DATE: October 2, 2014

SUBJECT: Supplemental Proposal Cost Estimate for Reducing the Dioxins/Furans (D/F) Standard for Group 1 Furnaces

FROM: Mark Bahner , RTI International

TO: Rochelle Boyd , U.S. E nvironmental P rotection A gency

The purpose of this memorandum is to document cost estimates related to lowering the D/F standard for Group 1 furnaces from 15 micrograms toxic equivalency per megagram of feed (15 μ g TEQ / Mg ) to 10 μ g TEQ / Mg

. These cost estimates are revisions to cost estimates that were reported in the January 30, 2012 memorandum, “ Draft Technical Support Document for the Secondary Aluminum Production Source Category ” (Docket item EPA

- HQ_OAR

- 2010

- 0544

- 0152). The reason for the revision s is that additional emissions data were obtained from the s econdary a luminum industry between the Proposal in January 2012 and the Supplemental Proposal in 2014.
Costs for Lowering the Dioxin/Furan (D/F) limit for Group 1 Furna ces The EPA multipathway screen analysis results indicated exceedances of worst

- case screening levels, which do not necessarily indicate risks ; however, they cannot be ruled out based on the results

. To evaluate the potential to reduce D/F emissions, our analysis focused on two options: 1) lower the D/F limit from 15 to 10 μ g TEQ/Mg for group 1 furnaces processing other than clean charge at all facilities, and 2) lower the D/F limit for Group 1 furnaces processing other than clean charge to 10 μ g TEQ/Mg , after applying a subcategorization that only required facilities with a production capacity of more than 200,000 tons per year ( tpy ) in G roup 1 furnaces to meet the lower limit. The lower limit could po tentially be met with activated carbon injection systems. With regard to the first option, based on testing reported in information collection request responses 1
, and supplemental information received from facilities after the 2012 Proposal 2
, there are tw elve Group 1 furnaces with emissions above 10 μ g/ Mg as shown in Table 1

. All twelve furnaces are presently controlled with fabric filters, and are assumed to add activated carbon injection. The total capital cost for adding activated carbon injection on the 1 2 furnaces is estimated to be $ 390 , 0 00 , and the total
annu alized cost is estimated to be $ 1, 400 ,000

. The total annual D/F emission reduction if all furnaces emitted at 10 μ g/ Mg would be approximately 0. 49 grams TEQ. Therefore, the calculated cost effe ctiveness is approximately $ 2, 90 0,000 per gram TEQ of D/F. For the second option, only facilities with combined production capacity of all Group 1 furnaces greater than 200,000 tpy would be required to meet the proposed 10 μ g TEQ/Mg limit. Of the facilit ies listed in Table 1, Aleris Recycling (RTI #389) and Novelis Corporation (RTI #269) have a production capacity greater than 200,000 tpy. The calculated total capital cost to add carbon injection to the three furnaces at RTI #389 and the one furnace at RT I #269 is estimated to be $130,000, and the total annualized cost is estimated to be $46 0 ,000. The total emission reduction if these four furnaces emitted at the proposed 10 μ g TEQ/Mg limit would be 0. 12 grams TEQ. Therefore, the calculated cost effecti veness is approximately $ 3 , 8 0 0,000 per gram TEQ of D/F.Table 1. Group 1 Furnaces with Reported Emissions Greater than 10 μ g TEQ/Mg Feed

References

1. Letter, Peter Tsirigotis (U.S. EPA) to Russell Mayfield (Mayfield Salvage Company) et al.,

“ Requirement to provide information according to 42 U.S.C 7414 ,” February 7, 2011. This was the cover letter for the all

- company data collection ICR.

2. Memorandum, Mark Bahner (RTI, International) to Rochelle Boyd (U.S. EPA), “Development of the RTR Supplemen tal Proposal Risk Modeling Dataset for the Secondary Aluminum Production Source Category,” July 11, 2014. This memorandum also has a table that correlates RTI facility ID numbers wi th facility names and locations

. RTI ID Number Facility Name Emission Release Point ID 2014 Reported Emissions Update TEQ

(ug/Mg) 2014 Actual Emissions,

grams 2014 Emissions at

10 ug/Mg,

grams Emission Reduction at

10 ug/Mg,

grams 316 Metal Industries, Inc. 001 14.98 0.110 0.073 0.037 364 Continental Aluminum RV-1 14.55 0.224 0.154 0.070 269 Novelis Corporation 760MT 13.10 0.376 0.287 0.089 347 Hydro Aluminum - Louisville MELTFURN 01 (01) 12.40 1.055 0.851 0.204 389 Aleris Recycling P905 12.20 0.113 0.093 0.020 389 Aleris Recycling P901 11.30 0.105 0.093 0.012 302 Tennessee Aluminum Processors, Inc. 2 10.79 0.217 0.201 0.016 303 Aleris Specifiation Alloys, Inc. EP-002 10.77 0.350 0.325 0.025 392 Aleris Recycling, Inc. Rotary Furnace 7 10.50 0.351 0.334 0.017 364 Continental Aluminum RV-2 10.27 0.002 0.002 0.000 389 Aleris Recycling P903 10.20 0.095 0.093 0.002 303 Aleris Specifiation Alloys, Inc. EP-001 10.08 0.327 0.325 0.003 3.324 2.830 0.494 Totals