From: gary.barnett@aleris.com

To: Rochelle Boyd/RTP/USEPA/US@EPA

Cc: "Roy M. Harsch" < Roy.Harsch@dbr.com >

Date: 09/05/2012 01:23 PM

Subject: Fw: Methods 1 and 2 Frequency

Rochelle:

I am travelling this week with limited internet access. I have asked Roy Harsch to address Aleris' history with this

issue and concerns we have raised with the USEPA in past negotiations. His summary is in the email below.

As Roy Harsch details, Aleris does not believe a pitot t ube can function continuously in the ductwork due to the

particulate level present. Using baghouse fan RPM checked monthly is an acceptable alternative to annual hood

flow evaluations as determined by USEPA. Aleris proposes that regulatory language be ad ded to Subpart RRR that

recognizes RPM with monthly verification and 30 month flow verification using Methods 1 and 2 as an acceptable

alternative to annual flow verification.

Please let me know if you need a more formal letter or is an email sufficient?

From: "Harsch, Roy M." [Roy.Harsch@dbr.com]

Sent: 09/05/2012 04:28 PM GMT

To: Gary Barnett

Subject: RE: Methods 1 and 2 Frequency

Gary here is my response to what Ms. Boyd has provided in her latest email to you. I have to say that this

whole discussion is one that we had when were working out the terms of the Consent Decree

. As I recall

when discussed this issue we spent a lot of time talking to Todd Russo about it during the Consent Decree

negotiations. Each time we made some headway, Todd would have to go back and discuss it with head

quarters, the regions and the state s.

Since you are out of the office I have set out the draft provision and your comment from our original

April 12, 2012 comment letter below. Also included as an attachment is your August 2, 2012 letter in

response to the initial email from Ms. Boyd whi ch requested the results of the flow monitoring results that

you referenced in your original comment letter. It might be very helpful if she would either talk directly

to Todd or set up a conference call to discuss this issue. As I recall Aleris origi nally objected to having to

measure volumetric flow rates in the ductwork on an annual basis because it would require the use of

consultant services on what basically would be a continuous contract basis given the number of facilities

and number of affect ed capture/collection systems and because it would not really provide any useful

information based upon your observations of the measurements that were being done at the time. One of

the first alternatives that Todd offered was the same as the alternativ e from Mr.Aulshin that Ms. Boyd

sent you in her email of September 4, 2012. At the time you responded to Todd that this was really

unworkable given the environment that you would encounter in the ductwork were you would have to

install the Pitot tube. T he particulate matter and other materials that are entrained in the gas flow would

quickly result in fouling any tube that was installed. As I understand it there is nothing that would change

your opinion that this suggested alternative would work any bet ter now that it would have then when

Todd accepted your opinion. The requirement to test every 30 months was ultimately agreeable as long

as Aleris would agree to measure the RPM of the fan motor. USEPA should accept this and propose it as

alternative i n the draft based upon the information your have submitted that shows very little real

deviation in measured volumetric flow rate measurements that Aleris has had performed under the

Consent Decree. If this is not done, then USEPA should at least make it clear that the RPM

measurements are not needed as long as annual volumetric flow rate measurements are being done. If you

agree I can draft a letter to send to Ms. Boyd.April 12, 2012 Aleris International, Inc. Comment on Draft Proposed Amendments

§ 63.1510(d)(2) Inspect each capture/collection and closed vent system at least once each calendar

year to ensure that each system is operating in accordance with the requirements in § 63.1506(c) and

record the results of each inspection. The inspe ction shall include a volumetric flow rate measurement

taken at a location in the ductwork downstream of the hoods which will be representative of the actual

volumetric flow rate without the interference of leaks, the introduction of ambient air for coolin g, or other

ducts manifolded from other hoods.

While Aleris agrees with the need to routinely perform volumetric flow rate measurements, after

negotiation with the EPA, a determination was made that a frequency of every 30 months was sufficient.

This determination is documented in the Consent Decree.

Approximately fifty rechecks have been performed to comply with the requirements of the decree or due

to new stack testing. All have demonstrated that each system is ope rating in accordance with the

requirements in § 63.1506(c). Therefore there is no need to conduct this flow measurement more than

once every 30 months. In addition, volumetric flow rate measurement is a costly procedure. Such

measurements are commonly performed by outside contractors at a cost of approximately $2,000 per day.

Cost per inspection will vary by the number of systems to be checked. Requiring that this testing be

conducted more frequently than once every 30 months would impose an undue bu rden on the industry.

Aleris also objects to the requirement to perform volumetric flow measurements on each hood.

When multiple hoods are manifolded together, it is not always possible to meet Method 1 requirements

on all hoods to be measured. At times it is necessary to measure the main trunk and arrive at the

volumetric flow rate for an individual hood by calculation. For example, for a simple two hood

configuration it may be necessary to measure the main trunk and subtract one duct that does meet Method

1 requirements (C=A

- B) to determine the flow rate on the second hood. This method has been used

repeatedly and submitted to the EPA and state agencies with stack test reports, and has been accepted.

Response from Rochelle Boyd on my comment regarding the frequency for taking hood flow measurements.

She is requesting a response by Thursday.

From: Rochelle Boyd [Boyd.Rochelle@epa mail.epa.gov]

Sent: 09/04/2012 01:37 PM AST

To: Gary Barnett

Subject: Methods 1 and 2 Frequency

Hi Gary I am following up on your comment in regards to the frequency at which the Methods 1 and 2 are

to are to be performed. As clarified in the interpr etation letter dated 8/18/2006 by Michael Alushin, these

methods are to be done annually. I understand your concern about the 30 month frequency allowed by

your consent decree. We have tried to address this issue by allowing an alternative. We would lik e to

receive any comments on this draft language by C.O.B. Thursday, Sept. 6th, if possible. This is not a

mandatory request but I wanted to provide you the opportunity to review this draft. Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmenta l Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

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

Mail Drop D243

- 02

Ph: (919) 541

- 1390 Fax: (919) 541

- 3207

Email: boyd .rochelle@epa.gov(ii) As an alternative to annual flow rate measurements using EPA

Methods 1 and 2, measurement with EPA Methods 1 and 2 can be performed

once every five years, provided that,

(A) a flow rate indicator consisting of an S

- type Pitot tube and

differential pressure gauge (Magnehelic, manometer, or differential

pressure gauge) is installed with the Pitot tip located at a

representative point of the duct proximate to the location of the

Method 1 and 2 measurement site,

(B) the flow rate indic ator is installed and operated in accordance

with the manufacturer’s specifications,

(C) the differential pressure is recorded during the Method 2

performance test series,

(D) differential pressure readings are recorded monthly, and

maintained at or abov e 90% of the pressure differential indicated by

the flow rate indicator during the most recent Method 2 performance

test series, and

(E) an inspection of the Pitot tube and associated lines for damage,

plugging, and leakage at least once per year.