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MEMORANDUM

From: Donna Lee Jones, Ph.D., U.S. Environmental Protection Agency, Office of Air 

Quality Planning and Standards, Research Triangle Park, NC (D243-02)

Jones.DonnaLee@epa.gov 

Date: September 30, 2009

Subject: Rule Improvements for Secondary Aluminum Production NESHAP 

(40 CFR Part 63 Subpart RRR)

1. Definitions and Applicability

 Clean Charge 

o Add more quantitative measure of “clean” charge/scrap.

 Add specific methods to be used to prove scrap is entirely free of 

contaminants (see Operation & Monitoring, below).

o Add specifications for cleaning processes (e.g., for runaround scrap), such as:

 Minimum residence time and temperature for thermal drying process.

 Minimum RPM speed and residence time for centrifuging processes. 

o Add that sows, ingots, and t-bars with only paint markings are still considered 

clean charge.

o Add OECA clarification on how to ‘know’ if it is clean and/or entirely free of 

paints, coatings, and lubricants:

 Must have some knowledge of the processes applied to the scrap 

material by maintaining direct control of the scrap or by knowing the 

processes utilized by outside entities that have supplied the scrap. 

 Must have some knowledge of the history of that scrap material such 

that they may know that the material is “entirely free of paints, 

coatings, and lubricants.” “Entirely free” indicates that the scrap must 

contain no paints, coatings, or lubricants. This knowledge can be 

gained through several methods. One method would be to maintain 

direct control of the scrap material being processed and only process 

scrap generated within the facility or from other facilities within the 

same company that the owner or operators knows has not been 

subjected to paints, coatings and lubricants or where they know paints, 

coatings or lubricants have been removed consistent with the 

definition of “Clean charge”. Similarly, the owner or operators may

also process scrap from outside entities where they are familiar with 

the history of the scrap and therefore, know that the scrap meets the 

definition of “clean charge.” 

o Add OECA clarification on methods that would not allow owners or operators 

to “know” scrap is clean:

 Secondary aluminum production facilities may receive bales of 

aluminum scrap from scrap vendors. The scrap is accumulated from a 

variety of sources and the owner or operator may conduct a cursory 

inspection of the scrap bales to determine whether the material is 
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“entirely free of paints, coatings, and lubricants.” This type of 

inspection is insufficient and does not provide the owner or operator 

sufficient information regarding the scrap such that they may know 

that the scrap is “entirely free of paints, coatings, and lubricants.” 

Even more thorough inspections of the scrap may be insufficient, since 

the scrap may contain clear coated materials or lubricants not visible 

on the outside of the scrap. Consequently, scrap inspection alone may

not provide owners or operators sufficient knowledge of the scrap such 

that they can know that the scrap is “entirely free of paints, coatings, 

and lubricants.”

 Anodized Aluminum Scrap

o Exclude anodized aluminum scrap from the clean charge definition since dyes 

may be used as part of the anodizing process, which could volatilize in the 

furnace and contribute to THC or D/F emissions.

 Secondary Aluminum Processing Unit (SAPU) - Existing vs. New

o Clarify definitions to indicate that there can only be ONE existing SAPU and 

ONE new. The existing/new SAPU includes all existing/new Group 1 

furnaces and all existing new inline fluxers at a single facility.

 Scrap Shredders 

o Clarify that all scrap shredders processing other than clean scrap are subject to 

the rule.

o Clarify that all scrap shredders that generate visible emissions as determined 

by EPA Method 22 are subject to the rule regardless of whether scrap is 

considered clean or not.

o Exempt shredders that always process clean scrap and don’t generate visible 

emissions as determined by EPA Method 22. Minimally, exempt from 

periodic testing.

 Thermal Chip Dryers

o Clarify that a device that uses heat to evaporate water, oil, or oil/water 

mixtures from unpainted/uncoated aluminum chips is subject to subpart RRR.

 Furnaces that Are Affected Sources

o Identical Furnaces - Identify criteria under which furnaces may be 

defined as “identical.”

 Examples of possible criteria: temperature, processing rate, 

design, scrap materials charged to the furnaces, etc. 

o Stationary Furnace with Internal Heaters - Clarify that a furnace that is 

not portable and has internal heaters and is used to hold molten aluminum 

is a furnace under subpart RRR.

 Furnaces that are Not Affected Sources

o Transport Pots - Clarify that pots used to transport metal to customers are 

not furnaces.

o Diecaster Holding Furnace - Clarify that a furnace used by a diecaster 

that only metals or holds clean charge is not a subpart RRR furnace 

(diecaster does not have a sweat furnace or thermal chip dryer or scrap 

dryer, and does not use flux or only uses nonreactive nonHAP flux)
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 Sweat Furnace

o Clarify that any furnace that charges objects containing aluminum and is 

tipped to pour out molten aluminum is a sweat furnace. (Does this mean 

that tapping to get the melted aluminum out makes a furnace a Group 1 or 

2 furnace?)

 Bale Breaker

o Clarify that this is a device used to break the ties holding a bale of 

aluminum scrap before it is fed into the shredder and which is not also a 

scrap shredder. 

 Scalpers

o Clarify that scalpers used to remove rough spots from ingots prior to 

rolling into various product shapes are not subject to subpart RRR and are 

considered to be equipment in aluminum product manufacturing. 

 Capture and Collection System -- Add definition.

 Residence Time of an Afterburner

o Clarify that this is the total time required for gases to pass through the 

afterburner combustion chamber, which does not include the furnace, 

ductwork, or stack.

 Fluxes

o Cover Flux in Rotary or Other Agitated Furnaces

 Clarify that any flux used in a rotary furnace is by design agitated;

therefore, any flux used for “cover” or otherwise in this type of 

furnace is considered reactive

 Add definitions for agitated and non-agitated furnaces.

o Cover Flux Used to Also Remove Impurities

 Clarify how to distinguish between cover flux that only prevents 

oxidation vs. cover flux that also removes impurities (and is therefore 

reactive?) which can result in HAP emissions at a later point.

o Continuous vs., Batch (intermittent) Flux Additions

 Add definitions so that different monitoring strategies can be set (see 

below).

 Feed/charge Rate

o Clarify that the feed/charge rates obtained during performance tests should be 

used to calculate the emission limit for each pollutant from each SAPU

 Thermal Delaminating of Aluminum Scrap and Mechanical Granulation of 

Recovered Metal are Affected Sources under Subpart RRR

o Heat is used to separate aluminum foil from paper and plastic in scrap, 

o Chambers operate at a maximum temperature of 900F and no melting of the 

recovered aluminum occurs in the chamber

o Subsequent melting of recovered aluminum need not occur at the same facility

that conducts the recovery operation.
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2. Reporting

 Area Sources: Add annual compliance certification reports (currently exempt from 

Title V permits). Similar to requirements in EPA’s 40 CFR part 63 area source 

program.

 Semi-annual Report Formats. Add minimum requirements to be included in these 

reports.

3. Operating and Monitoring Requirements 

 Add/expand Monitoring Requirements for:

o Capture and collection systems 

o Reactive flux injection rate

o Lime injection rate (lb/hr) verification during daily operation

o Feed/charge weight at scrap dryers/delacquering kilns and decoating kilns

 Establish feed/charge weight parameters during performance test

o Reactive flux injection furnaces “charge and top” operations

 Include alternative process control monitoring?

o Scrap inspection

 Add how to collect representative sample for oil content.

 Add how to correlate visual inspections with physical measurements

o Ceramic candle filter control devices

o Molten level at passage between sidewell and hearth during reactive fluxing

 Specify how to establish molten level

 Specify different monitoring intervals for continuous charging 

(@15 minutes) vs., batch (@batch charge addition)

o Control measures not required by rule but used during performance test to 

control pollutants with emission limits under the rule.

 For example, ammonia or carbon injection rates used to control D/F.

 Reduce Monitoring Requirements:

o Solid flux 

 Add monitoring only when solid flux is added for batch/intermittent flux 

additions; keep monitoring for every 15 minutes with continuous flux 

additions.

 O&M Plan Revisions

o Require submission for approval of ANY changes and forbid operation before 

plan is approved. 

o Require minimum time (3 months?) to submit for approval prior to a planned 

change in operation.

o Clarify options under 63.1510(o) (Site-specific monitoring for Group 1 furnace 

without add-on air pollution control devices) 

o Clarify that 63.1510 does NOT apply to a SAPU that has already demonstrated 

compliance on an individual unit basis, as per 63.1510(u).

o Require repeat testing of actual volumetric flowrates of hoods during annual 

inspection of hood operational integrity

 Allowable Operating Conditions

o Clarify feed/charge rate in operation vs. during performance tests
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o Clarify that can exceed performance test charge weight as long as the 

performance test is still representative of facility operation at highest emission 

level of all pollutants. For example, if clean charge is added to regular charge in 

Group 2 furnace and final weight is above performance test rate but not if clean 

charge is excluded, or if all clean charge us used in a Group 2 furnace at feed rate 

higher than the test rate.

 NOT Allowable Operating Conditions

o [Add any situations that need to be listed]

 Thermocouple Calibration for Afterburners

o Clarify that a second thermocouple can be used in a dual calibration system 

instead of the rule required calibration; if minimally weekly checks are done for 

agreement of the dual thermocouples.

4. Performance Testing

 Feed/charge Rate

o Clarify requirements to determine feed/charge rate used during performance test 

that will be used to calculate emissions for each pollutant.

o Clarify that all the feed/charge rate during ALL performance testing is required to 

be the level that is likely to create the highest emissions (of pollutant known to be 

the highest emitters, or all pollutants, if possible)

 Frequency of Testing

o Clarify that testing needs to be done every five years to show compliance 

regardless of level of emissions.

 Multiple Emission Units:

o Clarify for SAPU and non-SAPU ducted to a common control device.

o Clarify for identical furnaces (to reduce individual testing).

 Temporary Enclosures for Collection of Fugitive Emissions

o Add requirement to capture fugitive emissions during testing

 Add requirement to account for fugitives that could be lost from furnace or 

other doors being opened during tests.

 Add requirement for temporary enclosure to be used if not possible to 

capture fugitives otherwise.

 Additional Data to be Collected during Performance Tests

o Require documentation of the type of scrap processed during performance test.

o Require testing/documentation of flow rate for each hood and capture/collection 

system.

o Require testing/documentation operating levels of control measures used during 

performance test to reduce emissions although not explicitly required by rule 

(e.g., ammonia or carbon injection to control D/F).

 Exemptions from Performance Tests

o Scrap shredders that always process clean scrap and don’t generate visible 

emissions (due to low speed and or other parameters) as determined by EPA 

Method 22 should be exempt from periodic testing, if not exempt from rule.

o Group 1 furnaces operated <130oF (as measured at the inlet and outlet) should 

be exempted from afterburner testing for dioxin/furans 

 D/F formation temperature is >130 oF.
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 Hood Performance Tests

o Clarify that the volumetric flowrate ENTERING the hood should be used and not 

the stack exit flow.

o Clarify that testing of hood flowrate can be done BEFORE performance test is 

begun (so can readjust before testing whole system); need to retest hood after 

adjustments.

o Clarify that must measure actual volumetric flowrate of hood during lowest 

expected air flow conditions (ambient air damper in most open position).

 Method 22 Testing

o Add allowance for testing in three 20 minute intervals, with greater than 

10 minute breaks in between for a total test time of 60 minutes.

5. Calculations

 Hoods

o Can only use high canopy hood equation if low canopy equation is not 

appropriate, i.e., where the distance between the hood and the hot source is 

greater than the diameter of the source or greater than 3 feet, which ever is larger.

 Multiple Control Devices:

o Clarify calculations for individual furnaces ducted to a common control device.

 Emissions Calculations to Meet Limits in Terms of Mass of Product 

o [Would this be useful?]

6. Corrections Where Requirements Are Obsolete or Erroneous 

 Ventilation System Requirements: 

o Remove ACGIH Ventilation Manual (23rd edition) that is incorporated by 

reference. This manual is no longer available for purchase, is outdated. Also, 

EPA no longer incorporates non-Agency documents such as operating 

manuals. 

 Bag Leak Detection Systems (BLDS) Requirements:

o Remove 1997 guidance document on bag leak detection systems. Current 

BLDS operate digitally, which is not covered in 1997 guidance.

o Add requirement that manufacturer’s operating instructions should be 

followed at all times.

7. Typographical Corrections

 §63.1503 Definitions: Clean Charge

o Replace comma with semicolon before the phrase: “...and runaround scrap,” as 

follows:

 Clean charge means furnace charge materials, including molten 

aluminum; T-bar; sow; ingot; billet; pig; alloying elements; aluminum 

scrap known by the owner or operator to be entirely free of paints, 

coatings, and lubricants; uncoated/unpainted aluminum chips that have 

been thermally dried or treated by a centrifugal cleaner; aluminum scrap 

dried at 343 °C (650 °F) or higher; aluminum scrap delacquered/ decoated 

at 482 °C (900 °F) or higher; and runaround scrap.
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 § 63.1505. Emission standards for affected sources and emission units;

(k) Secondary aluminum processing.

o Correct Equation 1 legend for Tti = feed/charge rate for individual emission 

unit I:

 Change “emission unit I” to “emission unit i” to be consistent with 

other equations in the rule..

 § 63.1510(n)(2). Sidewell group 1 furnace with add-on air pollution control 

devices

o Change reference citing § 63.1506(m)(7) to §63.1506(m)(6). There is no 

§63.1506(m)(7) and §63.1506(m)(6) has the right information..