ether) 542756 1,3-Dichloropropene 62737 Dichlorvos 111422 Diethanolamine 121697 N,N-Diethyl aniline (N,N-Dimethylaniline) 64675 Diethyl sulfate 119904 3,3-Dimethoxybenzidine 60117 Dimethyl aminoazobenzene 119937 3,3-Dimethyl benzidine 79447 Dimethyl carbamoyl chloride 68122 Dimethyl formamide 57147 1,1-Dimethyl hydrazine 131113 Dimethyl phthalate 77781 Dimethyl sulfate 534521 4,6-Dinitro-o-cresol, and salts 51285 2,4-Dinitrophenol 121142 2,4-Dinitrotoluene 123911 1,4-Dioxane (1,4-Diethyleneoxide) 122667 1,2-Diphenylhydrazine 106898 Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106887 1,2-Epoxybutane 140885 Ethyl acrylate 100414 Ethyl benzene 51796 Ethyl carbamate (Urethane) 75003 Ethyl chloride (Chloroethane)



# B-14

# CAS Number Chemical Name 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412
106934 Ethylene dibromide (Dibromoethane) 107062 Ethylene dichloride (1,2-Dichloroethane) 107211 Ethylene glycol 151564 Ethylene imine (Aziridine) 75218 Ethylene oxide 96457 Ethylene thiourea 75343 Ethylidene dichloride (1,1-Dichloroethane) 50000 Formaldehyde 76448 Heptachlor 118741 Hexachlorobenzene 87683 Hexachlorobutadiene 77474 Hexachlorocyclopentadiene 67721 Hexachloroethane 822060 Hexamethylene-1,6-diisocyanate 680319 Hexamethylphosphoramide 110543 Hexane 302012 Hydrazine 7647010 Hydrochloric acid 7664393 Hydrogen fluoride (Hydrofluoric acid) 123319 Hydroquinone 78591 Isophorone 58899 Lindane (all isomers) 108316 Maleic anhydride 67561 Methanol 72435 Methoxychlor 74839 Methyl bromide (Bromomethane) 74873 Methyl chloride (Chloromethane) 71556 Methyl chloroform (1,1,1-Trichloroethane) 60344 Methyl hydrazine 74884 Methyl iodide (Iodomethane) 108101 Methyl isobutyl ketone (Hexone) 624839 Methyl isocyanate 80626 Methyl methacrylate 1634044 Methyl tert butyl ether 101144 4,4-Methylene bis(2-chloroaniline) 75092 Methylene chloride (Dichloromethane) 101688 Methylene diphenyl diisocyanate (MDI) 101779 4,4-Methylenedianiline 91203 Naphthalene



# B-15

# CAS Number Chemical Name 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412
98953 Nitrobenzene 92933 4-Nitrobiphenyl 100027 4-Nitrophenol 79469 2-Nitropropane 684935 N-Nitroso-N-methylurea 62759 N-Nitrosodimethylamine 59892 N-Nitrosomorpholine 56382 Parathion 82688 Pentachloronitrobenzene (Quintobenzene) 87865 Pentachlorophenol 108952 Phenol 106503 p-Phenylenediamine 75445 Phosgene 7803512 Phosphine 7723140 Phosphorus 85449 Phthalic anhydride 1336363 Polychlorinated biphenyls (Aroclors) 1120714 1,3-Propane sultone 57578 beta-Propiolactone 123386 Propionaldehyde 114261 Propoxur (Baygon) 78875 Propylene dichloride (1,2-Dichloropropane) 75569 Propylene oxide 75558 1,2-Propylenimine (2-Methyl aziridine) 91225 Quinoline 106514 Quinone 100425 Styrene 96093 Styrene oxide 1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin 79345 1,1,2,2-Tetrachloroethane 127184 Tetrachloroethylene (Perchloroethylene) 7550450 Titanium tetrachloride 108883 Toluene 95807 2,4-Toluene diamine 584849 2,4-Toluene diisocyanate 95534 o-Toluidine 8001352 Toxaphene (chlorinated camphene) 120821 1,2,4-Trichlorobenzene 79005 1,1,2-Trichloroethane



# B-16

# CAS Number Chemical Name 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412
79016 Trichloroethylene 95954 2,4,5-Trichlorophenol 88062 2,4,6-Trichlorophenol 121448 Triethylamine 1582098 Trifluralin 540841 2,2,4-Trimethylpentane 108054 Vinyl acetate 593602 Vinyl bromide 75014 Vinyl chloride 75354 Vinylidene chloride (1,1-Dichloroethylene) 1330207 Xylenes (isomers and mixture) 95476 o-Xylenes 108383 m-Xylenes 106423 p-Xylenes 0 Antimony Compounds 0 Arsenic Compounds (inorganic including arsine) 0 Beryllium Compounds 0 Cadmium Compounds 0 Chromium Compounds 0 Cobalt Compounds 0 Coke Oven Emissions 0 Cyanide Compounds 1 

# 0 Certain Glycol ethers 2 

# 0 Lead Compounds 0 Manganese Compounds 0 Mercury Compounds 0 Fine mineral fibers 3 

# 0 Nickel Compounds 0 Polycyclic Organic Matter 4 

# 0 Radionuclides (including radon) 5 

# 0 Selenium Compounds NOTE: For all listings above which contain the word “compounds” and for glycol ethers, the following applies: Unless otherwise specified, these listings are defined as including any unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part of that chemical’s infrastructure.
1

# XCN where X = H or any other group where a formal dissociation may occur. For example KCN or Ca(CN)2

# .



# B-17

# CAS Number Chemical Name 

# Appendix B Section 112(b) List of Hazardous Air Pollutants (HAP) U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412

2

# Includes mono- and di- ethers of ethylene glycol (except for ethylene glycol monobutyl ether (CAS Number 111–76–2), -diethylene glycol, and triethylene glycol R–(OCH2CH2)n–OR where

4

# Includes organic compounds with more than one benzene ring, and which have a boiling point greater than or equal to 100°C. 5

# A type of atom which spontaneously undergoes radioactive decay. n = 1, 2, or 3 R = alkyl or aryl groups R = R, H, or groups which, when removed, yield glycol ethers with the structure: R–(OCH2

# CH)n–OH. Polymers are excluded from the glycol category.
3

# Includes mineral fiber emissions from facilities manufacturing or processing glass, rock, or slag fibers (or other mineral derived fibers) of average diameter 1 micrometer or less.



# B-18