June 8, 2010 

Memorandum 

Subject: Summary of Meeting of with Aluminum Association 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 request 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 would consider all the comments when 

drafting the next version of the information collection request. 

II. Place and Date

 The meeting was held at the U. S. Environmental Protection 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 teleconference 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" producers. 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 proportion of the ~400 facilities thought (by 

EPA) to be subject to the secondary aluminum production NESHAP. AA representatives 
2 

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

sweat furnace operators. 

 B. Technology Review

 EPA personnel described plans for the technology review 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 given as examples. 

 C. Confidential business information

 In order to assess residual risk on the basis of emission 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. Certain 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 air 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 production are often available. Industry 

representatives considered nameplate capacity of particular 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 information 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 information were distributed (Attachments 4 through 

6). 

 D. Speciated organic HAP and particulate metal HAP emissions data

 EPA's risk modeling approach depends on HAP-specific 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 concern about the cost and utility of required 

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

devices in information gathering during the development of the NESHAP (approximately 1990 

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

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

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

analyze samples from multiple identical affected sources equipped with identical control devices. 

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

 The NESHAP contains no emission limits for HF. Industry 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 data 
3 

were obtained in the testing program conducted as part of the development of the NESHAP 

(1990-1996), and that HF presented a much lower toxicity 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 American Congress of Government Industrial 

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

 G. Industry comments on draft information collection 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 Association 


Attachment 3, p. 1

Mr. XXXXXXXX, President

XXXXXXXX

XXXXXXXX

XXXXXXXX

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

Dear Mr. XXXXX:

Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental 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 regulations involves gathering and analyzing 

information. We are seeking information specific to your company’s facilities 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 of 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 surveys and return them to us by the deadline.

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

secondary aluminum production under section 112(d) of the CAA on March 23, 2000. We are 

now in the process of collecting updated information concerning hazardous air pollutant (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 technologies 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 surveys, we request information on secondary aluminum processes, 

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

complete and return to us in electronic format. If we presently have National Emissions 

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

existing data for your facility. You 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 the information you provide to us in this survey, along with similar information we 

receive from other companies in your industry, we will determine the amount of HAPs emitted;

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

economic impacts associated 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 contains a summary of our legal authority in section 114 of the CAA to 

obtain the information requested in this 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, please do not label your entire response “Confidential” if only a portion 

includes trade secrets. 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 this

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

September 1, 1976).

Because section 114 of the CAA does not allow emission data to be claimed 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 Enclosure 5.

We have contracted RTI International (RTI) (Contract No. EP-D-06-118) to help us 

gather information about your industry. As 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. 7414(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 incorporated 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 requesting, 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 Ms. Boyd at the address below by XXX

XX, 20XX.

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 request includes data with a claim of 

confidential business information, please 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 Park, 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 NOT 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 information 

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 Standards 
Attachment 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 authority

Enclosure 5: Clarification 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 5

1

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 2002
2

“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 data 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 standard 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 compliance 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 a
3

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 immediately 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 containing 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 the 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 authorized 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. No
4

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 other 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 employees 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 by
5

EPA which contain CAA CBI must be stamped “Subject 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 cover 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 edited 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), Congress 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 Section 110 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 Counsel 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, request that EPA treat such information as confidential. 

Information obtained under Section 114 and 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, substantive criteria to be used in such 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 Information 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 confidential 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 against 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 position, and if so, what those harmful effects would be, 

why they should be viewed as substantial, and an explanation 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 29

Secondary Aluminum (40 CFR part 63, subpart RRR)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

Aluminum Association Comments 5/17/2010

Aluminum Association comments to the Section 114 survey form included in red text as follows.

General 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. 

Confidential 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 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 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 request 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. Facility Information

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 29

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

a. Address: ____________________________________________________________

b. City: ________________________________________________________________

c. State: _______________________________________________________________

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. Name (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 page 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 facility, plant engineer or supervisor.

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

(CHECK one)

EPA Major Source of Hazardous Air Pollutants (HAP):

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

EPA Area source (Synthetic Minor) of HAP

7. Facility NAICS codes

Note: The primary NAICS code represents the line of business that generates the most 

income for the facility

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 29

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

___ 500-749

___ 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 company 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 apply to this facility). 

___ Subpart RRR (Secondary Aluminum)

____ Diecasting Operations

____ 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 29

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. 

12. 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 scrap).

14. Total Amount of scrap charged 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 2009

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

ATT7.doc Page 5 of 29

_______________ 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 charge‟ 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 

copies, 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 applications (pending only)

□ Performance test reports (submit most recent test reports)

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

chosen in the remainder of the survey)

□ Consent decrees or orders – this request should be limited to the last three years.

□ Notice(s) of operating violations

□ Startup, 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 monitoring 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 materials 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 29

Part 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/delacquering/ 

decoating kiln

Group 1 FurnaceClean charge only**

Group 1 FurnaceHandling other than 

clean charge**

Group 2 Furnace**

In-line Fluxer 

Dross-only Furnace

Rotary Dross Cooler

Sweat Furnace

Other (specify):

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 wells 

or 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 29

Part C. Scrap Charge Rates and Controls Used for Major Sources Subpart RRR MACT 

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

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

rate._________(please specify)

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

protected. Information 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.

scrap/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 

Scrap 

Charged 

(tons/year)

Maximum 

Capacity of 

Unit 

(tons scrap/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 29

*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: ________________

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 

Capacity 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 

(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 9 of 29

Capacity may be measured in aluminum pounds produced as an option.

What is meant by “Clean Charge (yes/no)”? As examples should 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 with

charge material, alloy type and casting operation 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 furnaces – cycle times vary with 

charge material, alloy 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 29

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.

27. 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 afterburner 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 29

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

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

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/hr)

Control Device

Type 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 

aluminum/yr)

Maximum 

Capacity of Unit 

(lbs. 

aluminum/hr)

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 29

Part D. Scrap Charge Rates and Controls Used for Area Sources Subpart RRR MACT

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

whichever year has the highest production rate._________(please specify)

29. For Each Thermal Chip Dryer

Unit

ID No.

Amount of Chips 

Charged (tons)

Maximum 

Capacity of Unit 

(tons charge/yr)

Maximum Capacity 

of Unit (lbs.

charge/hr)

Control Device

Type

Device

ID No.

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

Unit

ID No.

Amount of Scrap 

Charged (tons/year)

Maximum 

Capacity of Unit 

(tons scrap/yr)

Maximum 

Capacity of Unit 

(lbs. scrap/hr)

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 29

31. For Each Group 1 Furnace

Unit ID 

Number

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 measured 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 29

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/hr)

Control Device

Type

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 

aluminum/yr)

Maximum 

Capacity of Unit 

(lbs.

aluminum/hr)

Control Device

Type

Device

ID No.
ATT7.doc Page 15 of 29

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 emission inventory reports that include these data.

34. Each Secondary Aluminum Processing Unit (SAPU) at the facility, if applicable

a. Complete this table if your facility chose to measure compliance 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) 

* The charge rate used to calculate these emission limits should be based on the charge rate during the performance test.

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 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 this table if your facility chose to measure SAPU compliance using the weight of the aluminum produced.
ATT7.doc Page 16 of 29

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)

* The 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 table 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 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.”
ATT7.doc Page 17 of 26

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

Unit

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

(lbs./ton)

D/F

(grain/ton)

HCl 

(lbs./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 residence time, enter “AB/RT” 

in the table.

* **Please include dioxin/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 emissions‟ – 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 

Emission Rate 

(lbs./yr)

Maximum 

Allowable 

(lbs./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 RRR.

Equipment/Process 

Description

List each individual 

HAP CAS# Emission Rate (lbs./yr)

Maximum 

Allowable 

(lbs./yr)

Maximum 

Allowable 

(lbs./hr)
ATT7.doc Page 19 of 26

How are emissions to 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 acceptable?

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. 

Part F. Detailed Control Device and Emission Release Information

Please provide the information below OR on the enclosed spreadsheet. Please also submit any emission 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. Add-on air pollution control devices (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 

Efficiency 

(if Known)

(percent)

Overall 

Efficiency, if 

known 

(percent)

Methods Used for 

Determining Capture 

& Control 

Efficiencies**(a-c)

Type(s) of Unit

Unit

ID No.

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

** Control & Capture Efficiency 
ATT7.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 facilities.

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 out to 5 decimal places. If coordinates are not known, please provide a scaled site 

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

Information on mapping or coordinates should be provided if available. Emission test plans should 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 Exit 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 places. If coordinates are not known, please provide a scaled 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 National Emissions Inventory (NEI) from relevant States.
ATT7.doc Page 22 of 29

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

Pollutant(s) 

Tested

Emissions 

Unit Name Unit ID No. (Specify Units)

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 minutes 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 29

Furnace ID

Was reactive flux 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 the sidewell and hearth during 

periods of reactive fluxing?

How was the molten metal level 

monitored?

c. For each Group 1 furnace that is not ducted to a control device:

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 that 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 the furnace doors, etc.?

Requested information should focus on adequate ventilation rate and excess fugitive 

emission observations.
ATT7.doc Page 24 of 29

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 visible 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. Facility Operations 

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 aluminum produced as well as the amount of charge?

_____________________________________________________________________

c. Could you develop and report your emission rates in terms of amount of emissions 

per unit of aluminum produced? If not, what prevents you from doing so?

_____________________________________________________________________

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 29

41. Fluxing

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

attach MSDS for each flux:

Flux 

Identification

Flux Still in 

Use? 

(Yes or No)

Mass Used 

(lbs./yr)

Furnace or inline fluxer ID 

in which flux 

was used

Purpose (e.g. 

cover, 

degassing, 

demagging, etc.)

Define cover flux including examples.

b. If you have sidewell (scrapwell) furnaces, did you use reactive flux in the sidewell 

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

_____________________________________________________________________

c. Do you use different types or quantities of flux for different flux applications? If so, 

how do the procedures differ?

_____________________________________________________________________

d. What are your flux rate operating 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 /ton 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 29

Clarify that molten metal 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 conditions 

at this facility (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 adding 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 only 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 you have any plans to install any new higher efficiency rated control devices or 

have any pending applications to add on any new controls? If so, please specify and 

include any copies of pending permit applications as requested in Part A, item #17.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

, For the control technologies identified and listed 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 29

43. Pollution 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 29

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 report) 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 amount of data over a three 

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

Startup/Shutdown*

Description of the event, including 

identification of the emissions source or 

sources [unit ID(s)] associated with the 

startup or shutdown

Was any permit condition was exceeded 

and, if so, what permit condition was 

exceeded

Was the event 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

Actions taken to minimize emissions 

during the event, including the use of 

any backup control systems

Estimates or measurements, if any, of 

emissions during the event; if you did 

not have the ability to quantify 

emissions during the event, please 

explain why

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 conducted 
ATT7.doc Page 29 of 29

*Startup: the commencement of operation of an affected source or portion of an affected source 

for any purpose.

Shutdown: the cessation of operation of an affected source or portion of an affected source for 

any purpose

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

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

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 event; 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 

shutdown
ATT7.doc Page 30 of 29

Part I. Criteria Air Pollutants (CAP)

Please provide the information below OR in the enclosed spreadsheet. Please also submit any emission inventory or test reports 

that include these data. 

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 year 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 CAP emissions from equipment collocated at your facility that is not regulated under 40 CFR 63, 

subpart RRR.

ID 

No.

Emission

Unit

CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOx
ATT7.doc Page 31 of 29

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 in 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/Material
ATT7.doc Page 32 of 29

Start-up fuel:

Typical Start-up fuel amount (Specify 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 should 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 as normal 

operations. 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 the unit and describe the process for 

each?____________________________________________________________________________________

_________________________________________________________________________________________

__________________________________________________________________________________________
ATT7.doc Page 33 of 29

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 protected.

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 part 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 noncombustible 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/decoating 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 operations 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 foreign 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 nonreactive, non-HAP-containing/non-HAPgenerating gases or agents.

In-line fluxer means a device exterior to a furnace, located in a transfer line from a furnace, used to 

refine (flux) molten aluminum; also known as a flux box, degassing box, or demagging box. 

Melting/holding furnace, or melter/holder, means a group 1 furnace that processes only clean charge, 

performs melting, holding, and fluxing functions, and does not transfer molten aluminum to or from 

another furnace.

Rotary dross cooler means a water-cooled rotary barrel device that accelerates cooling of dross.

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 of 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 open well through which molten aluminum is circulated between the hearth, where heat is 

applied by burners, and the open well, which is used for charging scrap and solid flux or salt to the 

furnace, injecting fluxing agents, and skimming dross.
NESHAP for Secondary Aluminum (40 CFR part 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 dryer 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-Aminobiphenyl

62533 Aniline

90040 o-Anisidine

1332214 Asbestos

71432 Benzene (including benzene from gasoline)

92875 Benzidine

98077 Benzotrichloride

100447 Benzyl chloride

92524 Biphenyl

117817 Bis(2-ethylhexyl)phthalate (DEHP)

542881 Bis(chloromethyl)ether

75252 Bromoform

106990 1,3-Butadiene

156627 Calcium cyanamide

133062 Captan

63252 Carbaryl

75150 Carbon disulfide

56235 Carbon tetrachloride

463581 Carbonyl sulfide

120809 Catechol

133904 Chloramben

57749 Chlordane

7782505 Chlorine

79118 Chloroacetic acid

532274 2-Chloroacetophenone

108907 Chlorobenzene
ATT7.doc B-2

510156 Chlorobenzilate

67663 Chloroform

107302 Chloromethyl methyl ether

126998 Chloroprene

1319773 Cresols/Cresylic acid (isomers and mixture)

95487 o-Cresol

108394 m-Cresol

106445 p-Cresol

98828 Cumene

94757 2,4-D, salts and esters

3547044 DDE

334883 Diazomethane

132649 Dibenzofurans

96128 1,2-Dibromo-3-chloropropane

84742 Dibutylphthalate

106467 1,4-Dichlorobenzene(p)

91941 3,3-Dichlorobenzidene

111444 Dichloroethyl ether (Bis(2-chloroethyl)ether)

542756 1,3-Dichloropropene

62737 Dichlorvos

111422 Diethanolamine

121697 N,N-Diethyl aniline (N,N-Dimethylaniline)

64675 Diethyl sulfate

119904 3,3-Dimethoxybenzidine

60117 Dimethyl aminoazobenzene

119937 3,3-Dimethyl benzidine

79447 Dimethyl carbamoyl chloride

68122 Dimethyl formamide

57147 1,1-Dimethyl hydrazine

131113 Dimethyl phthalate

77781 Dimethyl sulfate

534521 4,6-Dinitro-o-cresol, and salts

51285 2,4-Dinitrophenol

121142 2,4-Dinitrotoluene

123911 1,4-Dioxane (1,4-Diethyleneoxide)

122667 1,2-Diphenylhydrazine

106898 Epichlorohydrin (l-Chloro-2,3-epoxypropane)

106887 1,2-Epoxybutane

140885 Ethyl acrylate

100414 Ethyl benzene

51796 Ethyl carbamate (Urethane)

75003 Ethyl chloride (Chloroethane)
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 Ethylene thiourea

75343 Ethylidene dichloride (1,1-Dichloroethane)

50000 Formaldehyde

76448 Heptachlor

118741 Hexachlorobenzene

87683 Hexachlorobutadiene

77474 Hexachlorocyclopentadiene

67721 Hexachloroethane

822060 Hexamethylene-1,6-diisocyanate

680319 Hexamethylphosphoramide

110543 Hexane

302012 Hydrazine

7647010 Hydrochloric acid

7664393 Hydrogen fluoride (Hydrofluoric acid)

123319 Hydroquinone

78591 Isophorone

58899 Lindane (all isomers)

108316 Maleic anhydride

67561 Methanol

72435 Methoxychlor

74839 Methyl bromide (Bromomethane)

74873 Methyl chloride (Chloromethane)

71556 Methyl chloroform (1,1,1-Trichloroethane)

60344 Methyl hydrazine

74884 Methyl iodide (Iodomethane)

108101 Methyl isobutyl ketone (Hexone)

624839 Methyl isocyanate

80626 Methyl methacrylate

1634044 Methyl tert butyl ether

101144 4,4-Methylene bis(2-chloroaniline)

75092 Methylene chloride (Dichloromethane)

101688 Methylene diphenyl diisocyanate (MDI)

101779 4,4-Methylenedianiline

91203 Naphthalene

98953 Nitrobenzene

92933 4-Nitrobiphenyl

100027 4-Nitrophenol
ATT7.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 beta-Propiolactone

123386 Propionaldehyde

114261 Propoxur (Baygon)

78875 Propylene dichloride (1,2-Dichloropropane)

75569 Propylene oxide

75558 1,2-Propylenimine (2-Methyl aziridine)

91225 Quinoline

106514 Quinone

100425 Styrene

96093 Styrene oxide

1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin

79345 1,1,2,2-Tetrachloroethane

127184 Tetrachloroethylene (Perchloroethylene)

7550450 Titanium tetrachloride

108883 Toluene

95807 2,4-Toluene diamine

584849 2,4-Toluene diisocyanate

95534 o-Toluidine

8001352 Toxaphene (chlorinated camphene)

120821 1,2,4-Trichlorobenzene

79005 1,1,2-Trichloroethane

79016 Trichloroethylene

95954 2,4,5-Trichlorophenol

88062 2,4,6-Trichlorophenol

121448 Triethylamine

1582098 Trifluralin

540841 2,2,4-Trimethylpentane
ATT7.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 Manganese Compounds

0 Mercury Compounds

0 Fine mineral fibers 3

0 Nickel Compounds

0 Polycyclic Organic Matter 4

0 Radionuclides (including radon) 5

0 Selenium Compounds

NOTE: For all listings above which contain the word “compounds” and for glycol ethers, the 

following applies: Unless otherwise specified, these listings are defined as including any 

unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) 

as part of that chemical’s infrastructure.

1 XCN where X = H or any other group where a formal dissociation may occur. For example 

KCN or Ca(CN)2.

2

Includes mono- and di- ethers of ethylene glycol (except for ethylene glycol

monobutyl ether (CAS Number 111–76–2), diethylene glycol, and triethylene glycol R–

(OCH2CH2)n–OR where

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–

(OCH2CH)n–OH. Polymers are excluded from the glycol category.

3

Includes mineral fiber emissions from facilities manufacturing or processing glass, rock, or 

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

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 29

Secondary Aluminum (40 CFR part 63, subpart RRR)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

Aluminum Association Comments 5/17/2010

Aluminum Association comments to the Section 114 survey form included in red text as follows.

General 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. 

Confidential 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 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 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 request 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. Facility Information

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 29

______________________________________________________________________________

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

a. Address: ____________________________________________________________

b. City: ________________________________________________________________

c. State: _______________________________________________________________

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. Name (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 page 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 facility, plant engineer or supervisor.

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

(CHECK one)

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

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

EPA Area source (Synthetic Minor) of HAP

7. Facility NAICS codes

Note: The primary NAICS code represents the line of business that generates the most 

income for the facility

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 29

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

___ 500-749

___ 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 company 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 apply to this facility). 

___ Subpart RRR (Secondary Aluminum)

____ Diecasting Operations

____ 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 29

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. 

12. 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 scrap).

14. Total Amount of scrap charged 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 2009

_______________ 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 29

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 charge’ 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 

copies, 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 applications (pending only)

□ Performance test reports (submit most recent test reports)

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

chosen in the remainder of the survey)

□ Consent decrees or orders – this request should be limited to the last three years.

□ Notice(s) of operating violations

□ Startup, 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 monitoring 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 materials 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 29

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

yes, why? 

Part 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/delacquering/ 

decoating kiln

Group 1 FurnaceClean charge only**

Group 1 FurnaceHandling other than 

clean charge**

Group 2 Furnace**

In-line Fluxer 

Dross-only Furnace

Rotary Dross Cooler

Sweat Furnace

Other (specify):

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 wells 

or 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 29

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 5-18-10.doc Page 8 of 29

Part C. Scrap Charge Rates and Controls Used for Major Sources Subpart RRR MACT 

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

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

rate._________(please specify)

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

protected. Information 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.

scrap/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 

Scrap 

Charged 

(tons/year)

Maximum 

Capacity of 

Unit 

(tons scrap/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 29

*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: ________________

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 

Capacity 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 

(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 10 of 29

Capacity may be measured in aluminum pounds produced as an option.

What is meant by “Clean Charge (yes/no)”? As examples should 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 with

charge material, alloy type and casting operation 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 furnaces – cycle times vary with 

charge material, alloy 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 29

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.

27. 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 afterburner 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 29

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

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

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/hr)

Control Device

Type 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 

aluminum/yr)

Maximum 

Capacity of Unit 

(lbs. 

aluminum/hr)

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 29

Part D. Scrap Charge Rates and Controls Used for Area Sources Subpart RRR MACT

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

whichever year has the highest production rate._________(please specify)

29. For Each Thermal Chip Dryer

Unit

ID No.

Amount of Chips 

Charged (tons)

Maximum 

Capacity of Unit 

(tons charge/yr)

Maximum Capacity 

of Unit (lbs.

charge/hr)

Control Device

Type

Device

ID No.

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

Unit

ID No.

Amount of Scrap 

Charged (tons/year)

Maximum 

Capacity of Unit 

(tons scrap/yr)

Maximum 

Capacity of Unit 

(lbs. scrap/hr)

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 29

31. For Each Group 1 Furnace

Unit ID 

Number

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 measured 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 5-18-10.doc Page 15 of 29

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/hr)

Control Device

Type

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 

aluminum/yr)

Maximum 

Capacity of Unit 

(lbs.

aluminum/hr)

Control Device

Type

Device

ID No.
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 16 of 29

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 emission inventory reports that include these data.

34. Each Secondary Aluminum Processing Unit (SAPU) at the facility, if applicable

a. Complete this table if your facility chose to measure compliance 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) 

* The charge rate used to calculate these emission limits should be based on the charge rate during the performance test.

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 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 this 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 29

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)

* The 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 table 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 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.”
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.

Unit

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

(lbs./ton)

D/F

(grain/ton)

HCl 

(lbs./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 residence time, enter “AB/RT” 

in the table.

* **Please include dioxin/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 emissions’ – 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 

Emission Rate 

(lbs./yr)

Maximum 

Allowable 

(lbs./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 RRR.

Equipment/Process 

Description

List each individual 

HAP CAS# Emission Rate (lbs./yr)

Maximum 

Allowable 

(lbs./yr)

Maximum 

Allowable 

(lbs./hr)
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 20 of 26

How are emissions to 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 acceptable?

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. 

Part F. Detailed Control Device and Emission Release Information

Please provide the information below OR on the enclosed spreadsheet. Please also submit any emission 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. Add-on air pollution control devices (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 

Efficiency 

(if Known)

(percent)

Overall 

Efficiency, if 

known 

(percent)

Methods Used for 

Determining Capture 

& Control 

Efficiencies**(a-c)

Type(s) of Unit

Unit

ID No.

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

** Control & Capture Efficiency 
AL 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 facilities.

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 out to 5 decimal places. If coordinates are not known, please provide a scaled site 

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

Information on mapping or coordinates should be provided if available. Emission test plans should 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 Exit 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 places. If coordinates are not known, please provide a scaled 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 National Emissions Inventory (NEI) from relevant States.
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 23 of 29

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

Pollutant(s) 

Tested

Emissions 

Unit Name Unit ID No. (Specify Units)

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 minutes 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 29

Furnace ID

Was reactive flux 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 the sidewell and hearth during 

periods of reactive fluxing?

How was the molten metal level 

monitored?

c. For each Group 1 furnace that is not ducted to a control device:

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 that 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 the furnace doors, etc.?

Requested information should focus on adequate ventilation rate and excess fugitive 

emission observations.
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 25 of 29

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 visible 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. Facility Operations 

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 aluminum produced as well as the amount of charge?

_____________________________________________________________________

c. Could you develop and report your emission rates in terms of amount of emissions 

per unit of aluminum produced? If not, what prevents you from doing so?

_____________________________________________________________________

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 5-18-10.doc Page 26 of 29

41. Fluxing

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

attach MSDS for each flux:

Flux 

Identification

Flux Still in 

Use? 

(Yes or No)

Mass Used 

(lbs./yr)

Furnace or inline fluxer ID 

in which flux 

was used

Purpose (e.g. 

cover, 

degassing, 

demagging, etc.)

Define cover flux including examples.

b. If you have sidewell (scrapwell) furnaces, did you use reactive flux in the sidewell 

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

_____________________________________________________________________

c. Do you use different types or quantities of flux for different flux applications? If so, 

how do the procedures differ?

_____________________________________________________________________

d. What are your flux rate operating 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 /ton 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 5-18-10.doc Page 27 of 29

Clarify that molten metal 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 conditions 

at this facility (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 adding 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 only 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 you have any plans to install any new higher efficiency rated control devices or 

have any pending applications to add on any new controls? If so, please specify and 

include any copies of pending permit applications as requested in Part A, item #17.

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

, For the control technologies identified and listed 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 29

43. Pollution 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 5-18-10.doc Page 29 of 29

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 report) 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 amount of data over a three 

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

Startup/Shutdown*

Description of the event, including 

identification of the emissions source or 

sources [unit ID(s)] associated with the 

startup or shutdown

Was any permit condition was exceeded 

and, if so, what permit condition was 

exceeded

Was the event 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

Actions taken to minimize emissions 

during the event, including the use of 

any backup control systems

Estimates or measurements, if any, of 

emissions during the event; if you did 

not have the ability to quantify 

emissions during the event, please 

explain why

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 conducted 
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 30 of 29

*Startup: the commencement of operation of an affected source or portion of an affected source 

for any purpose.

Shutdown: the cessation of operation of an affected source or portion of an affected source for 

any purpose

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

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

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 event; 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 

shutdown
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 31 of 29

Part I. Criteria Air Pollutants (CAP)

Please provide the information below OR in the enclosed spreadsheet. Please also submit any emission inventory or test reports 

that include these data. 

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 year 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 CAP emissions from equipment collocated at your facility that is not regulated under 40 CFR 63, 

subpart RRR.

ID 

No.

Emission

Unit

CAP Emissions *

(tons per year)

Lead VOC PM PM10 PM2.5 CO SOx NOx
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 32 of 29

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 in 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/Material
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 33 of 29

Start-up fuel:

Typical Start-up fuel amount (Specify 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 should 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 as normal 

operations. 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 the unit and describe the process for 

each?____________________________________________________________________________________

_________________________________________________________________________________________

__________________________________________________________________________________________
AL Assn comments on EPA 114 survey form 5-18-10.doc Page 34 of 29

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 protected.

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 part 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 noncombustible 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/decoating 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 operations 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 foreign 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 nonreactive, non-HAP-containing/non-HAPgenerating gases or agents.

In-line fluxer means a device exterior to a furnace, located in a transfer line from a furnace, used to 

refine (flux) molten aluminum; also known as a flux box, degassing box, or demagging box. 

Melting/holding furnace, or melter/holder, means a group 1 furnace that processes only clean charge, 

performs melting, holding, and fluxing functions, and does not transfer molten aluminum to or from 

another furnace.

Rotary dross cooler means a water-cooled rotary barrel device that accelerates cooling of dross.

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 of 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 open well through which molten aluminum is circulated between the hearth, where heat is 

applied by burners, and the open well, which is used for charging scrap and solid flux or salt to the 

furnace, injecting fluxing agents, and skimming dross.
NESHAP for Secondary Aluminum (40 CFR part 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 dryer 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-Aminobiphenyl

62533 Aniline

90040 o-Anisidine

1332214 Asbestos

71432 Benzene (including benzene from gasoline)

92875 Benzidine

98077 Benzotrichloride

100447 Benzyl chloride

92524 Biphenyl

117817 Bis(2-ethylhexyl)phthalate (DEHP)

542881 Bis(chloromethyl)ether

75252 Bromoform

106990 1,3-Butadiene

156627 Calcium cyanamide

133062 Captan

63252 Carbaryl

75150 Carbon disulfide

56235 Carbon tetrachloride

463581 Carbonyl sulfide

120809 Catechol

133904 Chloramben

57749 Chlordane

7782505 Chlorine

79118 Chloroacetic acid

532274 2-Chloroacetophenone

108907 Chlorobenzene
AL 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)

95487 o-Cresol

108394 m-Cresol

106445 p-Cresol

98828 Cumene

94757 2,4-D, salts and esters

3547044 DDE

334883 Diazomethane

132649 Dibenzofurans

96128 1,2-Dibromo-3-chloropropane

84742 Dibutylphthalate

106467 1,4-Dichlorobenzene(p)

91941 3,3-Dichlorobenzidene

111444 Dichloroethyl ether (Bis(2-chloroethyl)ether)

542756 1,3-Dichloropropene

62737 Dichlorvos

111422 Diethanolamine

121697 N,N-Diethyl aniline (N,N-Dimethylaniline)

64675 Diethyl sulfate

119904 3,3-Dimethoxybenzidine

60117 Dimethyl aminoazobenzene

119937 3,3-Dimethyl benzidine

79447 Dimethyl carbamoyl chloride

68122 Dimethyl formamide

57147 1,1-Dimethyl hydrazine

131113 Dimethyl phthalate

77781 Dimethyl sulfate

534521 4,6-Dinitro-o-cresol, and salts

51285 2,4-Dinitrophenol

121142 2,4-Dinitrotoluene

123911 1,4-Dioxane (1,4-Diethyleneoxide)

122667 1,2-Diphenylhydrazine

106898 Epichlorohydrin (l-Chloro-2,3-epoxypropane)

106887 1,2-Epoxybutane

140885 Ethyl acrylate

100414 Ethyl benzene

51796 Ethyl carbamate (Urethane)

75003 Ethyl chloride (Chloroethane)
AL Assn comments on EPA 114 survey form 5-18-10.doc B-3

106934 Ethylene dibromide (Dibromoethane)

107062 Ethylene dichloride (1,2-Dichloroethane)

107211 Ethylene glycol

151564 Ethylene imine (Aziridine)

75218 Ethylene oxide

96457 Ethylene thiourea

75343 Ethylidene dichloride (1,1-Dichloroethane)

50000 Formaldehyde

76448 Heptachlor

118741 Hexachlorobenzene

87683 Hexachlorobutadiene

77474 Hexachlorocyclopentadiene

67721 Hexachloroethane

822060 Hexamethylene-1,6-diisocyanate

680319 Hexamethylphosphoramide

110543 Hexane

302012 Hydrazine

7647010 Hydrochloric acid

7664393 Hydrogen fluoride (Hydrofluoric acid)

123319 Hydroquinone

78591 Isophorone

58899 Lindane (all isomers)

108316 Maleic anhydride

67561 Methanol

72435 Methoxychlor

74839 Methyl bromide (Bromomethane)

74873 Methyl chloride (Chloromethane)

71556 Methyl chloroform (1,1,1-Trichloroethane)

60344 Methyl hydrazine

74884 Methyl iodide (Iodomethane)

108101 Methyl isobutyl ketone (Hexone)

624839 Methyl isocyanate

80626 Methyl methacrylate

1634044 Methyl tert butyl ether

101144 4,4-Methylene bis(2-chloroaniline)

75092 Methylene chloride (Dichloromethane)

101688 Methylene diphenyl diisocyanate (MDI)

101779 4,4-Methylenedianiline

91203 Naphthalene

98953 Nitrobenzene

92933 4-Nitrobiphenyl

100027 4-Nitrophenol
AL 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 beta-Propiolactone

123386 Propionaldehyde

114261 Propoxur (Baygon)

78875 Propylene dichloride (1,2-Dichloropropane)

75569 Propylene oxide

75558 1,2-Propylenimine (2-Methyl aziridine)

91225 Quinoline

106514 Quinone

100425 Styrene

96093 Styrene oxide

1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin

79345 1,1,2,2-Tetrachloroethane

127184 Tetrachloroethylene (Perchloroethylene)

7550450 Titanium tetrachloride

108883 Toluene

95807 2,4-Toluene diamine

584849 2,4-Toluene diisocyanate

95534 o-Toluidine

8001352 Toxaphene (chlorinated camphene)

120821 1,2,4-Trichlorobenzene

79005 1,1,2-Trichloroethane

79016 Trichloroethylene

95954 2,4,5-Trichlorophenol

88062 2,4,6-Trichlorophenol

121448 Triethylamine

1582098 Trifluralin

540841 2,2,4-Trimethylpentane
AL 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 Manganese Compounds

0 Mercury Compounds

0 Fine mineral fibers 3

0 Nickel Compounds

0 Polycyclic Organic Matter 4

0 Radionuclides (including radon) 5

0 Selenium Compounds

NOTE: For all listings above which contain the word “compounds” and for glycol ethers, the 

following applies: Unless otherwise specified, these listings are defined as including any 

unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) 

as part of that chemical’s infrastructure.

1 XCN where X = H or any other group where a formal dissociation may occur. For example 

KCN or Ca(CN)2.

2 Includes mono- and di- ethers of ethylene glycol (except for ethylene glycol

monobutyl ether (CAS Number 111–76–2), diethylene glycol, and triethylene glycol R–

(OCH2CH2)n–OR where

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–

(OCH2CH)n–OH. Polymers are excluded from the glycol category.

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

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

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 5-18-10.doc B-6