UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

AUG 1 8 2006 

OFFICE OF 

ENFORCEMENT AND 

COMPLIANCE ASSURANCE 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

Compliance with American Conference of Governmental Industrial Hygienists 

Ventilation Manual in the Secondary Aluminum Production National Emission 

Standard for Hazardous Air Ptollutaf:.nts ~· 

Michael A. Alushin, Directo 

Compliance Assessment and dia rograms i vision 

Office of Compliance 

Regional Air Division Directors (I-X) 

The purpose of this memorandum is to provide guidance on implementation and 

compliance monitoring for the Secondary Aluminum National Emission Standard for Hazardous 

Air Pollutants (NESHAP) Subpart RRR requirements on capture and collection of emissions. 

Several regions have determined that many facilities are not following the required ventilation 

practices and/or not providing sufficient information to demonstrate compliance with the 

requirements in Subpart RRR. 

The Secondary Aluminum NESHAP adopts by reference chapters 3 and 5 of the 

Industrial Ventilation: A Manual of Recommended Practice, 23rd edition, published by the 

Amencan Conference of Governmental Industrial Hygienists (ACGIH). As required by Section 

63.1506(c) of Subpart RRR, owners or operators of affected sources or emissions units with addon air pollution control devices must: 

( 1) Design and install a system for the capture and collection of 

emissions to meet the engineering standards for minimum exhaust 

rates as published by the American Conference of Governmental 

Industrial Hygienists in chapters 3 and 5 of "Industrial Ventilation: 

A Manual of Recommended Practice" (incorporated by reference 

in §63.1502 of this subpart). 

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In addition, Section 63.1515 (b)(5) requires facilities subject to Subpart RRR to provide the 

following: 

Design information and analysis, with supporting documentation, 

demonstrating conformance with the requirements for 

capture/collection systems in §63.1506(c). 

Below are specific issues raised by EPA Regional Offices on the capture and collection of 

emissions at secondary aluminum facilities followed by EPA headquarters responses. 

Issue 1: 

40 CFR Section 63.1515(b)(5) requires facilities to submit a Notification of Compliance 

Status Report (NOCSR) within 60 days after the compliance date. The NOCSR must identify the 

facility's compliance status with the rule requirements, including Chapters 3 and 5 of the ACGIH 

Industrial Ventilation Manual for capture and collection systems. Specifically, the rule requires 

that the NOCSR include design information and analysis with supporting documentation 

demonstrating conformance with the capture and collection systems required by Section 

63.1506(c). What information must the facility provide to demonstrate compliance with Section 

63.1506(c)? 

Response 1: 

To demonstrate conformance with the ACGIH minimum volumetric flowrate 

calculations, the facility must collect actual volumetric tlowrate measurements to compare to the 

ACGIH calculated tlowrates. Actual tlowrate measurements should be taken in accordance with 

the methodologies prescribed in EPA Reference Methods 1_9nd 2 (and EPA Reference Methods 

3 and 4 if needed) which are contained in 40 CFR Part 60, Appendix A. The actual tlowrate 

measurements should be taken at locations in the duct work downstream of the furnace hoods 

which will be representative of the actual volumetric tlowrate without the interference of leaks, 

the introduction of ambient air for cooling, or other ducts manifolded from other hoods. The 

measured volumetric tlowrate should reflect what is actually being captured by each hood. In 

some cases, facilities are using stack gas exit volumetric tlowrates that were determined during a 

perfmmance test; however, these tlowrates are not necessarily representative of what is actually 

entering each hood. Generally, facilities should also measure the actual volumetric tlowrate 

dUiing the lowest expected tlowrate conditions. For example, reduced draw at the hood can be 

created when the damper position that introduces ambient air is in the most open position. 

In addition, the facility may wish to take the actual volumetric tlowrate measurements 

immediately prior to the performance test instead of conducting the measurement and the test at 

the same time. Taking the actual tlowrate measurement prior to the performance test enables a 

facility to identify any problems with the capture and collection system before the petformance 

test, and thus avoid having the performance test be invalidated. This approach is acceptable if 

the company measures the actual volumetric tlowrate immediately prior to the peri'ormance test, 
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and makes no structural or configuration changes to the capture and collection system after the 

measurement and before the performance test. Design information and analysis with supporting 

documentation demonstrating conformance with the capture and collection system required by 

Section 63 .1506( c) may be required when any parameter or design configuration changes occur 

that could impact the volumetric flowrate. 

Issue 2: 

40 CFR Section 63.151 0( d) requires a source to inspect each capture and collection 

system at least once each calendar year to ensure that each system is operating in accordance with 

the operating requirements in Section 63 .1506( c) and to record the results of each inspection. 

How do facilities ensure that they continue to meet the capture and collection requirements? 

Response 2: 

To verify that each capture and collection system continues to operate in accordance with 

the minimum volumetric flowrate that is calculated using the equations in Chapters 3 and 5 during 

the annual inspection, the source would need to repeat the collection of the actual volumetric 

measurements in accordance with the methodologies and locations discussed in Response 1 above. 

Also, the total capture and collection system should be inspected to ensure continued operational 

integrity (e.g., inspect for eroded or deteriorated ductwork). 

Issue 3: 

Some facilities have used the high canopy hood equation in situations where the low 

canopy hood equation was more appropriate. The facilities have zeroed out the height between the 

hot source and the hood while using the high canopy equation. Can a facility use the high canopy 

hood equation for all design configurations? 

Response 3: 

No. The equation that most closely fits the actual design configuration ofthe capture and 

collection system should be used. Section 3.9.3 in Chapter 3 ofthe ACGIH Industrial Ventilation 

Manual states that "if the distance between the hood and the hot source does not exceed 

approximately the diameter of the source or 3 feet, whichever is smaller, the hood may be 

considered a low canopy hood. Therefore, compliance with all of the equations in the ACGIH 

Industrial Ventilation Manual should be enforced as identified in Section 63.1506(c). 

If you have any questions, please contact Scott Throwe of my staff (202-564-7013), or 

Dick Dubose (404-562-9168) or Todd Russo (404-562-9194) of EPA Region 4, who worked with 

our office in drafting this memorandum. 

cc: Regional Air Enforcement Managers 

Dick Dubose, Region 4 

Todd Russo, Region 4