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**MEMORANDUM DATE:**  January 30 , 2012 **SUBJECT :**  Draft Technology Review for the Secondary Aluminum Production Source Category **F ROM**  **:** Mark Bahner and David Green , RTI , International **TO:** Rochelle Bo yd, U.S. Environmental Protection Agency , OAQPS
**1.0 BACKGROUND**  **1.1 Requirements of Section 112(d)(6) of the CAA**  Section 112 of the CAA requires the EPA to establish technology

- based standards for sources of HAP. These technology

- based standards are often referred to as maximum achievable control technology , or MACT , standards. Section 112 also contains provisions requiring the EPA to periodicall y revisit these standards. Specifically , paragraph 112 (d)(6) states: (6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than e very 8 years. **1.2 Description of the Secondary**  **Aluminum Production**  **Source Category and Requirements of**  **the Current NESHAP** The current National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Secondary Aluminum Production source category was promulgated on March 2 3, 2000 (6 5 FR 1 5 690 ) as 40 CFR part 63, subpart RRR
. The rule was amended at 67 FR 79808 , December 30, 2002; 69 FR 53980 , September 3, 2004; 70 FR 57513 , October 3, 2005 ; and 70 FR 75320 , Dec ember 19, 2005. The NESHAP applies to affected sources of HAP emissions at secondary aluminum production facilities. A secondary aluminum production facility is defined as an y establishment using clean charge, aluminum scrap or dross from a luminum production, as the raw material and performing one or more of the following processes: scrap shredding, scrap drying/delacquering/decoating, thermal chip drying, furnace operations (i.e., melting, holding, sweating, refining, fluxing, or alloying), recovery of aluminum from dross, in

- line fluxing or dross cooling. A secondary aluminum production facility may be independent or part of a primary aluminum production facility . For purposes of the NESHAP, aluminum die casting facilities, aluminum foundries and aluminum extrusion facilities are not considered to be secondary aluminum production facilities if the only materials they

melt are clean charge, customer returns, or internal scrap, and if they do not operate sweat furnaces, thermal chip dryers, o r scrap dryers/delacquering kilns/decoating kilns.2

T here are 161 secondary aluminum production facilit ies that are subject to the NESHAP. Emission limits have been promulgated for particulate matter (PM) as a surrogate for metal HAP, total hydrocarbons (T HC) as a surrogate for organic HAP other than dioxins and furans , dioxins and furans (D/F) expressed as toxicity equivalents, and hydrogen chloride (HCl) as a surrogate for HCl, hydrogen fluoride and chlorine. HAP are emitte d from the following affected sources: aluminum scrap shredders (regulated for PM), thermal chip dryers ( regulated for THC and D/F ) , scrap dryers/delacquering kilns/decoating kilns (regulated for PM, D/F, HCl and THC ) , sweat furnaces ( regulated for D/F), dross - only furnaces ( regulated for PM), rotary dross coolers ( regulated for PM), group 1 furnaces ( regulated for PM, HCl and D/F), and in

- line fluxers ( regulated for PM and HCl). Group 2 furnaces and certain in

- line fluxers are regulated by work practices. Control devices currently in use to reduce emissions from affected sources subject to the NESHAP include fabric filters for control of PM from aluminum scrap shredders ; afterburners for control of THC and D/F from thermal chip dryers ; afterburners plus lime

- injected fabric filters for control of PM , HCl, THC and D/F from scrap dryers/delacquering kilns/decoating kilns ; afterburners for control of D/F from sweat furnaces ; fabric filters for control of PM from dross

- only

furnaces and rotary

dross coolers ; lime

- injected fabric filters for control of PM and HCl from in

- line fluxers ; and lime

- injected fabric filters for control of PM, HCl and D/F from group 1 furnaces. All affected sources with add

- on controls are also subject to design requirements and operating limits to limit fugitive emissions. **2.0 DEVELOPMENTS IN PRAC**  **TICES, PROCESSES, AN D CONTROL**  **TECHNOLOGIES** For the purposes of this technology review, a “development” was considered to be a (n):  add

- on control technology that was not identified d

uring the development of the current NESHAP for the source category ;  i mprovement to an existing add

- on control technology that could result in significant additional HAP emissions reductions;  w ork practice or operational procedure that was not identified during development of the current NESHAP for the source category ; or  applicable p rocess change or pollution prevention alternative that was not identified and considered during the development of the current NESHAP for the source category
. We investigated developments in practices, proce sses , and control technologies through a literature review and discussions with industry representatives, and included questions in a Section 114 information collection request (I CR) that was sent to all companies thought to be subject to the NESHAP. The results of these anal yses are presented in the following sections. **2.1 Literature review and industry contacts**  2.1.1. Multichamber Delacquering Kiln/Melting Furnace3

At least one compan y supplies multichamber furnaces that combine the functions of a delacquering kiln and a melting furnace. This furnace has the potential to reduce emissions , because all of the emissions from the delacquering of used beverage cans and other coated scrap are swept into another chamber wher e the delacquered scrap is melt ed

. These emissions are combusted in the melting chamber, reducing energy requirements; destro yi ng THC and D/F; and eliminating the need for an afterburner. A multichamber furnace can therefore be used as a replacement for a delacquering/decoating kiln (with afterburner) plus a group 1 furnace handling only clean charge, or the multichamber furnace can be used as a replacement for group 1 furnace handling other than clean charge. At least 16 of these furnaces are in operation in Europe, Asia and the M iddle E ast. One furnace of this ty pe is presently

operating in the U. S. and is permitted as a group 1 furnace handling other than clean charge

. The emissions test data for the one multichamber furnace operating in the U.S. indic ate that the furnace produces D/F emissions that are within the range of emissions test data for other group 1 furnaces handling other than clean charge , and delacquering/decoating kilns. Thus, the multichamber furnace D/F test data are within the range of other equipment using control technology

considered by the EPA in the Subpart RRR NESHAP. The multichamber furnace does n ot produce lower D/F emissions (in toxic equivalents, or TEQs) than any other group 1 furnace handling other than clean charge, or than any delacquering/decoating kiln , as shown in Table 1

. Table 1 lists D/F emissions from the one multichamber furnace , operating at Logan Aluminum . Table 1 also lists D/F emissions from three group 1 furnaces handling other than clean (i.e., “dirt y”) ch arge, and three delacquering/decoating kilns. The other furnaces and delacquering/decoating kilns in Table 1 w ere selected because they had low reported D/F emissions, and emission test reports were available to support those reported emissions. The D/F em issions from these other sources are lower than for the multichamber furnace

. Therefore, based on available information, we are unable to conclude that the multichamber furnace technology reduces HAP emissions relativ e to technologies that were considered b y the EPA in promulgating the subp art RRR NESHAP and are already used b y other facilities in the U.S. **Table 1. Comparison of D/F Emissions from a**  **Multichamber Furnace**  **with Other**  **Technologies RTI**  **ID Facility**  **Nam e**  **Equipment**

**ID Equipment** 

**Type Test Date**  **Test -**  **Condition Av**  **erage D/F in**  **ug/Mg TE Q**  **(1)** 351 Logan Aluminum Multichamber

Furnace Grp1 dirty

charge 5/13/2008 1

- 50%Class I/50% Class III 1.061 (2) 351 Logan Aluminum Multichamber

Furnace Grp1 dirty

charge 5/13/2008 1

- 100% Class I 0.461 351 Logan Aluminum Multichamber

Furnace Grp1 dirty

charge 5/14/2008 2

- 80% UBC’s/20% Class I 0.496 351 Logan Aluminum Multichamber

Furnace Grp1 dirty

charge 8/12/2008 1

- 50%Class I/50% Class III 0.26 421 Alcan Rolled Products DC1M Grp1 dirty charge 1/29

-

31/2008 1 0.023 335 Jupiter Aluminum Furnace 2 Grp1 dirty charge 1/25/2010 1 0.0274

**RTI ID**  **Facility Nam**  **e Equipment** 

**ID Equipment** 

**Type Test Date**  **Test -**  **Condition Average D/F in**  **ug/Mg TEQ (1)**  211 Alumax Texarkana EPN 011A Grp1 dirty charge 4/20/2009 1 0.103 198 Novelis P9A Delacquering Kiln 10/01

-

02/2008 1 0.00 0419 198 Novelis P9B Delacquering Kiln 9/30

-

10/1/2008 1 0.000173 415 JL French P30

- 1 Delacquering Kiln 6/22/2009 1 0.02 (1) Average of three test runs, except where noted. (2) Average of two test runs. 2. 2 .2. Eddy

Current Separators Sweat furnaces are used in the secondary aluminum industry

to separate aluminum from ferrous metals. Certain ty

pes of scrap , primarily

automotive, are composed of individual pieces of metal which contain both aluminum and iron or steel. Automobile parts such as aluminum engine blocks with cast iron cylinders, aluminum transmission cases with steel gears and inserts and aluminum suspension components with steel inserts are examples of sweat furnace feed. These materials, often containing oil and grea se, are separated by melting the aluminum from the ferrous metals with higher melting points. The molten aluminum is tapped to form ingots or “sows,” and the ferrous residue is raked from the furnace. Sweat furnace emissions contain D/F , which results from the combustion of the organic contaminants in the scrap. Eddy current separators are used to separate a concentrated aluminum fraction from a heterogeneous scrap feed. These units operate at ambient temperature and emit no D/F or other gaseous pollutants. Eddy

current separators are used to separate a concentrated aluminum fraction from a heterogeneous scrap feed. These units operate at ambient temperature and emit no D/F or other gaseous pollutants. They are used on the material output from mechanical shredders that shred automobiles and appliances (not on the aluminum scrap shredders used in the secondary

aluminum industry). These units can potentially decrease the need for sweat furnaces. However, the product of eddy current separators is not an alumi num ingot or sow, as with a sweat furnace. Therefore, the product of eddy current separators must undergo further processing to produce an aluminum ingot or sow , and it is not possible to directly compare eddy current separators with sweat furnaces. 2.1. 3 Cataly

tic Filter Bags Cataly tic filtration s ys tems, including catal yt ic filter bags, are available to reduce D/F emissions. These bags incorporate an expanded poly tetrafluoroethylene membrane coated with a precious metal catal ys t which promotes the oxi dation of D/F. One manufacturer claims that this sy stem is installed in over 100 applications around the world, including at least one secondary aluminum processing plant

. To determine the extent that these bags are in use in the secondary aluminum indu stry in the U. S., EPA included a question in an information collection request ( ICR) sent to all ide ntified secondary

aluminum production facilities. The question “ Do you use catal yt ic filters for dioxin control (e.g.,5

http://www.donaldson.com/en/industrialair/literature/051754.pdf ) ? ” was answered “ no ” or “ not applicable ” by

126 of the 159 facilities that responded to the I CR . The remaining facilities did not answer this question. Some, or all, of the blank responses and the “not applicable” responses are attributable to facilities that do not operate fabric filters

. Therefore, the EPA has no information about any secondary aluminum facility

in the U.S. currentl y using catal yt ic filter bags , and no specific secondary aluminum facility in another country that uses catal yt ic filter bags has been identified

. Cataly tic fabric filter bags are potentiall y problematic for the secondary aluminum production industry because they require a minimum fabric filter inlet temperature of approximately 30 0 degrees Fahrenheit to produce the catal yt ic oxidation of D/F . Man y fabric filters at se condary aluminum production facilities in the U.S. operate below this temperature , specificall y to avoid de novo creation of D/F in the fabric filter , which occurs at temperatures from approximately 300 to 840 degrees Fahrenheit (150 to 450 degrees Celsius) , 1 and because large amounts of ambient air flow into hoods are necessary to meet design guidelines of the American Council of Governmental Industrial Hygieni sts (ACGIH). Therefore, the fact that cataly tic filter bags require a temperature above approximately 300 degrees Fahrenheit conflicts with a need to remain below 300 degrees Fahrenheit to avoid de novo sy nthesis of D/F, and the need to draw in large amounts of ambient air into hoods to meet ACGIH guidelines. Ther e fore, the EPA cannot conclude that fabric filter bags are more effective at reducing D/F emissions at secondary

aluminum production facilities than the control technologies considered by the EPA in the 2000 Subpart RRR NESHAP. Catalytic filtration sy stems are not at present a demonstrated control technology for the S econdary A luminum P roduction source category that should be used as the technical basis to require more stringent emission limits for the source category
. 2.1.4 Work Practices: Good Combustion Practices D/F emissions in municipal and medical waste combustors are controlled in part through “good combustion practice (GCP).” For municipal waste combustors , the major technical objectives of GCP were determined to be achieved b y monitoring and controlling: (a) the flue gas concentration of CO; (b) steam load (a surrogate for PM carryover) and (c) temperature at the inlet of the PM control device. 1 The first two parameters are not applicable in the operation of secondary aluminum furnaces and kilns, since the fuel in secondary aluminum is not waste, but is instead ty

picall y natural gas. [Afterburner operation (for sweat furna ces, chip dryers and delacquering kilns/decoating kilns/scrap dryers) is presentl y subject to inspection for burners and proper adjustment of combustion air.] The third parameter, temperature at the inlet of the PM control device, must already be monitored in the existing NESHAP. Therefore, GCP, as it relates to D/F formation in secondary aluminum production, is already addressed by

the existing NESHAP , and is not a development in practices, processes, or control technologies for the S econdary A luminum source category under section 112(d)( 6). 2.1.5 Work Practices: Other Work Practices6

The EPA investigated other work practices such as better scrap inspection and cleaning, and process monitoring. However, no such practices were identified that were not already identified at the time of the original NESHAP. For example, the issue of scrap inspection was investigated extensively

in the development of the original NESHAP , and no sampling or anal yt ical procedures were identified then or in our present review that can determine whether scrap of unknown origin is completely free of paints , coatings, or lubricants. **2.2 Responses to ICR**  In an attempt to identify developments in emission control technologies in use, an ICR was sent to all identified secondary aluminum production facilities. T he following questions were asked:

• Please provide details for any alternative control devices (i.e., control devices other than fabric filters, lime

- coated fabric filters, or afterburners), monitoring (including particulate matter or HC l continuous emissions monitors), or operating conditions at this facility for equipment regulated under 40 CFR 63, subpart RRR.

• Have you injected activated carbon or other type of sorbent for HAP control (excluding research efforts)? What barriers do you envision to adding carbon injection to fabric filters for HAP control?

• Do you have an y plans to install any new higher efficiency

rated control devices or have any pending applications to add on any new controls? 2. 2 .1 Activated Carbon Injection for D/F Control Three respondents reported using activated carbon injection for control of dioxin, and one respondent reported using activated carbon injection previously on a unit that has since been shut down. Activated carbon is ty pica lly added to control D/F, although in one case it was used with a thermal chip dryer and may also have helped control THC. This technology was known at the time of the development of the current standard and was regarded as a possible control alternative f

or sources that were unable to demonstrate compliance using lime

- injected fabric filters ; it is not a development under section 112(d)(6). The broader use of activated carbon for D/F control was ev aluated as part of demonstrating an ample margin of safety for multipathway risks from D/F. 2 2.2.2 Ammonia Injection for HCl Control Four respondents reported adding injecting ammonia into furnace exhaust gas as a means of HCl control. One of the four respondents plans to replace the lime currentl y used to control HCl emissions with ammonia. The EPA was unable to determine from the IC R responses wheth er the remaining respondents reporting the use of this technology are reducing lime usage as a result of using ammonia , or adding ammonia i n addition to l ime currentl y used ; Further w e do not have any HCl test data for the furnaces at these four facilities. The HAP emission reductions achieved from using this technology alone or in addition to lime injection are not known. This technology may be suitable technologically for retrofit to existing fabric filters

. The applicability of thi s technology

is unlikel y to be influenced b y furnace configuration because the ammonia is added between the furnace and the fabric filter

. It has the potential of decreasing the amount of fabric7

filter dust requiring disposal, but would likely result in i ncreased air emissions of ammonia ( which is not a HAP , but may contribute to nitrogen deposition ). The EPA does not have sufficient data to determine whether ammonia injection provides greater control of HCl emissions than lime injectio n . **3.0 CONCLUSIONS:**  **RECOMMENDED REVISIONS**  **BASED ON DEVELOPMENT S**  **IN PRACTICES, PROCES SES**  **, AND CONTROL TECHNOLO**  **GIES** This review identified several developments in practices, processes , or control technologies that have been implemented in this source cate gory since promulgation of the current NESHAP. However, these technologies are not in use b y a substantial number of secondary aluminum production facilities in the U. S. One possible reason for this is that facilities are able to meet the current MA CT emission limits without using them. Specific developments in practices, processes, or control technologies examined included:

• Multichamber Delacquering Kiln/Melting Furnace

– Only one such furnace is currentl y in use in the U.S. D/F emissions from this furnace are within the range of other group 1 furnaces handling other than clean charge, and delacquering/decoating kilns. Therefore, we are unable to conclude that this technology reduc es HAP emissions relative to technologies that were considered b y EPA in promulgating the subpart RRR NESHAP and are already used b y other facilities in the U.S.

• Eddy Current Separators

– Itis not possible to compare eddy current separators with second ary aluminum production equipment such as sweat furnaces. Sweat furnaces produce aluminum ingots or sows, whereas eddy current separators simply provide a concentrated aluminum fraction from a heterogeneneous scrap stream. The concentrated aluminum fractio n from an eddy current separator requires further processing to produce an aluminum ingot or sow.

• Cataly

tic Filter Bags

– The EPA requested all facil i ties potential subject to Subpart RRR to identify

whether they

used catal yt ic filter bags. None used the se bags. Further, there is potential problem in that catal yt ic filter bags require a mininum temperature of approximately 300 degrees Fahrenheit to destroy D/F, whereas secondary aluminum fabric filters ty pically operate at temperatures lower than 300 degr ees Fahrenheit to avoid de novo sy nthesis of D/F, and because large volumes of ambient air must be drawn into furnace hoods to promote effective capture. Therefore, we cannot conclude that fabric filter bags are more effective in reducing D/F emissions at secondary aluminum facilities than control technologies considered by the EPA in the 2000 Subpart RRR NESHAP.

• Work Practices: Good Combustion Practices (GCP)

– GCP as they relate to reducing emissions from municipal waste combustors and medical waste inc inerators are not generall y applicable to secondary aluminum furnaces, since secondary aluminum furnaces burn natural gas rather than waste. One GCP parameter that is applicable to the secondary

aluminum i ndustry

is to monitor fabric filter inlet temperature; this must already be monitored in the existing NESHAP. Therefore, GCP, as it relates to D/F formation in secondary aluminum, is already addressed b y the existing NESHAP.

• Work Practices: Other Work Practices

– In addition to GCP, we investigat e d othe r work practices such as better scrap inspection and monitoring. No sampling or8 anal yt ical procedures could be identified that could determine whether scrap of unknown origin was completely free of paints, coatings, or lubricants.

• Activated Carbon Inject ion

– T hree facilities reported using activated carbon injection to control D/F. This technology was identified at the time of the development of the current NESHAP, and so is not a new development . An anal ys is of the greater use of activated carbon than i s currentl y practiced in the secondary aluminum production industry was performed as part of demonstrating an ample margin of safety for multipathway

risks from D/F.

• Ammonia Injection for HCl Control

– Four facilities use ammonia injection for HCl contro l. However, three use ammonia injection in combination with lime injection, so it is not pos sible to separate the HCl control achieved by lime injection with the HCl control achieved b y ammonia. The fourth facility had not yet switched to full ammonia inje ction. The EPA does not have sufficient data to determine whether ammonia injection provides greater HCl control than lime injection. **4.0 REFERENCES**  1. Kilgroe, James D., W. Steve Lanier, and T. Rob Van Alten. “Development of Good Combustion Practice for Muni cipal Waste Combustors.” Presented at 1992 National Waste Processing Conference. Available at: http://www.seas.columbia.edu/earth/wtert/sofos/nawtec/1992

- National

- Waste
- Processing

Conference/1992

- National

- Waste
- Processing

- Conference

- 15.pdf. Accessed January 2012

. 2. Bahner, Mark (RTI, International), to Rochelle Boyd (EPA). “Mem orandum: Draft Technical Support Document for the Secondary Aluminum Source Category .” January 2012. Available in EPA docket for Secondary Aluminum Production Risk and Technology Review.