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. Environmental Protection Agency

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 μg TEQ/Mg) to 10 

μg 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 revisions is that 

additional emissions data were obtained from the secondary aluminum 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 Furnaces

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 μg 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 μg TEQ/Mg, 

after applying a subcategorization that only required facilities with a production capacity of more than 

200,000 tons per year (tpy) in Group 1 furnaces to meet the lower limit. The lower limit could 

potentially be met with activated carbon injection systems. 

With regard to the first option, based on testing reported in information collection request responses1

,

and supplemental information received from facilities after the 2012 Proposal2, there are twelve Group 1 

furnaces with emissions above 10 μg/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 12 furnaces is estimated to be $390,000, and the total 

annualized cost is estimated to be $1,400,000. The total annual D/F emission reduction if all furnaces 

emitted at 10 μg/Mg would be approximately 0.49 grams TEQ. Therefore, the calculated cost 

effectiveness is approximately $2,900,000 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 μg TEQ/Mg limit. Of the facilities 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 RTI #269 is estimated to be $130,000, and the total annualized cost is 

estimated to be $460,000. The total emission reduction if these four furnaces emitted at the proposed 

10 μg TEQ/Mg limit would be 0.12 grams TEQ. Therefore, the calculated cost effectiveness is 

approximately $3,800,000 per gram TEQ of D/F. 
Table 1. Group 1 Furnaces with Reported Emissions Greater than 10 μg 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 Supplemental 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 with 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

Totals 3.324 2.830 0.494