Comments of the Aluminum Association on the EPA Issues and Recommendations List
to Revise the Secondary Aluminum Production NESHAP

(40 CFR Part 63 Subpart RRR) May 18, 2010 Reference EPA document: SECAL

- ANPR

- Amendments

- Memo

- 09

- 30

- 09.doc

The following list is a compilation of issues for review and consideration with the EPA memo addressing a draft list of Secondary Aluminum MACT rule improvements (dated 9

- 30

- 09). Also included at the end of this paper is a list of Aluminum Association requested rule c hanges not included or adequately addressed in the EPA list. The list is not presented in order of priority, but follows the listing chronology in the EPA memo.

Issues of Concern

1

. Definition of Clean Charge

– The current definition of clean charge includ es: 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.

Specific types of “ runaround scrap ” materials (generated on

- site by aluminum casting, extrudin g, rolling, scalping, forging, forming/stamping, cutting, and trimming operations) were defined as part of clean charge because this material is routinely processed in furnaces that represent the MACT floor and were a component of the MACT floor emissions testing used to establish furnace emission standards.

Two elements of the definition for clean charge have created interpretation issues. The first is “aluminum scrap known by the owner or operator to be entirely free of paints, coatings, and lubricants” . OECA has stated that some knowledge of the history of the processes applied to the scrap material is necessary for the operator to “know” that scrap material is entirely free of paints, coatings, and lubricants. OECA also believes that visual inspectio n is inadequate to determine whether scrap material is entirely free of paints, coatings, and lubricants. The Association generally accepts OECA’s position, but requests EPA to consider whether some type of sampling and analytical procedure could be used to determine if scrap from outside entities is entirely free of paints, coatings, and lubricants for processing as clean charge.

The second issue deals specifically with aluminum chips generated by turning, milling, boring, and machining of aluminum part s. Aluminum chips are considered clean charge if either thermally dried or treated by a centrifugal cleaner. The Association is satisfied with this definition for cleaned2 aluminum chips. Thermal chip drying is already defined under the rule. EPA
may wa nt to add a definition for “centrifugal cleaner”, although this is generally understood by the industry. 2

. Anodized aluminum

- EPA’s list of improvements for Secondary Aluminum MACT includes the need to exclude anodized aluminum scrap from the definition of clean charge . We believe this is unnecessary because the process of anodizing aluminum simply creates a layer of aluminum oxide on the metal surface, which would not result in HAP emissions when the anodized aluminum is recycled. Most aluminum anodizing d oes not include “dyes” as referenced in the EPA memo. Eliminating “all” anodized aluminum as clean charge will create processing cost increases with no commensurate HAP emission benefits. 3

. Existing and New Source SAPU

– The current definition of “existing SAPU” includes all existing group 1 furnaces and all existing in

- line fluxers within a facility. So, by definition, there can only be one existing source SAPU at each facility. However, the rule allows multiple new SAPUs and redesignation of existing emi ssion units into new SAPUs to address practical issues associated with emissions control systems on secondary aluminum “process trains”. For example, in cases where a melter, holder and in

- line fluxer are all controlled by a single lime

- injected baghouse, these three emission units were redesignated as a “new SAPU” to allow compliance demonstration for all three units by testing of the baghouse stack. Compliance demonstrations for this process train would be far more complicated if the facility could only have “one new source SAPU” as proposed in the EPA memo. Redesignation of existing emission units to form a new SAPU requires prior approval by the permitting authority under §63.1505(k)(6), which was added to the rule as part of a litigation settlement. 4

. S crap Shredders

– It is not clear how the applicability statement for all shredders to be subject to the SMACT rule is intended. The current rule regulates scrap shredders at major sources. If related to area sources, which are D/F related emission concern s, the requirement to regulate area source shredders makes little sense since shredders have no combustion related processing to contribute to D/F formation. Similarly, the statement that all shedders with visible emissions are subject to SMACT is also of concern, as there is no correlation with HAP emissions in such a determination. In addition, there is the concern with reference to Method 22 for visible emissions. The rule currently has no requirements for M22 testing. Finally, an exemption should be provided in the rule for low RPM shredders that do not exhibit fugitive emissions. 5

. Thermal Chip Dryers

– The draft proposes to expand the applicability of thermal chip dryers to add water

- only evaporation from the current definition for a thermal chip dry er. This expands the scope of the affected source and as such would require a reevaluation of the emission standards and possibly a new subcategory

. No data are available on HAP emissions, if any, from units used to evaporate water only from aluminum chi ps.3

6

. Residence Time of an Afterburner

– The draft eliminates as residence time any inclusion of the connected ductwork to the afterburner in calculating the total period for residence time. This is in direct conflict with the rule which allows duct work in the calculation of residence time if a thermal couple located in the duct verifies adequate temperature for D/F destruction. Many afterburners have high performances with lower residence time to reduce fuel consumption. This change would necessitate extr a costs, fuel consumption and GHG emission increases for no commensurate HAP reduction benefits. The rule should provide that the afterburner volume calculation include the firing zone plus combustion zone in refractory lined ductwork up to the control th ermocouple used to demonstrate compliance with the 1,400 degree F requirement. 7

. Capture and Collection Systems

– The memo is currently blank, but refers later to the elimination of the ACGIH Ventilation Manual for guidance on this issue. It is therefore a high priority to develop a reasonable definition under this issue that is workable and cost effective. 8

. SAPU Feed/charge Rate

– We disagree that SAPU emission limit should be calculated based on feed/charge rates during performance test. The total allowab le emissions in the numerator of the Emission Limit calculation in Equation 1 must change each day based on the throughput of charge material processed that day in order to account for group 1 furnaces or filter boxes that did or did not operate on any giv en day. Otherwise, calculated total allowable emissions would be higher than allowed under the MACT standard. 9

. O&M Plans: Capture and Collection Systems

– This is an area of special controversy that requires careful consideration to develop, as noted abo ve, workable and cost

- effective solutions. 10

. O&M Plans: Lime Injection Rate

– the draft includes a daily pound per hour (lb/hr) inspection/verification which for some systems is entirely unnecessary. The current SMACT provisions are adequate

. 11

. O&M Plans: Sc rap inspection

– EPA additions to address correlation of visual inspection with physical measurements must be workable so as not to preclude the viability of the existing scrap inspection programs. 12

. O&M Plans: Molten Metal Level

– It is not clear in the dra ft memo what additional monitoring is necessary. The current rule to assure the arc h of the passageway is submerged thus avoiding gas exchange between the side

- well and furnace hearth is adequate. 13

. O&M Plan Revisions

– The draft requirements for a 3 month time period for approval before any operational changes can be made at a facility is entirely unworkable. It adds an unnecessary burden of facilities and the ability to work efficiently and competitively in the market place, and also adds extra burdens to States and Permit Authorities by expanding their work loads. 14

. O&M Plan Revisions: Hood Flowrates

– The draft requirement for volumetric flowrate testing of hoods is unworkable for many installations. 15

. Performance Testing: Feed/charge Rate

– The dra f t i s not clear in what is being proposed. We agree that testing should be performed at the scrap/charge rate combination that creates the highest emissions potential.4 However, operating scenarios with differing scrap charge characteristics should not be rest ricted to the tested charge rate for higher HAP producing materials. 16

. Performance Testing: Frequency of Testing

– the five year testing period to be clarified should not apply to area sources because of the unnecessary increase in expense for such requir ements. 17

. Performance Testing: Temporary Enclosures

– The requirement fo r temporary enclosures to capture fugitive emissions is not workable, and indeed may create safety issues in conducting such testing. Other means are necessary to

asses s fugitive emissi ons contribution to the overall emission rate. 18

. Testing: Method 22 Testing

– Currently there are no Method 22 requirements in the rule, and the addition of such requirement is unnecessary and adds considerable cost for compliance.

Requested Additional Cha nges to the SMACT Rule

40 CFR 63.1506(c)(1)

– In line with EPA recommendations, delete the requirement to design ventilation systems to ACGIH handbook specifications.

40 CFR 63.1506(d)(1)

– Allow an exception for continuous processes such that the test period and recordkeeping time can be different.

40 CFR 63.1506(m)(4) and (g)(5)

– The lime feeder setting should be adjustable to the level required to meet the lime flow rate established by the performance test, and not subject to OM&M plan revision req uirements.

40 CFR 63.1510(e)

- Allow an exception for continuous processes such that the test period and recordkeeping time can be different.

40 CFR 63.1510(f)(1)(ii)

– Delete the requirement to use “Fabric Filter Bag Leak Detector Guidance” (Sept 1997 d ocument as it is out of date. Substitute with provision to set up per manufacturer’s instructions, and recommended by EPA.

40 CFR 63.1510(j)((4) and (5)

– Allow an exception for continuous processes such that the test period and recordkeeping time can be different.

40 CFR 63.1510(k)(1)

- Allow an exception for continuous processes such that the test period and recordkeeping time can be different.

40 CFR 63.1510(m)(1)

– Revise to provide that the measurement of the molten metal height is obtained at the low point of the furnace cycle, usually following metal tapping.

40CFR63.1511(b)

- Allow 180 days from startup for a new source to conduct the initial performance test(s). This would be consistent with the MACT general provisions (40CFR63.7(a)(2)). It is often difficult and sometimes impossible to achieve full production operation of a regulated source within 90 days.5

40 CFR 63.1511(b)(1)

– Delete the requirement that the testing be performed a t the highest production level. Substitute that the test b e c onducted at t he highest emission/ton level combination. Emissions testing should be performed with the scrap/charge believed to cause the greatest emissions potential and at a production rate representative for that scrap/charge combination. Production r ates established during the hypothetical maximum emissions test should not be restrictive of other lower emitting scrap/charge combinations.

40 CFR 63.1511(b)(2)

– Allow for particulate matter emission test on continuous processes to be one

- hour duratio n.

40 CFR 63.1517(2)

– Allow that records can be maintained on digital media.

Identical Furnaces

– The rule needs to be clarified to allow testing of a representative furnace to establish emission rates for furnaces with the same o r lower HAP emission
po tential.

Furnace Classifications

– furnace classifications are based on the operational characteristics of the furnace. As such, a source should be allowed to define alternative operating scenarios in the OM&M Plan that permit operation as a Group 1 contr olled, Group 1 uncontrolled, or group 2 depending on charge type and flux practices so long as emission limits compliance is demonstrated in performance testing.

Fugitive Emissions

– EPA should recognize that fugitive emissions were not included in the MACT floor emission limits and therefore are not subject to the MACT standard

. Clean Charge

– Provide in the rule that a Purchase Order requiring that scrap is “entirely free of paints, coatings and lubricants” should be acceptable for demonstrating “Cle an Charge” material.

Representative Testing

– Allow representative testing of equipment with Air Pollution Control Devices (APCD).

Control Device Shutdown

– Provision is needed to allow the shutdown of a fabric filter and/or lime injection system if the furnace is idled and not producing HAP emissions. Foe example, after a melting furnace is finished a charging & fluxing cycle, but the unit is standing on hold for the weekend without fluxing or additional charging.

Hood Flows

– Measurement of actual h ood ventilation flows should only be required as part of an emission performance test.

Charge Weight for In

- Series Units

– Equipment installed in an inter

- linked series (e.g. shredder/delacquering kiln/reverbatory furnace) should not be required to conduc t independent input or output charge weight determinations for each piece of equipment. In such equipment, calculated weights should be allowed so long as there is6

demonstration that the calculated weight meets the accuracy requirements in the rule based on the input or output measurement at the beginning/ end of the unit series of equipment.

Cover Flux Definition

– The current definition of cover flux (i.e. salt added to the surface of molten aluminum in a group 1 or group 2 furnace, without agitation o f the molten aluminum, for the purpose of preventing oxidation) must be revised. Incidental circulation to disperse the cover flux over the surface of the molten aluminum should not be considered agitation.

Alternative Operating and Testing Scenarios

– An approved alternative operating or testing scenario should be codified and grandfathered for the facility.

Consent Decree

– Requirements obtained by consent decree for a facility should be grandfathered and not subject to changes in subpart RRR.

Pro duction weight vs. charge weight

– Revise rule to remove restriction in 63.1506 (d)( 3 ) (i) and (ii)

. Rule should allow either feed/charge weight or production weight, as long as the same basis is used for performance test and SAPU compliance calculation.