From: gary.barnett@aleris.com

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

Cc: "Roy M. Harsch" <Roy.Harsch@dbr.com>

Date: 09/05/2012 01:23 PM

Subject: Fw: Methods 1 and 2 Frequency

Rochelle:

I am travelling this week with limited internet access. I have asked Roy Harsch to address Aleris' history with this

 issue and concerns we have raised with the USEPA in past negotiations. His summary is in the email below.

As Roy Harsch details, Aleris does not believe a pitot tube can function continuously in the ductwork due to the

 particulate level present. Using baghouse fan RPM checked monthly is an acceptable alternative to annual hood

 flow evaluations as determined by USEPA. Aleris proposes that regulatory language be added to Subpart RRR that

 recognizes RPM with monthly verification and 30 month flow verification using Methods 1 and 2 as an acceptable

 alternative to annual flow verification.

Please let me know if you need a more formal letter or is an email sufficient?

From: "Harsch, Roy M." [Roy.Harsch@dbr.com]

 Sent: 09/05/2012 04:28 PM GMT

 To: Gary Barnett

 Subject: RE: Methods 1 and 2 Frequency

Gary here is my response to what Ms. Boyd has provided in her latest email to you. I

 have to say that this whole discussion is one that we had when were

working out the terms of the Consent Decree. As I recall when discussed this issue we

 spent a lot of time talking to Todd Russo about it during the 

Consent Decree negotiations. Each time we made some headway, Todd would have to

 go back and discuss it with head quarters, the regions and the states. 

Since you are out of the office I have set out the draft provision and your comment

 from our original April 12, 2012 comment letter below. Also included as an 

attachment is your August 2, 2012 letter in response to the initial email from Ms. Boyd

 which requested the results of the flow monitoring results that you 

referenced in your original comment letter. It might be very helpful if she would

 either talk directly to Todd or set up a conference call to discuss this issue. As I

recall Aleris originally objected to having to measure volumetric flow rates in the

 ductwork on an annual basis because it would require the use of 

consultant services on what basically would be a continuous contract basis given the

 number of facilities and number of affected capture/collection systems and

because it would not really provide any useful information based upon your

 observations of the measurements that were being done at the time. One of the first
alternatives that Todd offered was the same as the alternative from Mr.Aulshin that

 Ms. Boyd sent you in her email of September 4, 2012. At the time you 

responded to Todd that this was really unworkable given the environment that you

 would encounter in the ductwork were you would have to install the Pitot 

tube. The particulate matter and other materials that are entrained in the gas flow

 would quickly result in fouling any tube that was installed. As I understand it 

there is nothing that would change your opinion that this suggested alternative would

 work any better now that it would have then when Todd accepted your

opinion. The requirement to test every 30 months was ultimately agreeable as long as

 Aleris would agree to measure the RPM of the fan motor. USEPA should 

accept this and propose it as alternative in the draft based upon the information your

 have submitted that shows very little real deviation in measured volumetric 

flow rate measurements that Aleris has had performed under the Consent Decree. If

 this is not done, then USEPA should at least make it clear that the RPM 

measurements are not needed as long as annual volumetric flow rate measurements are

 being done. If you agree I can draft a letter to send to Ms. Boyd.

April 12, 2012 Aleris International, Inc. Comment on Draft Proposed Amendments

§ 63.1510(d)(2) Inspect each capture/collection and closed vent system at least

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

the requirements in § 63.1506(c) and record the results of each inspection. The

inspection shall include a volumetric flow rate measurement taken at a location in the

ductwork downstream of the hoods which will be representative of the actual

volumetric flow rate without the interference of leaks, the introduction of ambient air

for cooling, or other ducts manifolded from other hoods.

While Aleris agrees with the need to routinely perform

 volumetric flow rate measurements, after negotiation with the EPA, a determination

 was made that a frequency of every 30 months was sufficient. This determination is

 documented in the Consent Decree. 

Approximately fifty rechecks have been performed to comply with the requirements of

 the decree or due to new stack testing. All have demonstrated that each system is

 operating in accordance with the requirements in § 63.1506(c). Therefore there is no

 need to conduct this flow measurement more than once every 30 months. 

In addition, volumetric flow rate measurement is a costly procedure. Such

 measurements are commonly performed by outside contractors at a cost of

 approximately $2,000 per day. Cost per inspection will vary by the number of

 systems to be checked. Requiring that this testing be conducted more frequently than

 once every 30 months would impose an undue burden on the industry.

Aleris also objects to the requirement to perform volumetric flow

 measurements on each hood. When multiple hoods are manifolded together, it is not

 always possible to meet Method 1 requirements on all hoods to be measured. At times

 it is necessary to measure the main trunk and arrive at the volumetric flow rate for an

 individual hood by calculation. For example, for a simple two hood configuration it

 may be necessary to measure the main trunk and subtract one duct that does meet

 Method 1 requirements (C=A-B) to determine the flow rate on the second hood. This

 method has been used repeatedly and submitted to the EPA and state agencies with

 stack test reports, and has been accepted. 

Response from Rochelle Boyd on my comment regarding the frequency for taking hood flow measurements.
She is requesting a response by Thursday.

From: Rochelle Boyd [Boyd.Rochelle@epamail.epa.gov]

 Sent: 09/04/2012 01:37 PM AST

 To: Gary Barnett

 Subject: Methods 1 and 2 Frequency

Hi Gary I am following up on your comment in regards to the frequency at which the Methods 1 and 2 are

 to are to be performed. As clarified in the interpretation letter dated 8/18/2006 by Michael Alushin, these

 methods are to be done annually. I understand your concern about the 30 month frequency allowed by

 your consent decree. We have tried to address this issue by allowing an alternative. We would like to

 receive any comments on this draft language by C.O.B. Thursday, Sept. 6th, if possible. This is not a

 mandatory request but I wanted to provide you the opportunity to review this draft. Thanks

Rochelle Boyd, Environmental Engineer

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

Ph: (919) 541-1390 Fax: (919) 541-3207

Email: boyd.rochelle@epa.gov

(ii) As an alternative to annual flow rate measurements

 using EPA Methods 1 and 2, measurement with EPA Methods

 1 and 2 can be performed once every five years,

 provided that,

(A) a flow rate indicator consisting of an S-type Pitot

 tube and differential pressure gauge (Magnehelic,

 manometer, or differential pressure gauge) is installed

 with the Pitot tip located at a representative point of

 the duct proximate to the location of the Method 1 and

 2 measurement site,

(B) the flow rate indicator is installed and operated in

 accordance with the manufacturer’s specifications,

(C) the differential pressure is recorded during the

 Method 2 performance test series,

(D) differential pressure readings are recorded monthly,

 and maintained at or above 90% of the pressure

 differential indicated by the flow rate indicator

 during the most recent Method 2 performance test

 series, and 

(E) an inspection of the Pitot tube and associated lines

 for damage, plugging, and leakage at least once per

 year.

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***********************************(See attached file: Boyd08012012 Response to

request for addtional information.pdf)


Aleris International Inc.

Furnace Hood Flow Measurements

Recycling

Chicago Hts #1 Rotary 16,190 20,641 08/18/09 T 26,062 01/17/12 21,133 05/09/12 T

#3 Rotary 26,114 56,826 06/12/12 T

Coldwater #7N Reverb 14,462 20,433 10/16/08 T 20,874 11/10/09 29,994 04/19/11

#8N Reverb 14,164 20,714 10/16/08 T 23,838 11/10/09 23,375 04/19/11

#1N Reverb 20,743 30,703 10/17/08 T 43,839 11/10/09 48,354 04/19/11

#1S Rotary 21,713 37,406 07/15/08 T 49,890 08/20/10

#2S Rotary 35,649 40,009 07/17/08 T 45,717 02/09/11

Friendly #1 Rotary 13,097 15,361 05/31/06 T 13,471 06/14/10 24,203 06/28/12

Goodyear #1 Rotary 21,895 34,166 03/26/07 T 39,941 12/03/09 34,370 09/12/11 T

Loudon #1 Rotary 15,840 26,957 01/11/07 T 33,509 05/12/09 39,106 09/02/11

#2 Rotary 16,290 26,690 01/11/07 T 31,871 05/12/09 28,265 09/02/11

#3 Rotary 15,270 26,666 01/11/07 T 33,907 05/12/09 31,506 09/02/11

Reverb Reverb 19,157 27,433 05/10/09 T 28,798 09/02/11

Morgantown #5 Rotary 20,685 16,732 05/09/06 T 16,780 11/04/09 22,519 04/11/11 T

#6 Rotary 20,872 15,649 05/09/06 T 15,995 11/04/09 21,850 04/11/11 T

#8 Rotary 21,405 53,044 03/06/12 T

#9 Rotary 21,045 41,963 03/06/12 T 43,695 06/07/12

Reverb Reverb 12,589 19,325 07/12/10 T 19,438 03/08/12

Post Falls #3 Rotary 21,745 24,603 07/12/06 T 26,494 06/03/09 31,551 10/18/11

Bens Run #1 Rotary 16,005 18,013 09/14/09 T 18,467 08/25/10 21,190 06/27/12

#2 Rotary 17,002 20,048 09/14/09 T 20,358 08/25/10 23,615 10/24/11 T

Saginaw #1 Reverb 12,780 11,594 09/11/07 T 22,693 12/17/08 24,683 11/12/09 24,968 06/14/12

#2 Reverb 14,325 17,605 09/11/07 T 15,620 12/17/08 18,378 11/12/09 18,534 06/14/12

#3 Reverb 12,015 15,018 09/10/07 T 17,954 12/17/08 17,981 11/12/09 23,767 06/14/12

Sapulpa #7 Rotary 22,040 25,377 06/22/10 T

Steele #1 Reverb 21,525 33,087 11/26/07 T 32,118 12/06/10

#2 Reverb 21,150 31,619 11/26/07 T 34,475 12/06/10

Wabash(S) #10 Reverb 22,988 23,716 09/23/08 T 26,022 08/16/10

#11 Reverb 23,850 25,515 09/23/08 T 26,175 08/16/10

#14 Reverb 25,288 25,550 09/23/08 T 25,587 08/16/10

#17 Reverb 24,567 29,296 05/15/08 T 45,463 08/17/10

Rolling

Uhrichsville #1 Rotary 12,984 18,390 07/13/09 T 18,435 12/08/11

#2 Rotary 13,269 22,856 07/16/09 T 26,779 12/08/11

#3 Rotary 13,509 21,954 07/13/09 T 23,933 12/08/11

#5 Rotary 12,534 21,435 07/16/09 T 24,719 12/08/11

#8 Rotary 13,508 26,142 07/16/09 T 28,299 12/08/11

#12 Reverb 22,690 49,291 02/08/10 T 55,643 05/17/11 44,778 08/29/11 T 45,095 06/27/12

Richmond #1 Reverb 15,675 34,469 05/31/11 T

#2 Reverb 16,797 38,894 05/31/11 T

#3 Reverb 19,873 36,988 05/31/11 T

Lewisport W2 Reverb 13,443 13,719 06/15/10 T 15,054 06/06/12

W1 Reverb 18,078 27112 04/11/12 T

Measured 

scfm Date Measured scfm Date Stack Test

Stack 

Test

LOCATION FURNACE ID EQUIPMENT

Calculated 

ACGIH 

Minimum scfm Date Measured 

scfm Date

ACTUAL 

Stack 

Test

ACTUAL ACTUAL ACTUAL 

Stack 

Test

Measured 

scfm

Attachment #1