June 8, 2010

Memorandum

Subject: Summary of Meeting of with Aluminum Associ ation Representatives

From: David Green and Mark Bahner, RTI

To: Rochelle Boyd, EPA/OAQPS

I. Purpose

The purpose of the meeting was to discuss Aluminum Association Representatives’

comments on EPA's draft information collection requ est in support of the Risk and Technology

Review of the Secondary Aluminum Production NESHAP. EPA personnel stated that they

would not formally respond to each comment, but wou ld consider all the comments when

drafting the next version of the information collec tion request.

II. Place and Date

The meeting was held at the U. S. Environmental Pr otection Agency (EPA), 109 T.W.

Alexander Drive, Research Triangle Park, NC 27711 between 11:00 am and 3:00 pm on May

19, 2010. The meeting was continued by teleconfere nce on May 26, 2010 between 2:00 and

3:00 pm.

III. Attendees

See Attachment 1.

IV. Meeting Summary

A meeting agenda is included at Attachment 2.

A. Aluminum Association membership

The Aluminum Association (AA) represents about 35 secondary aluminum producers and

about 20 primary aluminum or "fully integrated" pro ducers. No sweat furnaces are operated by

any of their members. Association members produce about 80% of the secondary aluminum in

the U. S., although they represent a much smaller p roportion of the ~400 facilities thought (by

EPA) to be subject to the secondary aluminum produc tion NESHAP. AA representatives2

identified the Institute of Scrap Recycling Industr ies as a possible means of communicating with

sweat furnace operators.

B. Technology Review

EPA personnel described plans for the technology r eview and information from industry

that would be useful concerning types of equipment and practices that may be used although not

required by the NESHAP. The use of ceramic filter bags in bag houses, and the replacement of

sweat furnaces with eddy current separators were gi ven as examples.

C. Confidential business information

In order to assess residual risk on the basis of e mission rates permitted by the current

NESHAP, data on throughput for individual affected sources would be used. This is a result of

the production based (mass emitted/mass charged or produced) standards promulgated for most

affected sources and pollutants in subpart RRR. Ce rtain industry representatives stated that some

charge rate and production rate information may be considered confidential. Industry

representatives stated that production limits on an individual unit-by-unit basis, and meaningful

unit-by-unit capacity data are rarely included in a ir pollution permits or other publically

disclosed reports. Some companies also considered information related to how much scrap they

buy to be confidential. Limits on facility wide pr oduction are often available. Industry

representatives considered nameplate capacity of pa rticular units to be of no use as actual

production is limited by the type of charge and the rate of casting, among other factors. EPA’s

policy on protecting confidential business informat ion was discussed. A draft transmittal letter

for an information collection request (Attachment 3 ) and enclosures describing what EPA

considers to be confidential business information, how EPA protects confidential business

information, and EPA's authority to collect informa tion were distributed (Attachments 4 through

6).

D. Speciated organic HAP and particulate metal HAP emissions data

EPA's risk modeling approach depends on HAP-specif ic emissions, while the NESHAP

generally has limits for surrogate pollutants. (e.g ., particulate matter (PM) for metal HAP and

total hydrocarbon (THC) for organic HAP (other than dioxin/furan) from certain affected

sources). Therefore, EPA plans to require selected companies to provide these HAP-specific

data. Some industry representatives expressed conc ern about the cost and utility of required

testing, and stated that these data were provided f rom facilities equipped with MACT control

devices in information gathering during the develop ment of the NESHAP (approximately 1990

to 1996). No data on hexavalent chromium were obt ained at that time. Industry representatives

stated that some speciated organic HAP emissions da ta (as well as HF) emissions data were

provided to EPA at that time. Industry representat ives also questioned the need to test and

analyze samples from multiple identical affected so urces equipped with identical control devices.

E. Approach to estimating risk from HF emissions r esulting from use of fluorinecontaining fluxes

The NESHAP contains no emission limits for HF. I ndustry representatives suggested

that F would be emitted at a much lower fraction of usage than Cl because it is more likely to

remain in the dross. Industry representatives also stated that some useable HF emissions data3

were obtained in the testing program conducted as p art of the development of the NESHAP

(1990-1996), and that HF presented a much lower tox icity than HCl.

F. Capture and ventilation requirements

In response to industry questions EPA stated that they planned to amend the NESHAP to

remove ventilation requirements based on the Americ an Congress of Government Industrial

Hygienists, but had not yet finalized details of wh at would be proposed to replace it.

G. Industry comments on draft information collect ion request

A draft information collection request, annotated with comments compiled by the

Aluminum Association is included as Attachment 7.

cc: Robert Strieter, VP EHS, The Aluminum Associati onAttachment 3, p. 1

Mr. XXXXXXXX , President

XXXXXXXX

XXXXXXXX

XXXXXXXX

Re: Requirement to provide i nformation according to 42 U.S.C 7414

Dear Mr. XXXXX :

Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Envi ronmental Protection

Agency (EPA) is requesting that you provide the information described in Enclosures 1 and 2.

At EPA, an important step in the development of regulation s involve s gathering and analyzing

information. We are s eeking information specifi c to your company ’ s facilit ies because such

information is key to understanding how an industry operates, and what facilities do and/or can

do to reduce, mitigate, or eliminate air pollution. We are requesting that you send the completed

surveys for all o f your facilities that are in the secondary aluminum production source category

(see 40 CFR 63, subpart RRR ) to us by XXXXX X, 20XX

. The Clean Air Act (42 U.S.C. 7414 )

requires that you complete the enclosed survey s a n d return t hem to us by the deadline

.

T he EPA issued national emission standards for hazardous air pollutants (NESHAP) for

secondary aluminum production under s ection 112 (d) of the C A A on March 23 , 200 0

. We are

now in the process of collecting updated information concerning hazardous air pol lutant ( HAP )

emission sources and controls in the secondary aluminum industry. This information will be

used as the basis for evaluating post

- MACT residual risk and control technolog ies as well as to

develop possible revised or additional standards as may be required by sections 112(d)(6) and

112(f) of the CAA

.

In the enclosed survey s , we request information on secondary aluminum processes,

emissions, and controls. Enclosure s 1 and 2 are the survey forms that you are required to

complete and return to u s in electronic format

. If we presently have National Emissions

Inventory ( NEI ) data for you r facility, the excel spreadsheet (Enclosure 2) will be populated with

existing data for your facility. Y o u will need to revise and update the existing data as well as

complete any missing information. Enclosure 3 contains the instructions for completing

Enclosures 1 and 2. Enclosure 8 is the compact disc containing the electronic forms.Attachment 3, p. 2

Using th e information you provide to us in th i s survey

, along with similar information we

receive from other companies in your industry

, we will determine the amount of HAP s emi tted ;

the present level of emission control ; and assess what would be the environmental, energy, and

economic impacts associ ated with installing and operating emission control techniques feasible

for your industry

. You may respond “ Not Applicable ” to questions that do not apply to your

facilities.

Enclosure 4 c ontains a summary of our legal authority in s ection 114 of the C AA to

obtain the information requested in th i s survey. If you believe that providing any specific

information to us would reveal a trade secret, please identify this information clearly in your

response

. However, p lease do not label your entire response “ Confidential ” if only a portion

include s trade secret s

. You can see in Enclosure 4 the type of information that EPA may ask of

you at a later time to prove that any information you have so identified is truly confidential. Any

information determined to be a trade secret will be protected by 18 U.S.C. 1905. If you do not

claim as confidential any of the information in your returned survey

, we can make th is

information available to the public without noti fying you further (40 CFR Part 2.203,

September 1, 1976).

Because s ection 114 of the CAA does not allow emission data to be claim ed as
confidential, the emission data you provide to us can be made available to the public. A detailed

explanation of what we consider to be emission data is contained in En closure 5

.

We ha ve contracted RTI International (RTI) (Contract No. EP

- D

- 06

- 118) to help us

gather information about your industry. A s noted in Enclosure 6

, we have designated RTI to be

our authorized representative. Therefore, RTI has the same rights discussed above and in

Enclosure 4 as EPA has

. This means that RTI will have access to all information provided to us

in your completed survey

. As a designated representative of the Agency, RTI must, by law, also

abide by the requirements of 42 U.S.C. 74 14(c) in regard to the confidentiality of what you claim

to be trade secrets.

Enclosure 7 summarizes our policies and procedures for handling trade secret information

and describes how our contractor also is required to use the same procedures as we do. Because

our contractors or other authorized representatives are required to follow the requirements in

Enclosure 6 , we believe that we can ensure your rights and protect any privileged information

you submit to us.

Drafts of Enclosure 1 and 2 were given to representatives of your industry for their

comments. We have incorporate d several of their comments and suggestions into the final

version. If you have questions regarding the need for this survey or need clarification on the

information we are reque st ing , please contact Rochelle Boyd with EPA ’ s Office of Air Quality

Planning and Standards at 919

- 541

- 1390 (e

- mail : boyd.rochelle @epa.gov).Attachment 3, p.3

Please return the completed survey form(s) to M s

. Boyd at the address below by XXX

XX

, 20 XX

.

Rochelle Boyd

U

. S

. EPA Mailroom (D243

- 02)

U .S. Environmental Protection Agency

Office of Air Quality Planning and Standards

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

If your response to this information collection re quest includes data with a claim of

confidential business information , p lease create a separate CD

- ROM or DVD

- ROM containing

only the spreadsheet with the CBI portion of your data . Clearly mark the disk with the words

“Confidential Business Information.” Send only these CBI files under separate cover to:

Roberto Morales

c/o Rochelle Boyd

U.S. EPA Mailroom (C404

- 02)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

109 T.W. Alexander Drive

Research Triangle Pa rk, NC 27711

For security of your data, EPA recommends sending your confidential files to Mr.

Morales via Registered U.S. Mail using return receipt requested, Federal Express, or other

method for which someone must provide a signature upon receipt.

DO N OT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION

TO EPA. E

- mail and facsimile are not secure forms of communication and should never be used

to transmit CBI.

I am sure you understand how important it is for the EPA to use the very best inform ation

available to develop the most meaningful standard. Your help in providing this information is

greatly appreciated.

Sincerely,

Peter Tsirigotis

Director, Sector Policies and Programs Division

Office of Air Quality Planning and StandardsAttach ment 3, p. 4

8 Enclosures

Enclosure 1: NESHAP for Secondary Aluminum Emissions Request

Enclosure 2: Emissions Database Update

Enclosure 3: Instructions for completing Enclosures 1 and 2

Enclosure 4: EPA’s information gathering a uthority

Enclosure 5: Clari fication of what EPA considers to be emissions data

Enclosure 6: Summary of contractor’s authority as representative of EPA

Enclosure 7: Procedures for safeguarding CBI under the CAA

Enclosure 8 : Compact Disc containing electronic versions of Enclosures 1 and 2

cc: XXXXX

State Agency

XXXXXXX

U.S. Environmental Protection Agency, Region XX

OAQPS/SPPD/MMG: RBoyd D243

- 02, 541

- 1390

(RTI/ MBahner

/ 541

- 6016 / 3 / 23/10 )Enclosure 51 Enclosure 5

1. Purpose

This memorandum describes Agency policy and procedures set forth for the handling of

information claimed as Confidential Business Information (CBI), whether submitted voluntarily

or obtained under Section 114 of the Clean Air Act (CAA), and governed by U.S. Environmental

Protection Agency (EPA) regulations in 40 Code of Federal Regulations (CFR), Part 2, Subpart

B, and other EPA regulations and policies.

2. Reference Documents:

a. Clean Air Act as amended.

b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information.

c. EPA Information Security Manual.

d. Clean Air Act Confidential Business Information Security Manual (January 2002)

3. Exception:

This document was prepared as a summary of data gathering and handling procedures

used by the OAQPS, EPA. Nothing in this document shall be construed as superseding or being

in conflict with any applicable regulations, statutes, or policies to which EPA is subject.

4. Definition:

Confidential Business Information - Information claimed by the provider to be

confidential. This information may be identified with such titles as trade secret, secret,

administrative secret, company secret, secret proprietary, privileged, administrative confidential,

company confidential, confidential proprietary, or proprietary. NOTE: These markings should

not be confused with the classification markings of National Security information identified in

Executive Order 11652.

5. Background

Section 114 (c) of the Clean Air Act as amended reads as follows: January 20022 “Any records, reports, or information obtained under subsection (a) shall be available to the

public, except that upon a showing satisfactory to the Administrator by any person that records,

reports, or information, or particular part thereof (other than emission data), to which the

Administrator has access under this section if made public, would divulge methods or processes

entitled to protection as trade secrets of such person, the Administrator shall consider such

records, report, or information or particular portion thereof confidential in accordance with the

purposes of Section 1905 of Title 18 of the United States Code, except that such record, report,

or information may be disclosed to other officers, employees, or authorized representatives of the

United States concerned with carrying out this Act or when relevant in any proceeding under this

Act.”

The treatment of CBI by EPA, including da ta obtained under Section 114 of the Clean

Air Act, is governed by 40 CFR, Part 2. These regulations require EPA offices to include a

notice with each request for information to inform the business of: (1) its right to assert a claim

of confidentiality covering part or all of the information, (2) the method for asserting a claim,

and (3) the effect of failure to assert a claim at time of submission. In addition, the regulations:

(1) set forth procedures for the safeguarding of confidential information; (2) contain provisions

for providing confidential information to authorize representatives; (3) contain provisions for the

release of information to the Congress, Comptroller General, other Federal agencies, State and

local governments, and Courts; (4) permit the disclosure of information within EPA to

employees with an official need for the information; and (5) prohibit wrongful use of such

information and cite penalties for wrongful disclosure. Further, the regulations contain the

Agency’s basic rule concerning the treatment of requests for information under the Freedom of

Information Act (5 U.S.C. 552).

6. Procedures:

a. Request for Information

Each request for information made under the provisions of Section 114(a) is signed by

the Division Director. The request includes sta ndard enclosure “EPA’s Information Gathering

Authority under Section 114 of the Clean Air Act,” which was designed to meet the requirement

of 40 CFR Part 2 discussed above.

b. Receipt of CAA Confidential Business Information

Upon receipt of information for which confidential treatment has been requested, the

OAQPS Document Control Officer (DCO) logs in the material and a permanent file is

established. If part of the material is claimed to be confidential, that portion should be marked

“Subject to Confidentiality Claim.” In co mpliance with Sections 2.204 and 2.208 of 40 CFR

Part 2, the Group Leader responsible for the requested information reviews the information to

determine the validity of the confidentiality claim as prescribed by the sections. If the

information is clearly not confidential, the Group Leader prepares a letter for the signature of the

responsible Division Director to notify the business of this finding. Information claimed as

confidential is hand carried to the OAQPS CBI Office to be logged into the OAQPS CAA CBI

tracking system and filed for safekeeping. The OAQPS CAA CBI tracking system provides a3 brief description of the material (submitter, subject, number of pages, etc.), identifies it with the

correct project number, or work assignment number, and lists those persons who are authorized

to have access to the information. A record of personnel accessing the information (Attachment

A) is also kept on filed. By regulation, confidential information must be so marked or

designated by the originator. EPA takes additional measures to ensure that the proprietary

designation is uniformly indicated and immediat ely observable. All unmarked or undesignated

information (except as noted below) may be authorized for public release.

c. Storage of CAA Confidential Business Information

Folders, documents, or material containi ng CAA CBI (as defined) shall be secured,

within the confines of the instructions listed in the OAQPS Security Manual. In addition, the

CBI storage area that has been identified specifically for that purpose and equipped with a

supplementary locking device. The storage area and files are under the direct control of the

OAQPS DCO.

Access to the storage area is limited to the Document Control Officer DCO, Document

Control Assistant (DCA) and the minimum number of persons required to effectively maintain

normal business operations as directed by th e Director, Planning, Resources and Regional

Management Staff (PRRMS).

Files may be issued upon confirmation that the requesting individual is authorized to

receive the information. All confidential files must be returned no later than close of business on

the same day. The intended user must sign the CBI Control Record when checking out files.

Individuals signing out confidential files are responsible for their safekeeping. Files must

never be left unattended. The information must not be disclosed to any non-authorized

personnel.

Storage procedures for CAA CBI by an author ized representative of EPA (see Section d.

below) must be, at a minimum, as secure as those established for EPA offices within OAQPS.

Whenever CBI is removed from the EPA files to be transmitted to an authorized representative, a

notation is made in the file’s control record and transfer log indicating what information was

transmitted, the date, and the recipient. The authorized representative returns a signed receipt to

the DCO.

d. Access to CAA Confidential Business Information

Only authorized EPA employees may open or distribute CAA CBI.

Only employees who require, have a need to know and are authorized access to CAA

CBI in the performance of their official duties are permitted to review documents and, upon

receiving a confidential document, must sign and date the form shown in Attachment A to certify

their access to the document.

The Group Leader having primary responsibility for the CAA CBI provides a

memorandum to the DCO designating those personnel authorized to access specific CBI. No4 person is automatically entitled to access based solely on grade, position, or security clearance.

The names of persons granted access to CAA CBI are placed on the CAA CBI access list. The

CAA CBI access list indicates the “specific” CBI each person is permitted to see. The Access

List is reviewed and updated periodically.

Companies under contract to perform work for the EPA may be designated authorized

representatives of EPA. As authorized representatives, contractors may be granted access to

CAA CBI. The following conditions apply when it has been determined that disclosure is

necessary:

(1) The contractor designated as a representative and its employees (a) may use such

confidential information only for the purpose of carrying out the work required, (b) must refrain

from disclosing the information to anyone othe r than EPA without having received from EPA

prior written approval of each affected business or of an EPA legal office, and (c) must return to

EPA all copies of the information (and any abstracts or excerpts there from) upon request or

whenever the information is no longer required for the performance of the work.

(2) The authorized contractor designated as a representative must obtain a written

confidentiality agreement from each of its empl oyees who will have access to the information.

A copy of each employee agreement (Attachment B) must be furnished to EPA before access is

permitted.

(3) The contractor designated as an authorized representative must agree that the

conditions in the contract concerning the use and disclosure of CAA CBI are included for the

benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary

interest in the information.

Information may be released to or accessed by EPA employees other than OAQPS

employees only upon approval of the Director, PRRMS.

Requests for CAA CBI from other Federal agencies, Congress, the Comptroller General,

Courts, etc., are processed in accordance with 40 CFR 2, Subpart B.

Requests under the Freedom of Information Act (FOIA) are handled in accordance with

40 CFR 2, Subpart A. The Freedom of Information Act Coordinator must be consulted prior to

responding to any request for information if a claim of confidentiality has been asserted or if

there is reason to believe that a claim might be made if the business knew release was intended.

e. Use and Disclosure of CAA Confidential Business Information

The CAA CBI as defined may not be used in publications, supporting document,

memoranda, etc., that become a part of the public domain, except as provided for in 40 CFR 2

Subpart B. CAA CBI may not be summarized without the approval of the Group Leader

responsible for the CAA CBI. Any authorized reproductions must be logged into the CAA CBI

document tracking system and treated according to the same procedures applicable to the

original confidential material. Documents, materials, or extracts of information generated by5 EPA which contain CAA CBI must be stamped “S ubject to Confidentiality Claim” and a cover

sheet must be attached to identify the material as CBI.

f. Handling of Other Information

Reports, memoranda, documents, etc., prepared by EPA or its authorized representatives

are not normally circulated outside EPA for comment or review prior to publication except in

such cases as described in section 6 above. However, because industrial-data-gathering visits,

plant inspections, and source testing can involve inadvertent receipt of CAA CBI, it is the policy

of OAQPS to protect all parties involved in the following manner:

(1) Prior to or at the inception of a plant inspection, data-gathering visit, or source test,

EPA or its authorized representative discusses with a responsible industry official the

information sought, how it is to be used, and how it is to be protected. A copy of this summary

is usually provided to the industry official being consulted.

(2) Following an inspection, visit, or test, a trip report is prepared to include, as

practicable, all information received by EPA or its authorized representative during the visit or

test. The report may be prepared by either EPA or its authorized representative. The draft report

is clearly identified, with an attached, yellow c over sheet. A second copy of the draft trip report

is forwarded by EPA to the responsible industry official for review. The responsible industry

official is requested by cover letter to review the report, clearly mark any information considered

to be confidential, and return the marked up-report to the responsible EPA employee within the

time specified. The original draft is kept in the CBI file until the marked-up copy is returned by

the business firm.

(3) When the reviewed copy of the report, as marked by the responsible plant official, is

received by EPA, information designated confidential is placed in the CBI files as described

above. The original draft of the trip report is ed ited to delete the confidential information and the

trip report is authorized for release.

Attachments (2)* Section 114 requires public availability of all emission data and authorizes disclosure of confidential

information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 1976)

(Rev. 12/8/95) Enclosure 2

EPA’s Information Gathering Authority

Under Section 114 of the Clean Air Act

Under Section 114 of the Act (42 U.S.C. 7414), Congr ess has given the U.S. Environmental Protection

Agency broad authority to secure information needed “for the purpose of (i) developing or assisting in the

development of any implementation plan under Sec tion 1 1 0 or 111(d), any standard of performance under

Section 111, or any emission standard under Section 112, (ii) determining whether any person is in violation of

any such standard of any requirement of such a plan, or (iii) carrying out any provision of this Act.” Among other

things, Section 114 authorizes EPA to make inspections, conduct tests, examine records, and require owners or

operators of emission sources to submit information reasonably required for the purpose of developing such

standards. In addition, the EPA Office of General Coun sel has interpreted Section 114 to include authority to

photograph or require submission of photographs of pertinent equipment, emissions, or both.

Under Section 114, EPA is empowered to obtain information described by that section even if you

consider it to be confidential. You may, however, re quest that EPA treat such information as confidential.

Information obtained under Section 114 a nd covered by such a request will ordinarily be released to the public

only if EPA determines that the information is not entitled to confidential treatment. * Procedures to be used for

making confidentiality determinations, s ubstantive criteria to be used in su ch determinations, and special rules

governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the Federal Register

on September 1, 1976 (40 FR 36902).

Pursuant to §2.204(a) of EPA’s Freedom of Informati on Act (FOIA) regulation, in the event a request is

received, or it is determined that a request is likely to be received, or EPA desires to determine whether business

information in its possession is entitled to confidentia l treatment even though no request for release of the

information has been received, please be advised that EPA will seek, at that time, the following information to

support your claim as required by §2.204( e)(4) of EPA’s FOIA regulations:

1. Measures taken by your company to guard agains t undesired disclosure of the information to others;

2. The extent to which the information has been disclosed to others, and the precautions taken in

connection therewith;

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, and a copy of any

such determinations, or reference to it, if available; and

4. Whether your company asserts that disclosure of the information would be likely to result in

substantial harmful effects on the business’ competitive positi on, and if so, what those harmful effects would be,

why they should be viewed as substantial, and an expl anation of the causal relationship between disclosure and

such harmful effects.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 1 of 2 9

S econdary Aluminum (40 CFR part 63, subpart RRR)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

Aluminum Association Comments 5/17 / 20 10

Aluminum Association c omments to the Section 114 survey form included in red text as follows

.

Gene ral Comments

Survey should specify that it is applicable to RRR regulated sources only.

Purpose of the survey should be stated upfront.

An estimate of the number of participating facilities should be included, or added to the

instructions.

Confidenti al Business Information (CBI)

- CAA section 114(c) provides for CBI protection in

114 information requests (other than emissions data):

(c) Any records, reports, or information obtained under subsection

(a) shall be available to the public, except that up on a showing satisfactory to the

Administrator by any person that records, reports, or information, or particular part

thereof (other than emission data), to which the Administrator has access under this

section if made public, would divulge methods or pro cesses entitled to protection as trade

secrets of such person, the Administrator shall consider such record, report, or

information or particular portion thereof confidential in accordance with the purposes of

section 1905 of title 18 of the United States Code, except that such record, report, or

information may be disclosed to other officers, employees, or authorized representatives

of the United States concerned with carrying out this Act or when relevant in any

proceeding under this Act.

As such we requ est that Section 114 data that a company with CBI information provide such data

under separate cover for security purposes in response to the Section 114 survey(s). This is of

particular relevance to aluminum production data.

Part A. F acility Informatio n

1. Name and address of legal OWNER of the facility:

________________________________ ________________________________ ______________

________________________________ ________________________________ ______________

________________________________ ________________________________ ______________

2. Name and address of legal OPERATOR of the facility, if different than the legal

OWNER

________________________________ ________________________________ ______________

________________________________ ________________________________ ______________

________________________________ ________________________________ ______________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 2 of 2 9 3. Complete street address of facility (physical location):

a. Address:

________________________________ ____________________________ b. City:

________________________________ ________________________________

c. Sta te:

________________________________ _______________________________ d. Zip:

________________________________ ________________________________ _

e. County:

________________________________ ______________________________

4. Provide mailing address of the facility if different than physical location:

a. Address:

________________________________ _____________________________ b. City:

________________________________ ________________________________

c. State:

________________________________ _______________________________ d. Zip:

________________________________ ________________________________ _

5. Facility contact able to answer technical questions about the completed survey

a. Nam e (First Name, Last Name):

________________________________ __________ b. Title:

________________________________ ________________________________

c. Telephone number: _______________ ____________ ext.

____________________ d. Fax number:

________________________________ __________________________

e. E

- mail:

________________________________ ______________________________ f. If the facility is not subject to 40 CFR part 63 , subpart RRR, please complete

this page, sign below and send this pag e certified mail to the non

- CBI address

listed on the instruction sheet by XXX,

I certify that this facility 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

.

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

A Responsible Official can be the president, vice

- president, secretary, or treasurer of the company that owns the facility; owner

of the facilit y, plant engineer or supervisor

.

6. What is the facility size classification for hazardous air pollutant (HAP) emissions ?

( C HECK one)

EPA Major Source of Hazardous Air Pollutants (HAP) :

EPA Area source ( based on potential to emit) of HAP

EPA Ar ea 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

a. Primary NAICS code

________________________________ ___________________ b. Other facility NAICS codes: ____________

__, ______________ ,

________________

8. Company Size

– ( CHECK one )NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 3 of 2 9 Note: Approximate 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.

___ <50

___ 50

- 99

___ 100

- 499

___500

- 749

___ 750

- 999

___ >1000

9. Facility Size

- ( CHECK one )

Note : Approximate number of all employees at facility in location identified in question

#3 above.

___ <50

___ 50

- 99

___ 100

- 499

___ 5 00

- 749

___ 750

- 999

___ >1000

10. Is the legal owner a small entity as defined by the Regulatory Flexibility Act?

( CHECK one)

Note : For private businesses, small entity is defined for each NAICS of the owning entity

based on number of employees and/or c ompany revenue. The parent company number of

employees is used for the secondary aluminum industry subsector (331). The small

business size standards for NAICS subsectors is located at the following link:

https://epic.od.nih.gov/naics/Naicscodelist.asp#Manufacturing

___ Yes

___ No

11. Federal and State rule/permit coverage. ( CHECK all that app ly t o this facility)

. ___ Subpart RRR (Secondary Aluminum)

____ Diecasting Oper ations

____ Foundry

____ Extruder

___ Subpart LL ( Primary Aluminum)

_________________________________ Other (SPECIFY rule name and subpart)

_________________________________ Other (SPECIFY rule name and subpart)

New Source Performance Standards (NSPS )

_________________________________ (SPECIFY rule name and subpart)

_________________________________ (SPECIFY rule name and subpart)

Title V

______________________ (SPECIFY rule that led to title V permit requirement)NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 4 of 2 9 State Air Toxics:

___________ ______________________ (SPECIFY rule name and subpart)

_________________________________ (SPECIFY rule name and subpart)

Other: ___________________________ (SPECIFY emission unit and rule)

_________________________________

Other: __________________ _________ (SPECIFY emission unit and rule)

_________________________________

What is meant by the „Other‟ category above?

If EPA requires a list of all State rules that apply to each facility, this will be listed in the

facility Title V permit.

1 2. Normal Facility Production Hours:

Hours/day:

___________________ Shifts/day: ___________________

Days/week: _

____ _____________ Weeks/year: __________________

13. Total Amount of aluminum produced in 2009 AND the amount of aluminum produced in

2004 or later, which represents the largest amount of aluminum produced:

_______________ tons of aluminum produced 2009

_______________ tons of aluminum produced in year of highest production

_______________ year

Consideration should be given to this information being CBI protected. Given that 2009 may not

be a representative year for the industry due to the recession, it might be preferable to specify

data from the most representative year instead of 2009.

There is need for a definition of scrap (e.g. whether or not it include internal runaround s crap).

14

. Total Amount of scrap charge d in 2009 AND the amount of scrap charged in 2004 or

later, which represents the largest amount of scrap charged:

_______________ tons of scrap charged in 200 9

_______________ tons of scrap charged in year of highest production

______________ year

Consideration should be given to this information being CBI protected. See comments above for

#13.

15. Approximately what percent of the total facility scrap charged (in #14 above) is clean

(including “run around” ) scrap

_______________ Percent in 2009NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 5 of 2 9

_______________ Percent in other year from #14 above ( specify year ) : ________

Method of calculation should be specified as the total input to the facility and not the sum of

inputs to each piece of equipment.

It appears that this question is really addressing „clean ch arge‟ as defined under section 63.1503.

Clarification is needed, and a definition of clean charge should be included.

Consideration should be given to this information being CBI protected.

16. Please provide a copy of a schematic of the plant layout for equipment in service under

subpart RRR

. Label the schematic with the unit IDs, which should also match the unit

IDs used to respond to later questions.

17. Please provide all of the pertinent information listed below. Please provide electronic

copi es, if available, and indicate items provided below

. Note: Use information from 2004 or later, whichever year has the highest production

rate

. _________(please specify)

(CHECK all that apply ):

□ Title V permit

□ Operating permit (Permit)

□ Permit applica tions (pending only)

□ Performance test reports (submit most recent test reports)

□ Emission inventory reports ( reporting year s should be the same as what years were

chosen in the remainder of the survey )

□ Consent decrees or orders

– this request should b e limited to the last three years.

□ Notice(s) of operating violations

□ S tartup, shutdown, and malfunction (SSM) plan

□ Site

- specific operating, maintenance, and monitoring plan

– Does this mean the

OM&M plan? Or is it referencing the site

- specific monito ring plan ?

The information request should be applicable to air regulations only.

This request should be applicable to Subpart RRR sources only.

We do not understand why consent decrees and NOV‟s are included in the survey or for what

purpose such materi als are requested.

Providing the documents requested will effectively substitute filling out some of the tables

included in the survey.

Does EPA need Title V renewal applications as part of “permit applications (pending only)? If

yes, why?NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 6 of 2 9 P art B. Facility Equipment Regulated under Subpart RRR (Secondary Aluminum NESHAP) 1

Please provide the information below for all equipment at your facility;

18. Regulated Equipment List

Unit

Identification

Numbers(s)

(Unit ID No.) Unit ID No.

as designated

in Title V or

State

Operating

Permit* Subpart RRR

Equipment Located

at

Facility?

(Y or N) Add

- on

Controls

(Y or N) Operating

in 2009?

(Y or N)

If “No”, list

last year of

operation

Aluminum Scrap

Shredder

Thermal Chip Dryer

Scrap

dryer/delacq uering/

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

Other ( spe cify):

Other ( specify):

Other ( specify):

* 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 well s

o r scrap wells

.

What is the purpose of the column „located at facility ‟ ?

What is meant by the „Other‟ category?

1 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.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 7 of 2 9 Part C. Scrap Charge Rates and Controls Used for Major Sources Subpart RRR MACT

Please provide the information below for all regulated equip ment at your facility; Use

information for this section from 2004 or later, whichever year has the highest production

rate

. _________(please specify)

Consideration should be given to this charge and production related information being CBI

protected. Info rmation should be reportable in emissions per ton of production instead of total

production data.

19. For Each Scrap Shredder

Unit ID

Number * Amount of

Scrap

Charged

(tons/year) Maximum

Capacity of

Unit (tons

scrap/yr) Maximum

Capacity of

Unit ( lbs.

scr ap/ hr ) Control Device

Type Device

ID No.

* Please indicate which of the scrap shredders listed above process only clean charge with no

visible emissions: ____________________________________________________________

Clarify what is the definition of “clean charge” for a scrap shredder? Is this as defined in the

rule? Is this applicable to shredders that use clean charge with no control?

20. For Each Thermal Chip Dryer

Unit ID

Number Amount of

Chips

Charged

(tons /year) Maximum

Capacity of

Unit

(tons chips /yr) Maximum

Capacity of

Unit

( lbs. chips /

hr ) Control Device

Type Device

ID No.

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

Unit ID

Number * Amount of

S crap Charged

(tons/year) Maximum

Capacity of

Unit

(tons s crap/yr) Maximum

Capacity of

Unit

( lbs. scrap/ hr ) Control Device *

Type Device

ID No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 8 of 2 9 * If the kiln is equipped with an afterburner operated at a minimum of 7 60°C, with a design

residence time of 1 second minimum, enter the control device ID Nos. here: ________________

22. For Each Dross Only Furnace

Unit ID

Number Amount of

Dross

Charged

(tons/year) Maximum

Capacity of

Unit

(tons dross /yr) Maximum

Capacity of

Unit

( lbs. dross / hr ) Control Device

Type Device

ID No.

23. For Each Rotary Dross Cooler

Unit ID

Number Amount of

Dross

Charged

(tons/year) Maximum

Capacity of

Unit

(tons dross /yr) Maximum

Capa city of

Unit

( lbs. dross / hr ) Control Device

Type Device

ID No.

24. For Each Group 1 Furnace

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Clean

charge

(yes/no) Maximum

Capacity of

Unit

(ton s

charge /year) Maximum

Capacity of

Unit

( lbs.

charge / hr ) Control Device

Type Device

ID No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 9 of 2 9 Capacity may be measured in aluminum pounds produced as an option

.

What is meant by “Clean Charge (yes/no)” ? As examples s hould the answer be “yes” if any material charged during the entire year is not “clean charge” (i.e. near 100 % clean charge ); do

we answer “ yes ” if the furnace processes any clean charge during the time period?

The information concerning maximum capacity of unit

– does it refer to the actual maximum

throughput for a year, or the potential maximum?

Capacity in “lbs. charge/hr” not meaningful parameter for batch furnaces

– cycle times vary wi th

charge material, alloy type and casting opera tion resulting in large variability in lbs charged per

hour

.

25. For Each Group 2 Furnace

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Maximum

Capacity of Unit

(tons

charge /year) Maximum

Capacity of

Unit ( lbs.

charge / hr ) Control Device

Type Device ID

No.

Capacity may be measured in aluminum pounds produced as an option

.

Capacity in “lbs. charge/hr” not meaningful parameter for batch f urnaces

– cycle times vary with

charge material, a lloy type and casting operation.

26

. For Each In

- line Fluxer

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Maximum

Capacity of

Unit (tons

charge /year) Maximum

Capacity of

Unit ( lbs.

charge / hr ) Control Device

Type Device ID

No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 10 of 2 9 Capacity may be measured in aluminum pounds produced.

Note that in

- line fluxers do not run all the time

– only when a batch of metal is being cast from

the furnace.

2 7

. For Each Sweat Furnace

Unit ID

Number * Amount of

Scrap

Charged

(tons/yr) Maximum

Capacity of

Unit (tons

scrap /year) Maximum

Capacity of

Unit ( lbs.

scrap / hr ) Control Device *

Type Device ID

No.

* If the sweat furnace is equipped with an afterburne r operated at a minimum of 1600°F, with a

design residence time of 0.8 second minimum, enter the control device ID here: _____________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 11 of 2 9 2 8

. For E ach Secondary Aluminum Processing Unit (SAPU) Using Emissions Averaging (as per section 63.1505(k) )

a. Com plete this table if your facility chose to measure compliance using the weight of the feed/charge

.

Unit

ID No. Amount of

Feed/

Charge

(tons/year) Charge

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(app roximate) Maximum

Capacity of

Unit (tons

charge/yr) Maximum

Capacity of Unit

( lbs. charge /h r) Control Device

Type Device

ID No.

b. Complete this table if your facility chose to measure compliance using the weight of the alumin um produced

.

Unit

ID No. Amount of

Aluminum

Produced

(tons) Production

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of

Unit

(tons

a luminum/yr) Maximum

Capacity of Unit

( lbs.

aluminum/h r) Control Device

Type Device

ID No.

This question needs discussion and clarification. Consideration should be given to deleting Item 28. The production rate used in the

SAPU emission calculation changes every day depending on whether the unit operated and what the production was that day. Other

information in the tables is duplication of information already requested above under #24 through #26.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 12 of 2 9 Part D . Scrap Charge Rates and Controls Used for Area Sources Su bpart 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 has the highest production rate

. _________(please specify)

2 9

. For Each Thermal Chip Drye r

Unit

ID No. Amount of Chips

Charged (tons) Maximum

Capacity of Unit

(tons charge /yr) Maximum Capacity

of Unit ( lbs.

charge / h r) Control Device

Type Device

ID No.

30

. For Each Scrap Dryer/Delacquering Kil n/Decoating Kiln

Unit

ID No. Amount of Scrap

Charged (tons/year) Maximum

Capacity of Unit

(tons scrap/yr) Maximum

Capacity of Unit

( lbs. scrap/ h r) Control Device *

Type Device

ID No.

* If the kiln is equipped with an afterburner operated at a minimum of 760°C, with a design residence time of 1 second minimum,

enter the control device ID Nos. here: _______________________________________________________________________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

ATT7.doc Page 13 of 2 9 31. For Each Group 1 Furnace

Unit ID

Num ber Amount of

Aluminum

Charged

(tons/yr) Clean

charge

(yes/no) Maximum

Capacity of Unit

(tons charge /year) Maximum

Capacity of Unit

( lbs. charge / hr ) Control Device

Type Device ID

No.

Capacity may be m easured in aluminum pounds produced.

32

. For Each Sweat Furnace

Unit ID

Number * Amount of

Scrap

Charged

(tons/yr) Maximum

Capacity of Unit

(tons scrap /year) Maximum

Capacity of Unit

( lbs. scrap / hr ) Control Device *

Type Device ID

* 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: _______

___________________________________________ _______________ _____ATT7.doc Page 14 of 2 9

33

. 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

.

Unit

ID No. Amount of

Feed/ Charge

(tons/year) Charge

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of

Unit (tons

charge/yr) Maximum

Capacity of

Unit ( lbs.

charge /h r) Control Device

T ype Device

ID No.

b. Complete this table if your facility chose to measure compliance using the weight of the aluminum produced

.

Unit

ID No. Amount of

Aluminum

Produced

(tons) Production

Rate used

to

calculate

emission

limits

(tons/hr ) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of Unit

(tons

a luminum/yr) Maximum

Capacity of Unit

( lbs.

aluminum/h r) Control Device

Type Device

ID No.ATT7.doc Page 15 of 2 9

Part E. Emissions and Limits

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)

Specify that the information request in this section is for RRR regulated sources.

Please also submit any e mission inventory reports that include these data.

34

. E ach Secondary Aluminum Processing Unit (SAPU) at the facility, if applicable

a. Complete this table if your facility chose to measure compli ance using the weight of the feed/charge ).

Unit

ID No. SAPU Wide

Emission Limits*

PM limit

(lbs. PM/ton charge)* Hydrogen Chloride (HCl)

(lbs. HCL/ton charge)* Dioxin/furan (D/F)

(grains D/F per ton charge)

* Th e charge rate used t o calculate these emission limits should be based on the charge rate during the performance test.

Footnote above is incorrect. SAPU Emission Limit change s daily with the amount of production produced that day in each unit. The

MACT standard is “lb emitt ed/ton aluminum charged” and the amount of emissions “allowed” by the SAPU changes daily depending

on how much material is processed by the emission unit. That way, if a unit does not operate on any given day, it does not contribute

to allowable emissions from the SAPU for that day.

Column labeled “Unit I.D. No.” does not make sense here. Is EPA requesting this information for each “SAPU” at the facility rather

than each “Emission Unit”? If yes, column should be labeled “SAPU I.D. No.”

b. Complete thi s table if your facility chose to measure SAPU compliance using the weight of the aluminum produced

.ATT7.doc Page 16 of 2 9

Unit

ID No. SAPU Wide

Emission Limits

PM limit

(lbs. PM/ton aluminum)* Hydrogen Chloride (HCl)

(lbs. HCL/ton aluminum)* Dioxin/furan (D/F)

(grains D/F per ton

aluminum)

* T he feed rate used to calculate these emission limits should be based on the weight of the aluminum produced during the

performance test

.

If each piece of equipment meets the individual source emissions limits, this ta ble can be omitted.

Footnote above is incorrect. SAPU Emission Limit changes daily with the amount of production produced that day in each unit. The

MACT standard is “lb emitted/ton aluminum charged” and the amount of emissions “allowed” by the SAPU cha nges daily depending

on how much material is processed by the emission unit. That way, if a unit does not operate on any given day, it does not c ontribute

to allowable emissions from the SAPU for that day.

Column labeled “Unit I.D. No.” does not make se nse here. Is EPA requesting this information for each “SAPU” at the facility rather

than each “Emission Unit”? If yes, column should be labeled “SAPU I.D. No.”ATT7.doc Page 17 of 26

35

. a. Emissions for each individual emission unit regulated under subpart RRR, as applicable.

U nit

ID No. Emissions

Unit Name Annual Routine Emissions From Regulated RRR Pollutants Control Device

(from Part C or D above)

Test Data?*

(Y/N) PM

(lb s. /ton) D/F

(grain/ton) HCl

(lb s. /ton) Total Hydrocarbons

(THC) (lbs./ton) Device Type ** Unit

ID No.

* Please provide any test data along with this form.

** If you comply with subpart RRR requirements for sweat furnaces by controlling your afterburner residen ce time, enter “AB/RT”

in the table

.

* ** Please include dio xin/furan congeners

THC data applicable only to delacquerers and dryers

Add column to reference applicable test report. These data are available in existing test reports making this section duplicative.

Define „annual routine emis sions‟

– we only have emission factors (lb/ton) from performance testing.

b

. Please list all other HAP emissions from equipment subject to 40 CFR 63, subpart RRR.

Equipment/Process

Description Unit ID

Number List each

individual

HAP * CAS# Routine

Emis sion Rate

( lbs. /yr) Maximum

Allowable

(lb s. /yr) Maximum

Allowable

(lbs. /hr)ATT7.doc Page 18 of 26

How might this table be applicable? If emissions are not tested are they to be estimated, and if so how? Otherwise a „no data‟

response should be provided. Are actual data to be included, or emission factors or other estimates to be also used?

c

. Please list estimated HAP emissions from equipment collocated at your facility that are not regulated under 40 CFR 63,

subpart R RR.

Equipment/Process

Description List each individual

HAP CAS# Emission Rate

( lbs. /yr) Maximum

Allowable

(lb s./ yr) Maximum

Allowable

(lb s. /hr)ATT7.doc Page 19 of 26

How are emissions t o be estimated? Are actual emission at to be used included, or emission factors or other estimates included? Can

this be a sum of HAP‟s for all other sources? Is the use of existing emission inventory acceptabl e?

This survey should be limited to RRR sources.

This request is outside scope of RRR and should be deleted

– other HAP sources are either already regulated under another MACT

categories or they are not part of the Secondary Aluminum MACT category.

P art F. Detailed Control Device and Emission Release Information

Please provide the information below OR o n the enclosed spreadsheet . Please also submit any e mission inventory or test reports

that include these data.

Specify that information request is for RRR regulated 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)

36. A dd

- on air p ollution control device s (use multiple lines if the same control device is used to control more than one pollutant).

Control Devices Units

Controlled

Device Type* Device

ID No. Pollutant

Controlled Capture

Efficiency (if

known)

(percent) Control

Device

Ef ficiency

(if Known)

(percent) Overall

Efficiency, if

known

(percent) Methods Used for

Determining Capture

& Control

Efficiencies**(a

- c)

Type(s) of Unit Unit

ID No.

* For example, afterburner, lime coated fabric filter, etc.

** Control & Capture EfficiencyATT7.doc Page 20 of 26

a = Testing (specify method)

b = Manufacturer's Specifications

c = Engineering Estimate

Please provide any additional information concerning the Control Devices:

________ ____________________________________________________________________________________________________

____________________________________________________________________________________________________________

________________________________________________ ____________________________________________________________

____________________________________________________________________________________________________________

Capture efficiency data not required under RRR, and therefore not known at most facil ities.

37. For each stack/ control device exhaust point , please provide the following information, if known , related to the information in

Item #36 above.

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)

Diameter

(ft) Area

(sq. ft.) Maximum Minimum

* Longitude and Latitude should be specified ou t to 5 decimal places. I f coordinates are not known , p lease provide a scale d site

diagram, with a latitude/longitude reference point, indicating stack locations

.

Information on mapping or coordinates should be provided if available. Emission test plans s hould provide a substitute.

38. For each exhaust point/stack not associated with a control device, please provide the following information, if known :ATT7.doc Page 21 of 26

Unit ID What control

devices are vented at

this point? Height of stack

or discharge (ft) Discharge Exi t Gas

Temperature

(degrees F) Latitude* Longitude* Flow Rate (SCFM)

Diameter

(ft) Area

(sq. ft.) Maximum Minimum

 Longitude and Latitude should be specified out to 5 decimal plac es. If coordinates are not known, p lease provide a scale d site

diagram, indicating stack locations.

Information on mapping or coordinates should be provided if available. Emission test plans should provide a substitute.

Data is available from the Natio nal Emissions Inventory (NEI) from relevant States.ATT7.doc Page 22 of 2 9

39

. For each affected source listed in [Section B, above] , identify the date(s) of latest

NESHAP compliance testing.

Subpart RRR sources should be specified.

Date

Tested Emission Unit

Test Method

Used Poll utant(s)

Tested Emissions

(Specify Units) Unit Name Unit ID No.

Emission test reports should provide substitute for table data entries.

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?

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?

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?

* Where two or more co

- controlled furnaces were tested simultaneously, list all furnace IDs.

The minu tes a charged door is open not required under RRR, and may be variable depending on

charge type and size.

b

. For each sidewell (scrapwell) furnace listed in response to 39a: Delete „scrapwell‟

term as it is not noted in RRR.ATT7.doc Page 23 of 2 9

Furnace ID

Was reactive fl ux used in the sidewell,

hearth, both, or neither?

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 t he sidewell and hearth during

periods of reactive fluxing?

How was the molten metal level

monitored?

c

. For each G roup 1 furnace that is not ducted to a control device :

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 air emissions escaping

from the furnace doors, etc.?

Were visible emissions monitored

during the performance test?

Were visible emissions observed

during the performance test?

d

. For each Group 1 furnace tha t is ducted to a control device :

Furnace ID

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 th e furnace doors, etc.?

Requested information should focus on adequate ventilation rate and excess fugitive

emission observations.ATT7.doc Page 24 of 2 9

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?

If yes, please describe.

Were visible emissions monitored

during the performance test?

Were visib le emissions observed

during the performance test?

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.?

Part G. Faci lity Operation s

40. General

a. What type of pretreatment (e. g. air drying, centrifugal drying, etc.) or presorting

takes places to get the aluminum scrap ready for processing?

What is the definition or presorting?

________________________________ ________________________________ _____

b. Do you track the amount of a luminum 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?

________________________________ ________________________________ _____

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 ?

________________________________ ________________________________ _____ATT7.doc Page 25 of 2 9

41. Fluxing

a. What fluxes were used in 2009 or the most recent year of normal operation? Please

attach MSDS for each f

lux:

Flux

Identification Flux Still in

Use?

(Yes or No) Mass Used

(lb s. /yr) Furnace or in

line fluxer ID

in which flux

was used Purpose (e.g.

cover, degassing,

demagging, etc.)

Define cover flux inc luding examples.

b

. If you have sidewell (scrapwell) furnaces, did you use reactive f lux in the sidewell

and the hearth? If so, d id you test emissions from both sources?

________________________________ ________________________________ _____

c. D o you use different types or quantities of flux for different flux applicatio ns? If so,

how do the procedures differ?

________________________________ ________________________________ _____

d

. What are your flux rate operatin g and monitoring procedures?

________________________________ ________________________________ _____

e. Do you have any fluoride emission data? If so, please provide or indicate here.

__________ tons/yr fluoride emissions (or lbs. F /to n charge)?

Fluoride emission data are not required under RRR, and therefore may not be available

from facilities. However, emission data was obtained on fluoride emissions from the

testing program conducted in developing the MACT rule under RRR.

f. For any cover fluxes listed, do you perform any agitation of these fluxes?

__________ If “yes”, does the agitation include only the surface or the entire depth of

the melt? __________________________________________________________ATT7.doc Page 26 of 2 9

Clarify that molten me tal circulation below the surface does not constitute „agitation‟.

42. Controls

a

. Do you use any alternative control devices (i. e. control devices other than fabric

filters, lime

- coated fabric filters, or afterburners) , monitoring, or operating con ditions

at this fa cility (i.e., ceramic air filters)?

________________________________ ________________________________ _____

b

. Have you ever injected activated carbon or other type of carbon for HAP control?

What barriers do you envision to addi ng carbon injection to fabric filters for HAP

control (check as many as apply ) ?

□ Cost of activated carbon

□ Creates problems with disposal of material collected by baghouse

□ Other (specify): ____________________________________________

Question on the use of activated carbon should apply o nly to routine use, not to R&D

testing.

c

. Do you use catalytic filters for dioxin control (e.g.,

http://www.donaldson.com/en/industrialair/literature/051754.pdf ) ?

.

________________________________ ________________________________ _____

d. Do y ou 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.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

, For the control technologies identified and liste d in 42d above, please provide cost information:

Unit ID

No. Control Device Total

Capital

Investment Total

Annual

Operating

and

Maintenance

Costs Base Year

for

Operating

Costs Type/Description Device ID.

No.ATT7.doc Page 27 of 2 9

43. Pollu tion Prevention

A. Describe any procedures you use at your facility to prevent pollution (as opposed to

controlling pollution after it is formed). Specify that procedures applicable for air emissions

related to RRR

_______________________________________ _______________________________________

B. Have you implemented any work practice standards or standard operating procedures

that will further reduce HAP emissions? ___ If so, please specify.

__________________________________________________________ ____________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

_____________________ _________________________________________________________

______________________________________________________________________________

______________________________________________________________________________ATT7.doc Page 28 of 2 9

Part H. Startup and Shutdown

44. For each startup and shutdown event that occurred over the last 3 years, please provide the

following information. If this information is contained in periodic and immediate SSM reports

(either stand

- alone or contained within the periodic excess emissions repo rt) submitted to your

permitting authority, you may submit copies of those reports instead.

This section should be limited to startups and shutdowns that caused excess emissions only.

Such records are required only when excess emissions occur. The amou nt of data over a three

year period is excessive. Request should be for 2009 only.

Startup/Shutdown*

D escription of the event, including

identification of the emissions source or

sources [unit ID(s)] associated with the

startup or shutdown

Was a ny permit condition was exceeded

and, if so, what permit condition was

exceeded

Was the event was 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

Duration of the event

A ctions 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 hav e the ability to quantify

emissions during the event, please

explain why

Was the emission profile of each unit

was different during startup and

shutdown than during normal operating

conditions and, if so, how emissions

were different and why. Please provide

any supporting information

List performance test data collected

during each period of startup or

shutdown, the test method used for each

event; when the testing was conductedATT7.doc Page 29 of 2 9

* Startup : the commencement of operation of an affected s ource 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

45. Are there any types of startup or shutdown events that you have been able to eliminat e; if so,

please describe the type of event and explain how these events were eliminated.

46. Optional: Do you wish to recommend a standard that would apply during startup and/or

shutdown? If so, please describe the type of event 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 ev ent; and how would compliance be

determined and/or monitored. and why; the test conditions at the time

of testing; and whether the tests were

associated with a routine startup or

shutdown

List monitoring data, including control

system parameter monitoring, collected

during each period of startup and

shutdownATT7.doc Page 30 of 2 9

Part I. Criteria Air Pollutants (CAP)

Please provide the information below OR i n the enclosed spreadsheet . Please also submit any e mission inventory or test reports

that include these dat

a.

This section should be voluntary, or eliminated as it does not apply to RRR emissions requirements

.

Please provide the information below for all regulated equipment at your facility; Use information for this section from 2004 or later,

whichever yea r has the highest production rate

. _________(please specify)

47. CAP emissions by unit for each emission unit subject to 40 CFR 63, subpart RRR

* Please provide any test data along with these sections

.

ID

No. Emission

Unit CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOx

b. Please list estimated C AP emissions from equipment collocated at your facility that is not regulated under 40 CFR 63,

su bpart RRR.

ID

No. Emission

Unit CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOxATT7.doc Page 31 of 2 9

48. Control devices used for CAP emission control

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

Part J

. Energy Usage

Please provide the information below OR i n the enclosed spreadsheet

.

This section should be limited to RRR sources only.

49. Please list total annual energy consumption.

Combustion Units (Include Emergency Combustion Equipment) Unit Unit Unit Unit Unit

Process Unit ID:

Equipment ID:

Type of Combustion Equipment:

Year Built: why is this relevant?

Number of Operating Hours per Year:

Design Capacity (Heat Input) (MMBtu/hr):

Fuel Type:

Heat Release Rate (Btu/scf):

Is the unit subject to NSPS?

If yes, indicate the year:

Start

- up Fuel/MaterialATT7.doc Page 32 of 2 9

Start

- up fuel:

Typical Start

- up fuel amount (Spe cify Units)

Typical length of time for start

- up (hours):

Higher heating value (HHV):

Fuels/Materials Combusted During Normal Operations (include solid, liquid, and gas

waste streams)

Fuel #1 Usage: (Specify Units)

Hours used per year:

Higher heating value (HHV):

Fuel #2 Usage: (Specify Units)

Hours used per year:

Higher heating value (HHV):

Fuel # 3 Usage: (specify Units

Hours used per year:

Higher heating value (HHV):

Consideration s hould be given to this information being CBI protected. Request should apply only to production equipment and not to

emergency equipment and building services. Heat release rate should be deleted. Fuel/Materials section irrelevant if same a s normal

oper ations. Fuel usage per year is generally not available for individual units.

This data is not available for individual emission units and is not relevant to RRR HAP emission standards.

50. Are any Cogeneration units listed above, if so please list th e unit and describe the process for

each?____________________________________________________________________________________

_________________________________________________________________________________________

________________________________________ __________________________________________________ATT7.doc Page 33 of 2 9

51. Electricity Usage

– applicable to RRR units only?

Normal

Operating

Annual

Electricity

Usage Year Usage (Specify Units)

Consideration should be given to this information being CBI protec ted.

K. Miscellaneous Information

52 . Were there any problems that were encountered during the permitting process of your facility due to the way the rule is written in

subpart RRR?

53. What specific improvements or rule changes would you like to see that would help your facility with compliance or better rule

interpretation?NESHAP for Secondary Aluminum (40 CFR p art 63, subpart RRR)

ATT7.doc A

- 1 Attachment A. Definitions (from subpart RRR)

Afterburner means an air pollution control device that uses controlled flame combustion to convert

combustible materials to nonc ombustible gases; also known as an incinerator or a thermal oxidizer.

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/decoati ng kiln, or

furnace. A bale breaker is not an aluminum scrap shredder.

Dross

- only furnace means a furnace, typically of rotary barrel design, dedicated to the reclamation of

aluminum from dross formed during melting, holding, fluxing, or alloying operat ions carried out in

other process units. Dross and salt flux are the sole feedstocks to this type of furnace.

Group 1 furnace means a furnace of any design that melts, holds, or processes aluminum that contains

paint, lubricants, coatings, or other forei gn materials with or without reactive fluxing, or processes clean

charge with reactive fluxing.

Group 2 furnace means a furnace of any design that melts, holds, or processes only clean charge and

that performs no fluxing or performs fluxing using only no nreactive, 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 wat er

- cooled rotary barrel device that accelerates cooling of dross.

Scrap dryer/delacquering kiln/decoating kiln means 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 o f the group 1 furnaces or in

- line fluxers

within a new SAPU is considered an emission unit within that secondary aluminum processing unit.

Sidewell means an open well adjacent to the hearth of a furnace with connecting arches between the

hearth and the op en 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.NESHAP for Secondary Aluminum (40 CFR p art 63, subpart RRR)

ATT7.doc A

- 2 Sweat furnace means 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 d ryer means a device that uses heat to evaporate water, oil, or oil/water mixtures from

unpainted/uncoated aluminum chips.ATT7.doc B

- 1

Appendix B



### Section 112(b) List of Hazardous Air Pollutants (HAP)

U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412

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

- Ami nobiphenyl

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 ChlorobenzeneATT7.doc B

- 2

510156 Chlorobenzilate

67663 Chloroform

107302 Chloromethyl methyl ether

126998 Chloroprene

1319773 Cresols/Cresylic acid (isomers and mixture)

95 487 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

5 1285 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

5179 6 Ethyl carbamate (Urethane)

75003 Ethyl chloride (Chloroethane)ATT7.doc B

- 3

106934 Ethylene dibromide (Dibromoethane)

107062 Ethylene dichloride (1,2

- Dichloroethane)

107211 Ethylene glycol

151564 Ethylene imine (Aziridine)

75218 Ethylene oxide

96457 Et hylene thiourea

75343 Ethylidene dichloride (1,1

- Dichloroethane)

50000 Formaldehyde

76448 Heptachlor

118741 Hexachlorobenzene

87683 Hexachlorobutadiene

77474 Hexachlorocyclopentadiene

67721 Hexachloroethane

822060 Hexamethylene

- 1,6

- diisocya nate

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 Me thanol

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

- Methylenedianili ne

91203 Naphthalene

98953 Nitrobenzene

92933 4

- Nitrobiphenyl

100027 4

- NitrophenolATT7.doc B

- 4

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 b eta

- 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 Styr ene 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

9553 4 o

- Toluidine

8001352 Toxaphene (chlorinated camphene)

120821 1,2,4

- Trichlorobenzene

79005 1,1,2

- Trichloroethane

79016 Trichloroethylene

95954 2,4,5

- Trichlorophenol

88062 2,4,6

- Trichlorophenol

121448 Triethylamine

1582098 Trifluralin

5408 41 2,2,4

- TrimethylpentaneATT7.doc B

- 5

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 Mangan ese 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

.

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

– (OCH 2 C H 2 )n

– OR where

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

– (OCH 2 CH)n

– OH. Polymers are excluded from the glycol category.

3 Includes mineral fiber emissions from facilities ma nufacturing or processing glass, rock, or

slag fibers (or other mineral derived fibers) of average diameter 1 micrometer or less.

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.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 1 of 2 9 S econdary Aluminum (40 CFR part 63, subpart RRR)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

Aluminum Association Comments 5/17 / 20 10

Aluminum Association c omments to the Section 114 survey form included in red text as follows

.

Gene ral Comments

Survey should specify that it is applicable to RRR regulated sources only.

Purpose of the survey should be stated upfront.

An estimate of the number of participating facilities should be included, or added to the

instructions.

Confidenti al Business Information (CBI)

- CAA section 114(c) provides for CBI protection in

114 information requests (other than emissions data):

(c) Any records, reports, or information obtained under subsection

(a) shall be available to the public, except that up on a showing satisfactory to the

Administrator by any person that records, reports, or information, or particular part

thereof (other than emission data), to which the Administrator has access under this

section if made public, would divulge methods or pro cesses entitled to protection as trade

secrets of such person, the Administrator shall consider such record, report, or

information or particular portion thereof confidential in accordance with the purposes of

section 1905 of title 18 of the United States Code, except that such record, report, or

information may be disclosed to other officers, employees, or authorized representatives

of the United States concerned with carrying out this Act or when relevant in any

proceeding under this Act.

As such we requ est that Section 114 data that a company with CBI information provide such data

under separate cover for security purposes in response to the Section 114 survey(s). This is of

particular relevance to aluminum production data.

Part A. F acility Informatio n

1. Name and address of legal OWNER of the facility:

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

2. Name and address of legal OPERATOR of the facility, if different than the legal

OWNER

______________________________________________________________________________

______________________________________________________________________________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 2 of 2 9 ______________________________________________________________________________

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

a. Address:

____________________________________________________________ b. City:

________________________________________________________________

c. Sta te:

_______________________________________________________________ d. Zip:

_________________________________________________________________

e. County:

______________________________________________________________

4. Provide mailing address of the facility if different than physical location:

a. Address:

_____________________________________________________________ b. City:

________________________________________________________________

c. State:

_______________________________________________________________ d. Zip:

_________________________________________________________________

5. Facility contact able to answer technical questions about the completed survey

a. Nam e (First Name, Last Name):

__________________________________________ b. Title:

________________________________________________________________

c. Telephone number: ___________________________ ext.

____________________ d. Fax number:

__________________________________________________________

e. E

- mail:

______________________________________________________________ f. If the facility is not subject to 40 CFR part 63 , subpart RRR, please complete

this page, sign below and send this pag e certified mail to the non

- CBI address

listed on the instruction sheet by XXX,

I certify that this facility 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

.

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

A Responsible Official can be the president, vice

- president, secretary, or treasurer of the company that owns the facility; owner

of the facilit y, plant engineer or supervisor

.

6. What is the facility size classification for hazardous air pollutant (HAP) emissions ?

( C HECK one)

EPA Major Source of Hazardous Air Pollutants (HAP) : 

EPA Area source ( based on potential to emit) of HAP 

EPA Ar ea 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

a. Primary NAICS code

________________________________ ___________________ b. Other facility NAICS codes: ____________

__, ______________ ,

________________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 3 of 2 9 8. Company Size

– ( CHECK one )

Note: Approximate 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.

___ <50

___ 50

- 99

___ 100

- 499

___500

- 749

___ 750

- 999

___ >1000

9. Facility Size

- ( CHECK one )

Note : Approximate number of all employees at facility in location identified in question

#3 above.

___ <50

___ 50

- 99

___ 100

- 499

___ 5 00

- 749

___ 750

- 999

___ >1000

10. Is the legal owner a small entity as defined by the Regulatory Flexibility Act?

( CHECK one)

Note : For private businesses, small entity is defined for each NAICS of the owning entity

based on number of employees and/or c ompany revenue. The parent company number of

employees is used for the secondary aluminum industry subsector (331). The small

business size standards for NAICS subsectors is located at the following link:

https://epic.od.nih.gov/naics/Naicscodelist.asp#Manufacturing

___ Yes

___ No

11. Federal and State rule/permit coverage. ( CHECK all that app ly t o this facility)

. ___ Subpart RRR (Secondary Aluminum)

____ Diecasting Oper ations

____ Foundry

____ Extruder

___ Subpart LL ( Primary Aluminum)

_________________________________ Other (SPECIFY rule name and subpart)

_________________________________ Other (SPECIFY rule name and subpart)

New Source Performance Standards (NSPS )

_________________________________ (SPECIFY rule name and subpart)

_________________________________ (SPECIFY rule name and subpart)

Title V

______________________ (SPECIFY rule that led to title V permit requirement)NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 4 of 2 9 State Air Toxics:

_________________________________ (SPECIFY rule name and subpart)

_________________________________ (SPECIFY rule name and subpart)

Other: ___________________________ (SPECIFY emission unit and rule)

_________________________________

Other: ___________________________ (SPECIFY emission unit and rule)

_________________________________

What is meant by the ‘Other’ category above?

If EPA requires a list of all State rules that apply to each facility, this will be listed in the

facility Title V permit.

1 2. Normal Facility Production Hours:

Hours/day:

___________________ Shifts/day: ___________________

Days/week: _

_________________ Weeks/year: __________________

13. Total Amount of aluminum produced in 2009 AND the amount of aluminum produced in

2004 or later, which represents the largest amount of aluminum produced:

_______________ tons of aluminum produced 2009

_______________ tons of aluminum produced in year of highest production

_______________ year

Consideration should be given to this information being CBI protected. Given that 2009 may not

be a representative year for the industry due to the recession, it might be preferable to specify

data from the most representative year instead of 2009.

There is need for a definition of scrap (e.g. whether or not it include internal runaround s crap).

14

. Total Amount of scrap charge d in 2009 AND the amount of scrap charged in 2004 or

later, which represents the largest amount of scrap charged:

_______________ tons of scrap charged in 200 9

_______________ tons of scrap charged in year of highest production

______________ year

Consideration should be given to this information being CBI protected. See comments above for

#13.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 5 of 2 9 15. Approximately what percent of the total facility scrap charged (in #14 above) is clean

(including “run around” ) scrap

_______________ Percent in 2009

_______________ Percent in other year from #14 above ( specify year ) : ________

Method of calculation should be specified as the total input to the facility and not the sum of

inputs to each piece of equipment.

It appears that this question is really addressing ‘clean ch arge’ as defined under section 63.1503.

Clarification is needed, and a definition of clean charge should be included.

Consideration should be given to this information being CBI protected.

16. Please provide a copy of a schematic of the plant layout for equipment in service under

subpart RRR

. Label the schematic with the unit IDs, which should also match the unit

IDs used to respond to later questions.

17. Please provide all of the pertinent information listed below. Please provide electronic

copi es, if available, and indicate items provided below

. Note: Use information from 2004 or later, whichever year has the highest production

rate

. _________(please specify)

(CHECK all that apply ):

□ Title V permit

□ Operating permit (Permit)

□ Permit applica tions (pending only)

□ Performance test reports (submit most recent test reports)

□ Emission inventory reports ( reporting year s should be the same as what years were

chosen in the remainder of the survey )

□ Consent decrees or orders

– this request should b e limited to the last three years.

□ Notice(s) of operating violations

□ S tartup, shutdown, and malfunction (SSM) plan

□ Site

- specific operating, maintenance, and monitoring plan

– Does this mean the

OM&M plan? Or is it referencing the site

- specific monito ring plan ?

The information request should be applicable to air regulations only.

This request should be applicable to Subpart RRR sources only.

We do not understand why consent decrees and NOV’s are included in the survey or for what

purpose such materi als are requested.

Providing the documents requested will effectively substitute filling out some of the tables

included in the survey.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 6 of 2 9 Does EPA need Title V renewal applications as part of “permit applications (pending only)? If

yes, why?

P art B. Facility Equipment Regulated under Subpart RRR (Secondary Aluminum NESHAP) 1

Please provide the information below for all equipment at your facility;

18. Regulated Equipment List

Unit

Identification

Numbers(s)

(Unit ID No.) Unit ID No.

as designated

in Title V or

State

Operating

Permit* Subpart RRR

Equipment Located

at

Facility?

(Y or N) Add

- on

Controls

(Y or N) Operating

in 2009?

(Y or N)

If “No”, list

last year of

operation

Aluminum Scrap

Shredder

Thermal Chip Dryer

Scrap

dryer/delacq uering/

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

Other ( spe cify):

Other ( specify):

Other ( specify):

* 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 well s

o r scrap wells

.

1 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.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 7 of 2 9 What is the purpose of the column ‘located at facility ’ ?

What is meant by the ‘Other’ category?NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 8 of 2 9 Part C. Scrap Charge Rates and Controls Used for Major Sources Subpart RRR MACT

Please provide the information below for all regulated equip ment at your facility; Use

information for this section from 2004 or later, whichever year has the highest production

rate

. _________(please specify)

Consideration should be given to this charge and production related information being CBI

protected. Info rmation should be reportable in emissions per ton of production instead of total

production data.

19. For Each Scrap Shredder

Unit ID

Number * Amount of

Scrap

Charged

(tons/year) Maximum

Capacity of

Unit (tons

scrap/yr) Maximum

Capacity of

Unit ( lbs.

scr ap/ hr ) Control Device

Type Device

ID No.

* Please indicate which of the scrap shredders listed above process only clean charge with no

visible emissions: ____________________________________________________________

Clarify what is the definition of “clean charge” for a scrap shredder? Is this as defined in the

rule? Is this applicable to shredders that use clean charge with no control?

20. For Each Thermal Chip Dryer

Unit ID

Number Amount of

Chips

Charged

(tons /year) Maximum

Capacity of

Unit

(tons chips /yr) Maximum

Capacity of

Unit

( lbs. chips / hr ) Control Device

Type Device

ID No.

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

Unit ID

Number * Amount of

S crap Charged

(tons/year) Maximum

Capacity of

Unit

(tons s crap/yr) Maximum

Capacity of

Unit

( lbs. scrap/ hr ) Control Device *

Type Device

ID No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 9 of 2 9

* If the kiln is equipped with an afterburner operated at a minimum of 7 60°C, with a design

residence time of 1 second minimum, enter the control device ID Nos. here: ________________

22. For Each Dross Only Furnace

Unit ID

Number Amount of

Dross

Charged

(tons/year) Maximum

Capacity of

Unit

(tons dross /yr) Maximum

Capacity of

Unit

( lbs. dross / hr ) Control Device

Type Device

ID No.

23. For Each Rotary Dross Cooler

Unit ID

Number Amount of

Dross

Charged

(tons/year) Maximum

Capacity of

Unit

(tons dross /yr) Maximum

Capa city of

Unit

( lbs. dross / hr ) Control Device

Type Device

ID No.

24. For Each Group 1 Furnace

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Clean

charge

(yes/no) Maximum

Capacity of

Unit

(ton s

charge /year) Maximum

Capacity of

Unit

( lbs.

charge / hr ) Control Device

Type Device

ID No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 10 of 2 9 Capacity may be measured in aluminum pounds produced as an option

.

What is meant by “Clean Charge (yes/no)” ? As examples s hould the answer be “yes” if any material charged during the entire year is not “clean charge” (i.e. near 100 % clean charge ); do

we answer “ yes ” if the furnace processes any clean charge during the time period?

The information concerning maximum capacity of unit

– does it refer to the actual maximum

throughput for a year, or the potential maximum?

Capacity in “lbs. charge/hr” not meaningful parameter for batch furnaces

– cycle times vary wi th

charge material, alloy type and casting opera tion resulting in large variability in lbs charged per

hour

.

25. For Each Group 2 Furnace

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Maximum

Capacity of Unit

(tons

charge /year) Maximum

Capacity of

Unit ( lbs.

charge / hr ) Control Device

Type Device ID

No.

Capacity may be measured in aluminum pounds produced as an option

.

Capacity in “lbs. charge/hr” not meaningful parameter for batch f urnaces

– cycle times vary with

charge material, a lloy type and casting operation.

26

. For Each In

- line Fluxer

Unit ID

Number Amount of

Aluminum

Charged

(tons/yr) Maximum

Capacity of

Unit (tons

charge /year) Maximum

Capacity of

Unit ( lbs.

charge / hr ) Control Device

Type Device ID

No.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 11 of 2 9 Capacity may be measured in aluminum pounds produced.

Note that in

- line fluxers do not run all the time

– only when a batch of metal is being cast from

the furnace.

2 7

. For Each Sweat Furnace

Unit ID

Number * Amount of

Scrap

Charged

(tons/yr) Maximum

Capacity of

Unit (tons

scrap /year) Maximum

Capacity of

Unit ( lbs.

scrap / hr ) Control Device *

Type Device ID

No.

* If the sweat furnace is equipped with an afterburne r operated at a minimum of 1600°F, with a

design residence time of 0.8 second minimum, enter the control device ID here: _____________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 12 of 2 9 2 8

. For E ach Secondary Aluminum Processing Unit (SAPU) Using Emissions Averaging (as per section 63.1505(k) )

a. Com plete this table if your facility chose to measure compliance using the weight of the feed/charge

.

Unit

ID No. Amount of

Feed/

Charge

(tons/year) Charge

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(app roximate) Maximum

Capacity of

Unit (tons

charge/yr) Maximum

Capacity of Unit

( lbs. charge /h r) Control Device

Type Device

ID No.

b. Complete this table if your facility chose to measure compliance using the weight of the alumin um produced

.

Unit

ID No. Amount of

Aluminum

Produced

(tons) Production

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of

Unit

(tons

a luminum/yr) Maximum

Capacity of Unit

( lbs.

aluminum/h r) Control Device

Type Device

ID No.

This question needs discussion and clarification. Consideration should be given to deleting Item 28. The production rate used in the

SAPU emission calculation changes every day depending on whether the unit operated and what the production was that day. Other

information in the tables is duplication of information already requested above under #24 through #26.NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 13 of 2 9 Part D . Scrap Charge Rates and Controls Used for Area Sources Su bpart 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 has the highest production rate

. _________(please specify)

2 9

. For Each Thermal Chip Drye r

Unit

ID No. Amount of Chips

Charged (tons) Maximum

Capacity of Unit

(tons charge /yr) Maximum Capacity

of Unit ( lbs.

charge / h r) Control Device

Type Device

ID No.

30

. For Each Scrap Dryer/Delacquering Kil n/Decoating Kiln

Unit

ID No. Amount of Scrap

Charged (tons/year) Maximum

Capacity of Unit

(tons scrap/yr) Maximum

Capacity of Unit

( lbs. scrap/ h r) Control Device *

Type Device

ID No.

* If the kiln is equipped with an afterburner operated at a minimum of 760°C, with a design residence time of 1 second minimum,

enter the control device ID Nos. here: _______________________________________________________________________NESHAP for Secondary Aluminum (40 CFR part 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 14 of 2 9 31. For Each Group 1 Furnace

Unit ID

Num ber Amount of

Aluminum

Charged

(tons/yr) Clean

charge

(yes/no) Maximum

Capacity of Unit

(tons charge /year) Maximum

Capacity of Unit

( lbs. charge / hr ) Control Device

Type Device ID

No.

Capacity may be m easured in aluminum pounds produced.

32

. For Each Sweat Furnace

Unit ID

Number * Amount of

Scrap

Charged

(tons/yr) Maximum

Capacity of Unit

(tons scrap /year) Maximum

Capacity of Unit

( lbs. scrap / hr ) Control Device *

Type Device ID

* 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: _______

_______________________________________________________________AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 15 of 2 9 33

. 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

.

Unit

ID No. Amount of

Feed/ Charge

(tons/year) Charge

Rate used

to

calculate

emission

limits

(tons/hr) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of

Unit (tons

charge/yr) Maximum

Capacity of

Unit ( lbs.

charge /h r) Control Device

T ype Device

ID No.

b. Complete this table if your facility chose to measure compliance using the weight of the aluminum produced

.

Unit

ID No. Amount of

Aluminum

Produced

(tons) Production

Rate used

to

calculate

emission

limits

(tons/hr ) Percent Clean

Charge

(including

runaround

scrap)

(approximate) Maximum

Capacity of Unit

(tons

a luminum/yr) Maximum

Capacity of Unit

( lbs.

aluminum/h r) Control Device

Type Device

ID No.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 16 of 2 9 Part E. Emissions and Limits

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)

Specify that the information request in this section is for RRR regulated sources.

Please also submit any e mission inventory reports that include these data.

34

. E ach Secondary Aluminum Processing Unit (SAPU) at the facility, if applicable

a. Complete this table if your facility chose to measure compli ance using the weight of the feed/charge ).

Unit

ID No. SAPU Wide

Emission Limits*

PM limit

(lbs. PM/ton charge)* Hydrogen Chloride (HCl)

(lbs. HCL/ton charge)* Dioxin/furan (D/F)

(grains D/F per ton charge)

* Th e charge rate used t o calculate these emission limits should be based on the charge rate during the performance test.

Footnote above is incorrect. SAPU Emission Limit change s daily with the amount of production produced that day in each unit. The

MACT standard is “lb emitt ed/ton aluminum charged” and the amount of emissions “allowed” by the SAPU changes daily depending

on how much material is processed by the emission unit. That way, if a unit does not operate on any given day, it does not contribute

to allowable emissions from the SAPU for that day.

Column labeled “Unit I.D. No.” does not make sense here. Is EPA requesting this information for each “SAPU” at the facility rather

than each “Emission Unit”? If yes, column should be labeled “SAPU I.D. No.”

b. Complete thi s table if your facility chose to measure SAPU compliance using the weight of the aluminum produced

.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 17 of 2 9 Unit

ID No. SAPU Wide

Emission Limits

PM limit

(lbs. PM/ton aluminum)* Hydrogen Chloride (HCl)

(lbs. HCL/ton aluminum)* Dioxin/furan (D/F)

(grains D/F per ton

aluminum)

* T he feed rate used to calculate these emission limits should be based on the weight of the aluminum produced during the

performance test

.

If each piece of equipment meets the individual source emissions limits, this ta ble can be omitted.

Footnote above is incorrect. SAPU Emission Limit changes daily with the amount of production produced that day in each unit. The

MACT standard is “lb emitted/ton aluminum charged” and the amount of emissions “allowed” by the SAPU cha nges daily depending

on how much material is processed by the emission unit. That way, if a unit does not operate on any given day, it does not c ontribute

to allowable emissions from the SAPU for that day.

Column labeled “Unit I.D. No.” does not make se nse here. Is EPA requesting this information for each “SAPU” at the facility rather

than each “Emission Unit”? If yes, column should be labeled “SAPU I.D. No.”AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 18 of 26 35

. a. Emissions for each individual emission unit regulated under subpart RRR, as applicable.

U nit

ID No. Emissions

Unit Name Annual Routine Emissions From Regulated RRR Pollutants Control Device

(from Part C or D above)

Test Data?*

(Y/N) PM

(lb s. /ton) D/F

(grain/ton) HCl

(lb s. /ton) Total Hydrocarbons

(THC) (lbs./ton) Device Type ** Unit

ID No.

* Please provide any test data along with this form.

** If you comply with subpart RRR requirements for sweat furnaces by controlling your afterburner residen ce time, enter “AB/RT”

in the table

.

* ** Please include dio xin/furan congeners

THC data applicable only to delacquerers and dryers

Add column to reference applicable test report. These data are available in existing test reports making this section duplicative.

Define ‘annual routine emis sions’

– we only have emission factors (lb/ton) from performance testing.

b

. Please list all other HAP emissions from equipment subject to 40 CFR 63, subpart RRR.

Equipment/Process

Description Unit ID

Number List each

individual

HAP * CAS# Routine

Emis sion Rate

( lbs. /yr) Maximum

Allowable

(lb s. /yr) Maximum

Allowable

(lbs. /hr)AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 19 of 26 How might this table be applicable? If emissions are not tested are they to be estimated, and if so how? Otherwise a ‘no data’

response should be provided. Are actual data to be included, or emission factors or other estimates to be also used?

c

. Please list estimated HAP emissions from equipment collocated at your facility that are not regulated under 40 CFR 63,

subpart R RR.

Equipment/Process

Description List each individual

HAP CAS# Emission Rate

( lbs. /yr) Maximum

Allowable

(lb s./ yr) Maximum

Allowable

(lb s. /hr)AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 20 of 26 How are emissions t o be estimated? Are actual emission at to be used included, or emission factors or other estimates included? Can

this be a sum of HAP’s for all other sources? Is the use of existing emission inventory acceptabl e?

This survey should be limited to RRR sources.

This request is outside scope of RRR and should be deleted

– other HAP sources are either already regulated under another MACT

categories or they are not part of the Secondary Aluminum MACT category.

P art F. Detailed Control Device and Emission Release Information

Please provide the information below OR o n the enclosed spreadsheet . Please also submit any e mission inventory or test reports

that include these data.

Specify that information request is for RRR regulated 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)

36. A dd

- on air p ollution control device s (use multiple lines if the same control device is used to control more than one pollutant).

Control Devices Units

Controlled

Device Type* Device

ID No. Pollutant

Controlled Capture

Efficiency (if

known)

(percent) Control

Device

Ef

ficiency

(if Known)

(percent) Overall

Efficiency, if

known

(percent) Methods Used for

Determining Capture

& Control

Efficiencies**(a

- c)

Type(s) of Unit Unit

ID No.

* For example, afterburner, lime coated fabric filter, etc.

** Control & Capture EfficiencyAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 21 of 26 a = Testing (specify method)

b = Manufacturer's Specifications

c = Engineering Estimate

Please provide any additional information concerning the Control Devices:

____________________________________________________________________________________________________________

____________________________________________________________________________________________________________

____________________________________________________________________________________________________________

____________________________________________________________________________________________________________

Capture efficiency data not required under RRR, and therefore not known at most facil ities.

37. For each stack/ control device exhaust point , please provide the following information, if known , related to the information in

Item #36 above.

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)

Diameter

(ft) Area

(sq. ft.) Maximum Minimum

* Longitude and Latitude should be specified ou t to 5 decimal places. I f coordinates are not known , p lease provide a scale d site

diagram, with a latitude/longitude reference point, indicating stack locations

.

Information on mapping or coordinates should be provided if available. Emission test plans s hould provide a substitute.

38. For each exhaust point/stack not associated with a control device, please provide the following information, if known :AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 22 of 26 Unit ID What control

devices are vented at

this point? Height of stack

or discharge (ft) Discharge Exi t Gas

Temperature

(degrees F) Latitude* Longitude* Flow Rate (SCFM)

Diameter

(ft) Area

(sq. ft.) Maximum Minimum

• Longitude and Latitude should be specified out to 5 decimal plac es. If coordinates are not known, p lease provide a scale d site

diagram, indicating stack locations.

Information on mapping or coordinates should be provided if available. Emission test plans should provide a substitute.

Data is available from the Natio nal Emissions Inventory (NEI) from relevant States.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 23 of 2 9 39

. For each affected source listed in [Section B, above] , identify the date(s) of latest

NESHAP compliance testing.

Subpart RRR sources should be specified.

Date

Tested Emission Unit

Test Method

Used Poll utant(s)

Tested Emissions

(Specify Units) Unit Name Unit ID No.

Emission test reports should provide substitute for table data entries.

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?

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?

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?

* Where two or more co

- controlled furnaces were tested simultaneously, list all furnace IDs.

The minu tes a charged door is open not required under RRR, and may be variable depending on

charge type and size.

b

. For each sidewell (scrapwell) furnace listed in response to 39a: Delete ‘scrapwell’

term as it is not noted in RRR.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 24 of 2 9 Furnace ID

Was reactive fl ux used in the sidewell,

hearth, both, or neither?

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 t he sidewell and hearth during

periods of reactive fluxing?

How was the molten metal level

monitored?

c

. For each G roup 1 furnace that is not ducted to a control device :

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 air emissions escaping

from the furnace doors, etc.?

Were visible emissions monitored

during the performance test?

Were visible emissions observed

during the performance test?

d

. For each Group 1 furnace tha t is ducted to a control device :

Furnace ID

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 th e furnace doors, etc.?

Requested information should focus on adequate ventilation rate and excess fugitive

emission observations.AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 25 of 2 9 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?

If yes, please describe.

Were visible emissions monitored

during the performance test?

Were visib le emissions observed

during the performance test?

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.?

Part G. Faci lity Operation s

40. General

a. What type of pretreatment (e. g. air drying, centrifugal drying, etc.) or presorting

takes places to get the aluminum scrap ready for processing?

What is the definition or presorting?

_____________________________________________________________________

b. Do you track the amount of a luminum 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?

_____________________________________________________________________

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 ?

________________________________________________________________ _____AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 26 of 2 9 41. Fluxing

a. What fluxes were used in 2009 or the most recent year of normal operation? Please

attach MSDS for each f lux:

Flux

Identification Flux Still in

Use?

(Yes or No) Mass Used

(lb s. /yr) Furnace or in

line fluxer ID

in which flux

was used Purpose (e.g.

cover, degassing,

demagging, etc.)

Define cover flux inc luding examples.

b

. If you have sidewell (scrapwell) furnaces, did you use reactive f lux in the sidewell

and the hearth? If so, d id you test emissions from both sources?

_____________________________________________________________________

c. D o you use different types or quantities of flux for different flux applicatio ns? If so,

how do the procedures differ?

_____________________________________________________________________

d

. What are your flux rate operatin g and monitoring procedures?

_____________________________________________________________________

e. Do you have any fluoride emission data? If so, please provide or indicate here.

__________ tons/yr fluoride emissions (or lbs. F /to n charge)?

Fluoride emission data are not required under RRR, and therefore may not be available

from facilities. However, emission data was obtained on fluoride emissions from the

testing program conducted in developing the MACT rule under RRR.

f. For any cover fluxes listed, do you perform any agitation of these fluxes?

__________ If “yes”, does the agitation include only the surface or the entire depth of

the melt? __________________________________________________________AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 27 of 2 9 Clarify that molten me tal circulation below the surface does not constitute ‘agitation’.

42. Controls

a

. Do you use any alternative control devices (i. e. control devices other than fabric

filters, lime

- coated fabric filters, or afterburners) , monitoring, or operating con ditions

at this fa cility (i.e., ceramic air filters)?

_____________________________________________________________________

b

. Have you ever injected activated carbon or other type of carbon for HAP control?

What barriers do you envision to addi ng carbon injection to fabric filters for HAP

control (check as many as apply ) ?

□ Cost of activated carbon

□ Creates problems with disposal of material collected by baghouse

□ Other (specify): ____________________________________________

Question on the use of activated carbon should apply o nly to routine use, not to R&D

testing.

c

. Do you use catalytic filters for dioxin control (e.g.,

http://www.donaldson.com/en/industrialair/literature/051754.pdf ) ?

.

_____________________________________________________________________

d. Do y ou 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.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

, For the control technologies identified and liste d in 42d above, please provide cost information:

Unit ID

No. Control Device Total

Capital

Investment Total

Annual

Operating

and

Maintenance

Costs Base Year

for

Operating

Costs Type/Description Device ID.

No.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 28 of 2 9 43. Pollu tion Prevention

A. Describe any procedures you use at your facility to prevent pollution (as opposed to

controlling pollution after it is formed). Specify that procedures applicable for air emissions

related to RRR

______________________________________________________________________________

B. Have you implemented any work practice standards or standard operating procedures

that will further reduce HAP emissions? ___ If so, please specify.

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 29 of 2 9 Part H. Startup and Shutdown

44. For each startup and shutdown event that occurred over the last 3 years, please provide the

following information. If this information is contained in periodic and immediate SSM reports

(either stand

- alone or contained within the periodic excess emissions repo rt) submitted to your

permitting authority, you may submit copies of those reports instead.

This section should be limited to startups and shutdowns that caused excess emissions only.

Such records are required only when excess emissions occur. The amou nt of data over a three

year period is excessive. Request should be for 2009 only.

Startup/Shutdown*

D escription of the event, including

identification of the emissions source or

sources [unit ID(s)] associated with the

startup or shutdown

Was a ny permit condition was exceeded

and, if so, what permit condition was

exceeded

Was the event was 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

Duration of the event

A ctions 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 hav e the ability to quantify

emissions during the event, please

explain why

Was the emission profile of each unit

was different during startup and

shutdown than during normal operating

conditions and, if so, how emissions

were different and why. Please provide

any supporting information

List performance test data collected

during each period of startup or

shutdown, the test method used for each

event; when the testing was conductedAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 30 of 2 9 * Startup : the commencement of operation of an affected s ource 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

45. Are there any types of startup or shutdown events that you have been able to eliminat e; if so,

please describe the type of event and explain how these events were eliminated.

46. Optional: Do you wish to recommend a standard that would apply during startup and/or

shutdown? If so, please describe the type of event 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 ev ent; and how would compliance be

determined and/or monitored. and why; the test conditions at the time

of testing; and whether the tests were

associated with a routine startup or

shutdown

List monitoring data, including control

system parameter monitoring, collected

during each period of startup and

shutdownAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc Page 31 of 2 9 Part I. Criteria Air Pollutants (CAP)

Please provide the information below OR i n the enclosed spreadsheet . Please also submit any e mission inventory or test reports

that include these dat a.

This section should be voluntary, or eliminated as it does not apply to RRR emissions requirements

.

Please provide the information below for all regulated equipment at your facility; Use information for this section from 2004 or later,

whichever yea r has the highest production rate

. _________(please specify)

47. CAP emissions by unit for each emission unit subject to 40 CFR 63, subpart RRR

* Please provide any test data along with these sections

.

ID

No. Emission

Unit CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOx

b. Please list estimated C AP emissions from equipment collocated at your facility that is not regulated under 40 CFR 63,

su bpart RRR.

ID

No. Emission

Unit CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOxAL Assn comments on EPA 114 survey form 5

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- 10.doc Page 32 of 2 9 48. Control devices used for CAP emission control

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

Part J

. Energy Usage

Please provide the information below OR i n the enclosed spreadsheet

.

This section should be limited to RRR sources only.

49. Please list total annual energy consumption.

Combustion Units (Include Emergency Combustion Equipment) Unit Unit Unit Unit Unit

Process Unit ID:

Equipment ID:

Type of Combustion Equipment:

Year Built: why is this relevant?

Number of Operating Hours per Year:

Design Capacity (Heat Input) (MMBtu/hr):

Fuel Type:

Heat Release Rate (Btu/scf):

Is the unit subject to NSPS?

If yes, indicate the year:

Start

- up Fuel/MaterialAL Assn comments on EPA 114 survey form 5

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- 10.doc Page 33 of 2 9 Start

- up fuel:

Typical Start

- up fuel amount (Spe cify Units)

Typical length of time for start

- up (hours):

Higher heating value (HHV):

Fuels/Materials Combusted During Normal Operations (include solid, liquid, and gas

waste streams)

Fuel #1 Usage: (Specify Units)

Hours used per year:

Higher heating value (HHV):

Fuel #2 Usage: (Specify Units)

Hours used per year:

Higher heating value (HHV):

Fuel # 3 Usage: (specify Units

Hours used per year:

Higher heating value (HHV):

Consideration s hould be given to this information being CBI protected. Request should apply only to production equipment and not to

emergency equipment and building services. Heat release rate should be deleted. Fuel/Materials section irrelevant if same a s normal

oper ations. Fuel usage per year is generally not available for individual units.

This data is not available for individual emission units and is not relevant to RRR HAP emission standards.

50. Are any Cogeneration units listed above, if so please list th e unit and describe the process for

each?____________________________________________________________________________________

_________________________________________________________________________________________

__________________________________________________________________________________________AL Assn comments on EPA 114 survey form 5

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- 10.doc Page 34 of 2 9 51. Electricity Usage

– applicable to RRR units only?

Normal

Operating

Annual

Electricity

Usage Year Usage (Specify Units)

Consideration should be given to this information being CBI protec ted.

K. Miscellaneous Information

52 . Were there any problems that were encountered during the permitting process of your facility due to the way the rule is written in

subpart RRR?

53. What specific improvements or rule changes would you like to see that would help your facility with compliance or better rule

interpretation?NESHAP for Secondary Aluminum (40 CFR pa rt 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc A

- 1 Attachment A. Definitions (from subpart RRR)

Afterburner means an air pollution control device that uses controlled flame combustion to convert

combustible materials to nonc ombustible gases; also known as an incinerator or a thermal oxidizer.

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/decoati ng kiln, or

furnace. A bale breaker is not an aluminum scrap shredder.

Dross

- only furnace means a furnace, typically of rotary barrel design, dedicated to the reclamation of

aluminum from dross formed during melting, holding, fluxing, or alloying operat ions carried out in

other process units. Dross and salt flux are the sole feedstocks to this type of furnace.

Group 1 furnace means a furnace of any design that melts, holds, or processes aluminum that contains

paint, lubricants, coatings, or other forei gn materials with or without reactive fluxing, or processes clean

charge with reactive fluxing.

Group 2 furnace means a furnace of any design that melts, holds, or processes only clean charge and

that performs no fluxing or performs fluxing using only no nreactive, 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 wat er

- cooled rotary barrel device that accelerates cooling of dross.

Scrap dryer/delacquering kiln/decoating kiln means 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 o f the group 1 furnaces or in

- line fluxers

within a new SAPU is considered an emission unit within that secondary aluminum processing unit.

Sidewell means an open well adjacent to the hearth of a furnace with connecting arches between the

hearth and the op en 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.NESHAP for Secondary Aluminum (40 CFR pa rt 63, subpart RRR)

AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc A

- 2 Sweat furnace means 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 d ryer means a device that uses heat to evaporate water, oil, or oil/water mixtures from

unpainted/uncoated aluminum chips.AL Assn comments on EPA 114 survey form 5

- 18

- 10.doc B

- 1 Appendix B



### Section 112(b) List of Hazardous Air Pollutants (HAP)

U.S. Code Title 42, Chapter 85, Subchapter 1, Part A, § 7412

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

- Ami nobiphenyl

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 ChlorobenzeneAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc B

- 2 510156 Chlorobenzilate

67663 Chloroform

107302 Chloromethyl methyl ether

126998 Chloroprene

1319773 Cresols/Cresylic acid (isomers and mixture)

95 487 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

5 1285 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

5179 6 Ethyl carbamate (Urethane)

75003 Ethyl chloride (Chloroethane)AL Assn comments on EPA 114 survey form 5

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- 10.doc B

- 3 106934 Ethylene dibromide (Dibromoethane)

107062 Ethylene dichloride (1,2

- Dichloroethane)

107211 Ethylene glycol

151564 Ethylene imine (Aziridine)

75218 Ethylene oxide

96457 Et hylene thiourea

75343 Ethylidene dichloride (1,1

- Dichloroethane)

50000 Formaldehyde

76448 Heptachlor

118741 Hexachlorobenzene

87683 Hexachlorobutadiene

77474 Hexachlorocyclopentadiene

67721 Hexachloroethane

822060 Hexamethylene

- 1,6

- diisocya nate

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 Me thanol

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

- Methylenedianili ne

91203 Naphthalene

98953 Nitrobenzene

92933 4

- Nitrobiphenyl

100027 4

- NitrophenolAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc B

- 4 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 b eta

- 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 Styr ene 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

9553 4 o

- Toluidine

8001352 Toxaphene (chlorinated camphene)

120821 1,2,4

- Trichlorobenzene

79005 1,1,2

- Trichloroethane

79016 Trichloroethylene

95954 2,4,5

- Trichlorophenol

88062 2,4,6

- Trichlorophenol

121448 Triethylamine

1582098 Trifluralin

5408 41 2,2,4

- TrimethylpentaneAL Assn comments on EPA 114 survey form 5

- 18

- 10.doc B

- 5 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 Mangan ese 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

.

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

– (OCH 2 C H 2 )n

– OR where

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

– (OCH 2 CH)n

– OH. Polymers are excluded from the glycol category.

3 Includes mineral fiber emissions from facilities ma nufacturing or processing glass, rock, or

slag fibers (or other mineral derived fibers) of average diameter 1 micrometer or less.

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.AL Assn comments on EPA 114 survey form 5

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- 10.doc B

- 6