----- Forwarded by Rochelle Boyd/RTP/USEPA/US on 08/15/2012 08:39 AM

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From: Paul Sohi < psohi@aluminum.org >

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

Date: 08/15/2012 08:25 AM

Subject: Capture hood and work practices

Morning Rochelle,

Hope all is well, we mailed you this letter this week and wanted to email you a copy as well.

If you have any questions please feel free to contact me.

Kind regards,

Paul Sohi

Manager, EH&S

The Aluminum Association

1525 Wilson Boulevard, Suite 600,

Arlington, VA 22209

Tel: (703) 358 2976

Fax: (703) 358 2961

www.aluminum.orgFriday 10 th August, 2012

Rochelle Boyd

U.S. Environmental 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

Dear Ms. Boyd,

The Aluminum Associat ion is submitting these comments in response to EPA’s subpart RRR ( 

### National

Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production ) inquiry

dated July 13 th 2012. We would like to thank EPA for the opportunity to further clarify issue s that will

have direct impact on the U.S. aluminum recycling industry. After review of EPA’s questions and

proposed language, and consultation with EPA on July 25 th 2012, The Association would like to submit

the following clarifications and suggestions.

EPA s ubmitted two questions. The first asked for, “ l anguage that describes what constitutes

“impractical” conditions for installing temporary hooding meeting ACGIH guidelines.”

EPA proposed the following:

“ If the source is located within a building such that the hood cannot be located (because of the presence

of a wall or roof) consistent with acceptable hood design and installation procedures the use of a

temporary capture hood is impractical. Similarly, if the clearance required for the equipment used for

c harging, fluxing and/or drossing of the source makes it impossible to design and install a temporary

hood in accordance with ACGIH guidelines, the use of such a hood is impractical.”

The Aluminum Association suggest s replacing the above language with the f ollowing:

The installation of a temporary capture hood (with associated duct work and sampling location) is

considered impractical in any one the following situations:

a) Building or equipment obstructions (for example, wall, ceiling, roof, structural beams, utilities,

overhead crane, or other) are present such that the temporary hood cannot be located consistent

with acceptable hood design and installation practices;

b) Space limitations or work area constraints exist such that the temporary hood cannot be suppo rted

or located to prevent inference with normal furnace operations or avoid unsafe working

conditions for the furnace operator or source tester;

c) The temporary hood installation or removal would require curtailment of furnace operations for

more than ei ght (8) hours to ensure worker safety;

d) The cost for design, construction, installation and removal of the temporary hood on a single

furnace would exceed $150,000 ; or2

e) The furnace is a round top configuration.

The Association has clarified on several occ asions that one set of work practices during testing that could

be applied across the industry, or to furnace categories is impossible . The variability in furnace

installations and operating practices means that no one work practice will apply to every fur nace.

Therefore, the list of work practices to minimize emissions during testing should be linked with “or” and

should not be linked with “and”.

EPA has proposed the following work practices to minimize fugitive emissions during testing:

2) Minimization of fugitive emissions

Petition the permitting authority that such hoods are impractical and propose testing procedures

that will minimize fugitive emissions. These procedures may include, but are not limited to:

(A) Installing a hood that does not meet ACGIH guidelines,

(B) Using the building as an enclosure, and measuring emissions exhausted from the building,

(C) Installing temporary baffles on those sides or top of furnace opening where they will not

interfere with material handling,

(D) Increasing the exhaust rate from the furnace, so as to capture emissions that might otherwise

escape into the building,

(E) Minimizing the time the furnace doors are open,

(F) Delaying gaseous reactive fluxing until charging doors are closed,

(G) Delaying the addition of solid reactive flux until immediately before the charging doors are

closed, and

(H) Keeping building doors and other openings closed to the greatest extent possible to minimize

drafts that would divert emissions from be ing drawn into the furnace.

The Aluminum Association proposes the following changes to the proposed testing procedures:

2) Minimization of fugitive emissions

Petition the permitting authority that such hoods are impractical and propose testing proced ures3

that will minimize fugitive emissions. These procedures may include , if practical

, one or more of

the following , but are not limited to:

(A) Installing a hood that does not meet ACGIH guidelines

.

(B) Using the building as an enclosure, and measuring emissions exhausted from the building if

there ar e no other furnaces or other sources operating in the building. (The Aluminum

Association states that this option is not viable if there are other furnaces or sources inside the

Casthouse).

(C) Installing t emporary baffles on those sides or top of furnace opening if it is practical to do so

where they will not interfere with material handling or with the furnace door opening and closing

. (The Aluminum Association questions whether this would lower or minimi ze fugitive emissions).

(D) For furnaces with draft fans, i ncreasing the exhaust rate from the furnace, so as to capture

emissions that might oth erwise escape into the building if it can be done without increasing

furnace emissions in a way that make the t est non

- representative

. (The Aluminum Association

states that this is not feasible for natural draft furnaces).

(E) Minimizing the t ime the furnace doors are open or the top is off

.

(F) Delaying gaseous reactive fluxing u ntil charging doors are closed and the top is on

.

(G) Agitate or stir molten metal as soon as practicable after salt flux addition and closing doors as

soon as possible after solid fluxing operations, including mixing and dross removal. ( It is not

feasible to add flux “immediately before c losing charge doors” because solid flux must be stirred

and dross removed through the charging door immediately after salt addition).

(H) Keeping building doors and other openings closed to the greatest extent possible to minimize

drafts that would divert emissions from being drawn into the furnace ; or

(I) Maintain burners on low

- fire or pilot operation while the doors are open or the top is off.

Once again, we would like to thank you for allowing us the opportunity to comment on this issue. Please

conta ct my office (703

- 358

- 2981 or CJohnson@aluminum.org ) with questions or for further information.

Sincerely,

Charles D. Johnson

VP, Environment Health & Safety