From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Tuesday, May 27, 2014 4:06 PM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

Rochelle:

All of them would apply to sweat furnaces. See the attached OM&M and SS&M plans for our

furnaces.....

On Tue, May 27, 2014 at 3:16 PM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrote:

We are looking for some “good engineering practices” that sweat furnaces can use to

operate and maintain the overall efficiency of the sweat to minimize emissions, including

fugitive emissions. We have developed a list that w e felt might help the larger

aluminum smelters reduce emissions. Do you think this list is appropriate for sweat

furnaces? If not, which ones would be a problem? Do you have anything extra to add

about the seals or other routine maintenance that they co uld do to keep them running

efficiently and to get the best flow into the furnace while the doors are open?

• Increasing the exhaust rate from the furnace from furnaces with draft fans, so as

to capture emissions that might otherwise escape into the building;

• Minimizing the time the furnace doors are open

• Keeping building doors and other openings closed to the greatest extent

possible to minimize drafts that would divert emissions from being drawn into the

furnace; or

• Maintain burners on low

- fire or pilot operation while the doors are open (not too

sure about this one)

Let me know. Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Monday, May 19, 2014 3:17 PM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

Rochelle:

I am on the road again but can work on that list for you w hen I get back later this week.

Dave

On Mon, May 19, 2014 at 3:04 PM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrote:

Do you have a list of work practices or maintenance checks that they could do to

minimize fugitive emissions so that they are still required to keep up the maintenance of

the furnace even if they can meet the smoke test, but cannot pass the ACGIH

requirement? Also, can you send the list of old and new sweat furnace owners? Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Monday, May 19, 2014 12:22 PM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

Yes, especially my furnaces and any I have modified. We have looked at the fugitive emission

problems on furnaces for years now since many of our furnaces are in facilities where other

processes are being performed. I have never approved of hoods for a solution. I want all the

emissions to be pulled through the afterburner. I have seen instances where proper maintenance

on door seals and refractory has not been performed and we have fugitive emissions. It i s part of

my inspection program to point said lack of maintenance out on my reports and either schedule

the repairs in or instruct them on the proper procedures. In most cases they are keeping up with

everything these days.

Dave

On Mon, May 19, 2014 at 12:09 PM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrote:

So if most furnaces do not have the draft inducer, can most past the smoke test

showing negative pressure in the furnace?

Rochelle Boyd, Env ironmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: ( 919) 541

- 1390 Fax: (919) 541

- 3207From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Monday, May 19, 2014 12:07 PM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

No, most furnaces don't. But when we change an afterburner from a mount directly on the roof of

the furnace to a stand mount and have to make longer runs of breaching pipe from the furnace to

the afterburner, then yes. Al l our new furnaces have the stand mount right next to the furnace

with only a 3' run between the furnace and afterburner. Many existing furnaces rooms do not

have room for the upgrade so we move it outside the building. The average draft inducer install

is around $7,800.00.I prefer this method over using hoods then having to add additional control

equipment for the hoods.

On Mon, May 19, 2014 at 11:18 AM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrot e:

Does most sweat furnaces have a draft inducer? If not, how much does it cost to add

one? Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Divis ion

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Monday, May 19, 2014 10:36 AM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

The Al

- Jon/United was built in 93 but we did major modifications to it 2 years ago. Has 2.1

seconds retention time in the afterburner. The MAX

- 4000 was installed in 08 and has 1.5

seconds retention time. One thing that I have done for low draft types of fu rnaces where we go

positive (less than negative 0.03" wc. in the primary, is to add a draft inducer. Basically it is a

pad mount blower with a pipe with a velocity nozzle that goes in the stack above the afterburner.

It blows air up the center of the stack which increases the draft from the primary.Air is adjusted

by a gate vale and locked into place once we reach 0.15 wc" negative pressure into the

afterburner. That gives us at least 0.06"wc neg. in the primary. This way we can increase the

draft without a ffecting the flows that much but we do not pull all the heat out of the afterburner.

Dave

On Mon, May 19, 2014 at 10:24 AM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrote:

Yes. Thanks, which one wa s the older furnace?

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207From: Dave Conway [mailto: rsidave1@gmail.com ]

Sent: Monday, May 19, 2014 10:19 AM

To: Boyd, Rochelle

Subject: Re: Non

- flammable smoke

That may work. I used a piece of rolled up news paper and the smoke pulled into the door fine.

Here are the test results using an vane anemometer:

Furnace #1 Recycling S ervices/US Furnaces MAX

- 4000 Operating at 1650 deg. F in all

chambers. Total BTU input=4 MMBTU

Primary door: 154 FPM

Holding chamber door: 165 FPM

Furnace # 2 Al

- Jon/United AS 990 with Recycling Services/ US Furnaces upgraded afterburner.

Total BTU input=8 MMBTU

Primary door: 245 FPM

Holding chamber door: 260 FPM

Hope this helps.

Regards,

Dave Conway, Member

Recycling Services International, LLC

US Furnaces, LLC

20 Roosevelt Blvd.

Cohoes, NY 12047

518

- 424

- 1168On Fri, May 16, 2014 at 1:59 PM, Boyd, Rochelle < Boyd.Rochelle@epa.gov > wrote:

Would something like this work? Any way you can try something like this by Monday as

well?

Advertisement

SDI CHEKKIT Handheld Smoke Detector...

•

•

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Progr ams Division

109 T.W. Alexander Dri ve, RTP, NC 27711

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 54 1

- 3207

## US Furnaces Max 4 000

Operation, Maintenance and Monitoring Plan

Complete Operating Instructions (SOP)

Turn power and main gas valves on and record the gas meter reading.

Raise all doors and inspect all chambers.

1. Start com bustion blowers. Start “Primary 1”, “Primary 2” “Holding chamber” and

“Afterburner burners” by turning the selector switches to the on position. There is

a 2 minute built in purge prior to ignition. Observe that each burner did in fact

ignite by observing burner on lights and physically observing the flame by sight.

2. Close all doors.

3. Prepare work area for production day.

4. Install the afterburner data logger.

5. Select material to be charged and load on the table. Note: Refer to “Items not to be

charged into the chamber” as described by the permit, i.e. magnesium, cadmium,

radioactive, PCB’s, PVC’s, etc. materials.

6. When the afterburner temperature has reached at least 1600 deg. F and the

primary and holding chamber have reached the desired set point the furnace ma y

be charged.

7. The afterburner temperature is recorded as 15

- minute block averages and also 3

- hour block averages by a data logger.

8. Turn the “Hi

– Low Fire” switch to low. Raise the primary charge door and push

material into the chamber.

9. Close the door and observe the temperature controls. Note: Specifically observe

that the afterburner chamber did not drop below 1600 deg. F. If said chamber does

drop below the required temperature, the set point will need to be raised to

prevent a violation during the time the door is open. The standard set point is

1650 deg. F to prevent a violation.

10. Record the charge time, material type, afterburner temperature and the size of the

load in the “Daily Operators Log”.

Note: This unit is equipped with an interlock system th at prevents the primary

charge door from being opened should the afterburner temperature drop below

1600 degrees. There is however, a manual override switch which will allow the door

to operate under any temperature condition. This mode is primarily used f or

maintenance only. A red light on the control panel indicates that the interlock is in

the manual mode. Do not charge material into the chamber if the red interlock light

is illuminated.2

Turn the “Hi

- Low Fire” switch to high after most of the comb ustib le material has burned

off (if automatic high fire delay , turn to high as soon as door is closed). Stir and rake the

material as required by the material being processed. Average stir time is 10 to 15

minutes after charging the load. An additional stir and preliminary rake is usually

required within 5 to 10 minutes. Average final rake out time is 25 to 40 minutes after

charging. Record all stir and rake times on the “Daily Operators Log”.

11. Observe temperature controls throughout the operating day to assure p roper

operation of all chambers.

12. Observe the exit of the stack for emissions after each charge and make the proper

adjustments to the draft controls if necessary.

13. Drain the holding chamber as necessary. Note: Follow all required safety

procedures during th e draining of the holding chamber.

14. When process day is complete, turn off all burners and leave the combustion fans

on until the temperature has dropped below 500 deg. F.

15. Turn off the main gas valve.

16. Clean all chambers thoroughly.

17. Record the weight of mate rial processed on the daily log sheet.

Spare Parts On Hand

Refer to the recommended spare parts list for items that need to be in your inventory. Add

a spare Tc

- hr data logger to that list. Keep an inventory list of parts on hand.

Maintenance Schedule

Furnace is to be maintained and records kept of the following:

1. Daily & Weekly Inspection and Maintenance

Daily

- Grease Sow Mold Wheels (if applicable).

a) Inspect all chambers for refractory damage and repair as needed.

b) Inspect door raise cab les for wear and replace if needed.

c) Inspect burner tube areas for blockage.

d) Clean blower fans.

e) Adjust door seal (adjust the next day after replacing)

f) Inspect all hydraulic hoses, connections, seals, and cable sheaves (rollers).

2. Bi

- weekly Insp ection and Maintenance

a) Remove and clean igniters.

b) Inspect ignition cable and replace when necessary.

c) Clean UV Scanners.

d) Grease door raise bearings and draft control pillow block bearings

. e) Oil any unsealed type motor bearings.3

3. Monthly Inspection and Maint enance

a) Inspect and repair any structural area of the furnace.

b) Inspect and/or repair tap

- out hole and spout.

c) Inspect and repair afterburner and stack refractory.

d) Perform leak test on all gas lines.

4. Semi

- Annual Inspection and Maintenance if required (to be performed by RSI)

a) Calibrate all controls and data logger.

b) Inspect afterburner structural refractory areas.

c) Inspect structural areas

. d) Inspect, clean and service all burners.

e) Adjust all burner settings.

f) Observe overall furnace operation

. g) Check data logge r records.

h) Operators training refresher course is performed and training certificates are

issued where appropriate.

5. Annual Inspection and Maintenance (to be performed by RSI)

a) Inspect all burners, pilot light assemblies, and pilot light sensing devices for

proper operation.

b) Clean the pilot light sensors.

c) Inspect the combustion air for proper adjustment.

d) Inspect baffles and other internal structures to ensure their structural integrity.

e) Inspect dampers, fans, and blowers for proper operation.

f) Inspect for proper sealing.

g) Inspect motors for proper operation.

h) Inspect the refractory lining of the combustion chamber. Clean and replace the

refractory lining as necessary.

i) Inspect the shell of the afterburner for corrosion and hot spots.

j) For the burn cycle that f ollows the inspection, document the proper operation of

the afterburner. Document adjustments to the afterburner.

k) Verify that the afterburner is in good operating condition.

l) Follow the operation, maintenance and monitoring plan when making repairs.4

Moni toring

1. Afterburner temperature is recorded as 15

- minute block averages and also3

- hour

block averages by a data logger.

2. Retain data logger floppy discs for five (5) years.

3. Manually record the temperature on the Daily Operators Log when recording the

charge time and material.

4. Maintain a log of repairs performed and any periods of visible emissions.

5. If the temperature goes below 1600°F in the afterburner, follow the procedures in the

Startup, Shutdown and Malfunction Plan, including completing the Malfunction

Report with specifics on the date and time of emissions exceedance and corrective

action taken.

## US FURNACES MAX 4 000

Startup, Shutdown and Malfunction Plan

Startup

1. Record the gas meter reading before starting the furnace.

2. Visually inspect furnace for any broken equipment or items in need of repair.

3. Turn furnace primary holding and afterburners o n.

4. Allow for afterburner termperature to reach 1600° F.

5. Begin loading scrap alumimum in the primary chamber, not exceeding permit limits.

Shutdown

1. After molten aluminum is poured into molds for the day, turn off furnaces for the

primary, holding and afte rburners.

2. Record the gas meter reading after turning off furnace.

3. After primary chamber has cooled, remove all none aluminum metals.

4. Weigh, number and record all molds poured.

Complete Operating Instructions (SOP)

Turn power and main gas valves on and re cord the gas meter reading.

Raise all doors and inspect all chambers.

1. Start combustion blowers. Start “Primary 1”, “Primary 2” “Holding chamber 1”,

“Holding chamber 2” and “Afterburner burners” by turning the selector switches

to the on position. Observ e that each burner did in fact ignite by observing burner

on lights and physically observing the flame by site.

2. Close all doors.

3. Prepare work area for production day.

4. Install the afterburner data logger.

5. Select material to be charged and load on the table. Note: Refer to “Items not to be

charged into the chamber” as described by the permit, i.e. magnesium, cadmium,

radioactive, PCB’s, PVC’s, etc. materials.

6. When the afterburner temperature has reached at least 1600 deg. F and the

primary and holding chamber have reached the desired set point the furnace may

be charged.

7. T he afterburner temperature is recorded as 15

- minute block averages and also 3

- hour block averages by a data logger.

8. Turn the “Hi

– Low Fire” switch to low. Raise the primary charge door and push

material into the chamber.

9. Close the door and observe the temperature controls. Note: Specifically observe

that the afterburner chamber did not drop below 1600 deg. F. If said chamber does2 drop below the required temperature, the set point will need t o be raised to

prevent a violation during the time the door is open. The standard set point is

1650 deg. F to prevent a violation.

10. Record the charge time, material type, afterburner temperature and the size of the

load in the “Daily Operators Log”.

11. Turn th e “Hi

- Low Fire” switch to high after most of the combustible material has

burned off. Stir and rake the material as required by the material being processed.

Average stir time is 10 to 15 minutes after charging the load. An additional stir

and preliminary rake is usually required within 5 to 10 minutes. Average final

rake out time is 25 to 40 minutes after charging. Record all stir and rake times on

the “Daily Operators Log”.

12. Observe temperature controls throughout the operating day to assure proper

operati on of all chambers.

13. Observe the exit of the stack for emissions after each charge and make the proper

adjustments to the draft controls if necessary.

14. Drain the holding chamber as necessary. Note: Follow all required safety

procedures during the draining of the holding chamber.

15. When process day is complete, turn off all burners and leave the combustion fans

on until the temperature has dropped below 500 deg. F.

16. Turn off the main gas valve.

17. Clean all chambers thoroughly.

18. Record the weight of material processe d on the daily log sheet.

Possible Malfunctions and Corrective Actions

For all malfunctions:

 Record the date and time the malfunction began and ended in the Malfunction Log.

 Record the corrective actions taken including the date and time the correctiv e

action(s) began and when it was completed.

1. Burner will not light or stay lit and or chamber will not reach set

- point temperature:

a) Check that combustion blower is on and the airflow switch has closed to allow

line voltage to the flame safety device. I f blower is not operating check fuses or

circuit breakers. If voltage is supplied to the motor and still does not work, replace

the motor.

b) Check flame safety relays for proper operation and replace if necessary.

c) Check flame rod for proper operation and cle an or replace if necessary.

d) Check ignition electrode for proper operation and clean or replace if necessary.

e) Check reset button on flame safety device for proper operation.

f) Check that the proper gas supply is present and all valves are open.

2. Control do es not display the temperature:

a) Check fuse and power to the control.3

b) If there is power at the control and still no temperature readout, perform the

following test: Remove “positive” and “negative” thermocouple leads from the

back of the control. Install a jumper wire between the terminals that the wire was

removed from. Observe the digital display for an ambient temperature display. If

the display is present refer to item c.

c) Remove temperature probe and remove the element from the probe housing.

Inspect the element for signs of damage or breaks. Check housing for pitting or

burnout. Replace damaged items if necessary.

d) If there is still no temperature display after following items a, b, & c instructions,

replace and program a new temperature control.

e) Do not o perate the sweat furnace until the new data logger is installed and

operational.

3. Data logger did not record temperatures properly or no readings whatsoever.

a) Observe the afterburner control temperature readout. If no digital display is

present, follow the instruction for problem number 2. Note that the afterburner

temperature probe has a double element, one for the control and one for the data

logger.

b) Check all connections from the probe to the data logger.

c) Refer to the “Daily Operations Log” to see tha t furnace was operating during the

temperature recording period.

d) Check that the data logger was “Started” when connected to the computer using

the Omni Log software management program.

e) Check logger while connected to the computer for proper temperature ran ge and

type (as in C or F).

f) Check internal battery power while connected to the computer.

g) Program and install. Run the logger for a two hour test. Remove logger and

download information to check for proper operation. Reinstall logger.

h) Program and install t he backup logger if necessary.

4. Visible emissions are present out of the stack.

a) Turn “Hi

- Low” switch to the low position.

b) Turn the primary burners to the off position if smoke is still present.

c) Open the afterburner draft door to a 4” opening. Note: Close t he afterburner

draft door when combustible material is not present to prevent over cooling of

the afterburner.

d) Check material to find the source of excessive emissions and remove from all

future charges.

e) Record the time and duration of excessive emissions in the “Daily Operators

Log”.

f) Note and record the afterburner temperature in said log.

5. Data logger records values less than 1600°F.

a) Noticed by the operator reading the digital temperature at the controller.

b) Could occur due to a blown fuse in the burner or low air flow in the burner.4

c) Follow the corrective actions under item 1 above.

d) Record the corrective action taken to bring the temperature back up to 1600°F.

e) Record the date and time the corrective action began and the time it was

completed on the Malfunct ion Log.

6. If the malfunction is not identified here, modify this report within 45 days of the

malfunction to include it and the corrective actions.

a) If emissions standard was exceeded, report the malfunction within 2 days to the

VADEQ.

b) Submit a letter wit hin 7 working days explaining the circumstances of the event,

the reasons for not following this plan and whether or not any excess emissions

and/or parameter monitoring exceedances have occurred.

Emergency Shutdown (in the event of interrupted gas supply , gas leak, or power

outage)

1. Turn off main electrical supply and gas supply and empty the molten aluminum.

2. Contact supervisor.

3. Supervisor is to contact the appropriate utility for leak checks or explanation of

interrupted service.

4. Keep records of service interruptions and make notes on data logger spreadsheets

should the afterburner temperature drop prior to the batch process completion

## MALFUNCTION LOG

Type of Malfunction and

Cause Date and

Time of

Malfunction Date and Time

Corrective

Action Began Date and Time

Corrective

Action Ended Corrective Action

Taken