1

From: Nathaniel Jutras [Jutras.Nathaniel@epamail.epa.gov]

Sent: Monday, July 11, 2011 6:26 PM

To: gescudero@alliedmetalcompany.com; jlm@nffs.org; Woodard@epchc.org; Geoff@beckalum.com; bgriffin@scepterinc.com; DavidWagger@isri.org; donforchette; 

cjohnson@aluminum.org; rneilson@shapesllc.com; Dlammers@CohenBrothersInc.com; jerry@tap-rsi.com; harrietm@yaffeco.net; Michelle@crestwoodmetal.com

Cc: David.Rostker@sba.gov; Cortney_Higgins@omb.eop.gov; Lanelle Wiggins; Bahner, Mark A.; Anne Pope; Dave Guinnup; David Putney; Madeline Barch; Mark Kataoka; Michael 

Stewart; Rochelle Boyd; Steve Fruh; Susan Fairchild; Reeves, David; french.chuck@epa.gov; Green, David A.; srivastava.ravi@epa.gov

Subject: Follow-up to this afternoon's Introductory Meeting to Small Business Panel on Secondary Aluminum Production Risk and Technology Review

Attachments: SBAR Panel Briefing_RTR_Sec Aluminum_7-11-11.pptx; Appendix A.doc; An Overview of the Small Business Advocacy Review Panel Process.pptx

Dear Potential SERs,

Thank you again for your time this afternoon. Attached are the following 

materials:

1) The latest version of the PowerPoint Rochelle navigated us through today entitled "SBAR Panel Briefing_RTR_Sec Aluminum_7-11-

11/pptx"

2) "Appendix A" a supporting document for "SBAR Panel Briefing_RTR_Sec Aluminum_7-11-11/pptx"

3) "An Overview of the Small Business Advocacy Review Panel Process.pptx", which Lanelle went over briefly at the start of our 

call.

Once again, we look forward to receiving your written feedback. You may do so through July 25 by email (recommended) at 

Jutras.Nathaniel@epa.gov or by post at the address provided below. 

Regards,

Nathaniel P. Jutras

U.S. Environmental Protection Agency 

Office of Policy, Regulatory Management Division 1200 Pennsylvania Ave. NW, Mailcode 1806A Washington, DC 20460 

(P) (202) 564.0301 (F) (202) 564.0965

(See attached file: SBAR Panel Briefing_RTR_Sec Aluminum_7-11-11.pptx) (See attached file: Appendix A.doc)(See attached file: An 

Overview of the Small Business Advocacy Review Panel Process.pptx) 
Risk and Technology Review (RTR) 

for Secondary Aluminum 

Production

Briefing for the SBAR Panel

By Rochelle Boyd

U.S. EPA 

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

June 2011

Attachment 1 1
Overview

 SER and SBAR Panel

 Secondary Aluminum Production Source Category

 Existing Emissions Standards

 Affected Sources and Regulated Pollutants

 Equipment at Small Entities

 Coverage of Equipment by SERs

 Existing Control Devices

 Risk & Technology Review Requirements

 Data Collection Process and Results

 Potential Changes to the Standards

 Potential Impacts to Small Entities

 Possible Compliance Schedules

 Secondary Aluminum RTR Schedule

2
Small Entity Representative (SER) and 

Small Business Advocacy Review Panel

 A SER is a representative of a small entity who may be subject 

to the requirements of a proposed rule that the EPA has under 

development.

 SERs’ participation in the rulemaking process helps to ensure 

that the EPA hears the concerns and suggestions of small 

entities.

 The Small Business Advocacy Review (SBAR) Panel (EPA, SBA, & 

OMB) uses SER’s input to prepare a report that includes the 

Panel’s recommendations on minimizing the burden on small 

entities. 

 The report is part of the rulemaking record and is considered by 

Agency decision makers.

3

DRAFT - Do not cite or quote 
Potential SER Nominees

4

DRAFT - Do not cite or quote 
Secondary Aluminum Production –

Source Category Description

 The source category includes facilities that recover aluminum from 

scrap materials such as beverage cans, foundry returns, dross, and 

other scrap.

 Facilities in the source category conduct the following operations: 

 separation of aluminum from iron;

 preprocessing of scrap aluminum, including size reduction and removal 

of oils, coatings, and other contaminants;

 furnace operations including melting, in-furnace refining, fluxing, and 

tapping; 

 additional refining, by means of in-line fluxing;

 separation of aluminum from dross and cooling of dross. 

 Currently there are approximately 150 facilities in the U.S. Of these, 

an estimated 57 facilities are owned small entities.

5

DRAFT - Do not cite or quote 
6

 National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

for the Secondary Aluminum Production source category were 

promulgated on March 23, 2000

 The NESHAP were based on Maximum Achievable Control Technology 

(MACT) 

 Apply to all major sources 

 Do not apply to area sources, unless they operate affected sources 

emitting dioxins and furans (D/F)

 Thermal chip dryer, Scrap dryer/Decoating/Delacquering kiln, Sweat furnace, Group 1 

furnace handling other than clean charge

 Regulated pollutants

 PM - Particulate Matter (surrogate for metal HAP)

 THC - Total Hydrocarbon (surrogate for organic HAP, except for D/F) 

 HCl - Hydrogen Chloride (surrogate for inorganic HAP)

 D/F – Dioxins and Furans (based on 1989 TEQ factors)

Existing Emissions Standards

DRAFT - Do not cite or quote 
Affected Sources and Regulated Pollutants

 Aluminum scrap shredders - PM

 Thermal chip dryers – THC, D/F

 Scrap Dryers/ Delacquering Kilns/ Decoating Kilns (terms 

used interchangeably) - THC, PM, D/F, HCl

 Sweat furnaces – D/F

 Dross-only furnace – PM

 Rotary dross cooler – PM

 Group 1 furnace – PM, HCl, and D/F (if facility processes 

anything other than clean charge) 

 In-line fluxer – HCl, PM (if using reactive flux)

Note: More details on the emission standards are provided in Appendix A.

7

DRAFT - Do not cite or quote 
 Secondary Aluminum Processing Unit (SAPU) 

 The NESHAP has an optional averaging provision that 

allows all existing group 1 furnaces and in-line fluxers, or 

all new group 1 furnaces and in-line fluxers, to 

demonstrate compliance as a group for PM, HCL, and 

D/F, if they are processing anything other than clean 

charge

 Foundries, diecasters, and extruders are excluded if 

 They use only clean charge and 

 Do not operate affected sources regulated for 

Dioxins/Furans (D/F)

8

Affected Sources and Regulated Pollutants 

(continued)

DRAFT - Do not cite or quote 
9

Equipment at Small Entities

Area Sources Major Sources

Number of Facilities 50 7

Type of equipment # of facilities

w/ equipment

Total # of 

equipment units

# of facilities

w/ equipment

Total # of 

equipment units

Aluminum Scrap Shredder 9 11 2 2

Dross-only Furnace 2 4 0 0

Group 1 Furnace--Handling other than clean 

charge 19 41 7 7

Group 1 Furnace--Clean charge only 4 13 0 0

In-line Fluxer 4 8 2 6

Rotary Dross Cooler 4 7 1 1

Scrap Dryer/Delacquering/Decoating Kiln 4 7 0 0

Sweat Furnace 28 32 3 5

Thermal Chip Dryer 3 5 0 0

Note 1: Equipment highlighted in yellow subject to Subpart RRR

Note 2: Area source equipment only subject to D/F standards (not PM, 

THC, or HCl)

DRAFT - Do not cite or quote 
Coverage of Equipment by Potential SERs

10

Note:

1) The Aluminum Association has currently reported that they are representing 32 small entities, since that is more than half of all of the 

small entities, it is assumed that they would represent most of the types of equipment that are widely used in small entities. 

DRAFT - Do not cite or quote 

Nominee Equipment (Number of Pieces, Major/Area Source Status) Area

Source = 

Area

Major 

Source = 

Major

Allied Metal Company Group 1 Furnace handling other than clean charge (1) Area

Gulf Coast Metals Group 1 Furnace handling other than clean charge (2) Area

Beck Aluminum Group 1 Furnace handling other than clean charge (3) Area

Scepter, Inc. Scrap Shredder (2); Group 1 Furnace handling other than clean charge (7); In-line 

fluxer (1)

Area

Golden Aluminum Scrap Shredder (3); Scrap Dryer/Delacquering/Decoating Kiln (1); Group 1 Furnace

handling other than clean charge (3); In-line Fluxer (3); Group 2 Furnace (3)

Area

Trialco, Inc. Group 1 Furnace handling other than clean charge (2) Area

Staker Alloys Sweat Furnace (1) Area

Tennessee Aluminum 

Processors

Group 1 furnaces handling other than clean charge (5); Dross-only furnace (1) Area

Yaffee Iron Sweat Furnace (1) Area

Aluminum Shapes Group 1 furnace (3); Group 2 furnace (3); In-line fluxers (3) Major

Crestwood Metals Scrap Shredder (1); Sweat Furnace (3) Major
Existing Control Devices 

 Aluminum Scrap Shredders

 Fabric filters to control HAP metals

 Thermal Chip Dryers - remove water and lubricants from 

chips generated from machining

 Afterburners used to control THC and D/F

 Scrap dryers/delacquering kilns - remove paint, coatings, 

organics, rubber, insulation, and plastic from scrap

 Afterburners used to control THC and D/F

 Lime coated fabric filters used to control HCl and PM

 Sweat furnaces - separate aluminum from iron and steel

 Afterburners used to control D/F

11

DRAFT - Do not cite or quote 
Existing Control Devices 

 Dross-only Furnaces - recover aluminum from dross 

 Fabric filters to control HAP metals

 Rotary dross coolers 

 Fabric filters to control HAP metals

 Group 1 furnaces - melt contaminated scrap and/or use 

reactive flux

 Lime injected fabric filters used to control HCl and PM

 Some uncontrolled sources may meet standards

 In-line fluxers - chlorine or chlorine/inert gas blend used 

to refine and degas molten aluminum

 Lime coated fabric filters used to control HCl and PM

12

DRAFT - Do not cite or quote 
Risk & Technology Review (RTR) Requirements

 The Clean Air Act (CAA) requires the EPA to conduct the RTRs within 

8 years after promulgation of the MACT standard. 

 For the Technology Review, pursuant to Section 112(d)(6), we 

evaluate developments in practices, processes and controls that may 

be available to reduce HAP emissions beyond MACT.

 If we identify cost-effective and feasible approaches to further reduce 

emissions, we revise the NESHAP as appropriate.

 For the Risk Review, pursuant to Section 112(f), we assess the 

remaining risks due to HAP emissions after implementation of the 

NESHAP and revise the standards, if appropriate.

 The RTR will be reflected as amendments to the NESHAP. 

13

DRAFT - Do not cite or quote 
Residual Risk Approach

 To assess risks we gather data on emissions, processes and facilities, 

and apply models to estimate cancer risks, chronic non-cancer risks, 

acute non-cancer risks.

 The main objective is to estimate risks due to emissions from 

Secondary Aluminum Production sources.

 However, we also estimate risks based on emissions from co-located 

(non-secondary aluminum sources) to the extent feasible.

 e.g., primary aluminum production, metal coating, foundry, casting, and extruding 

operations

 We do not yet have risk results, we expect to have results by early 

August 2011. 

14

DRAFT - Do not cite or quote 
Risk Review vs. Technology Review

 Risk is evaluated by both the toxicity of pollutants and the 

exposure potential

 For both residual risk and technology reviews, we evaluate 

control options

 Technology is evaluated by the effectiveness of emission controls 

and systems in the industry

 In most cases, we have flexibility in how we revise MACT 

standards

 After evaluating control options for both reviews, if further 

regulation is needed, we choose options that are costeffective and reduce risks to protect public health with an 

ample margin of safety

15

DRAFT - Do not cite or quote 
Data Collection Request Sent to All Companies to 

Gather Information for the RTR

 We searched several data sources to try to identify all potential 

Secondary Aluminum facilities in the U.S., including:

 EPA’s National Emissions Inventory

 Data gathered during development of the initial MACT standard

 Industry sources 

 We sent an Information Collection Request (ICR) to all facilities 

identified as potential facilities subject to the Secondary Aluminum 

Production MACT to obtain:

 Capacity and production data

 Actual emissions data for both category and non-category sources

 Stack characteristics

 Regulated equipment list

 Technology information

 We received responses, and a large amount of data, from most 

facilities to inform our RTR analyses. 

16

DRAFT - Do not cite or quote 
Changes in the Industry

 About 400 facilities existed in 1999 when the NESHAP 

was initially proposed.

 Based on extensive research, and based on responses to 

the ICRs, we estimate that only 150 facilities are currently 

operating.

 The number of facilities decreased significantly since 1999 

due to mergers and buy-outs from larger companies and 

plant closures.

 We believe we have identified the vast majority of the 

existing facilities and have received data from most of 

these 150 facilities. 

17

DRAFT - Do not cite or quote 
Emissions Test Request Sent to Nine Companies to Collect 

Speciated HAP Data

 In order to conduct the risk assessment, we needed 

information on emissions of individual HAPs

 Volatile and Semi-volatile HAP

 Obtained speciated organic HAP data to apply to actual and 

allowable THC emissions for risk assessment input

 Fabric Filter particulate analysis

 Obtained speciated HAP metals data, including hexavalent 

chromium, to apply to actual and allowable PM emissions for risk 

assessment input

18

DRAFT - Do not cite or quote 
Selection of Nine Companies for Testing

19

 Primary test objective was to get speciated HAP data representative 

of the industry

 Companies were chosen to cover the range of relevant equipment 

applicable to this industry.

 As shown in Slides 20 and 21, we obtained data from the range of 

relevant equipment across the industry.

DRAFT - Do not cite or quote 
Nine-Company Test Request to Collect 

Speciated HAP Data

20

Equipment Number of Samples

Scrap shredders 7

Chip dryers 8

Scrap dryer/delacquering/

decoating kiln

9

Group 1 furnace 23

Rotary dross furnace 1

In-line fluxer 1

Group 1 furnace + delacq. 3

Shredder and others 1

Group 1 furnace + shredders 2

Total 55

Baghouse Dust Sampling for Metal HAP

DRAFT - Do not cite or quote 

Metal HAP include lead, arsenic, cadmium, berylium, manganese, mercury, nickel, 

chromium, selenium, antimony and cobalt.
21

Equipment Number of Samples

Chip dryers 5

Scrap dryer/delacquering/

decoating kiln

7

Total 12

Stack sampling for HAP organics

Nine-Company Test Request to Collect

Speciated HAP Data

DRAFT - Do not cite or quote 
Technology Review -

Findings from Preliminary Research

 European multi-chamber furnaces combine delacquering and melting 

functions

 In use worldwide but rare in the U.S.

 May minimize THC and D/F emissions from processing used beverage 

containers and other similar scrap

 Reduce fuel consumption

 Very limited emissions test data available

 Eddy current separators

 Sweat furnaces “sweat” aluminum off of bulk materials (e.g. engine blocks)

 If a part, or entire automobile, goes through an automobile shredder, small 

chunks aluminum may be separated by eddy current separators, which do 

not have air emissions. 

 Aluminum separated would go into a Group 1 furnace.

 Eddy current separators therefore reduce usage of sweat furnaces and 

increase usage of rotary furnaces.

 Could eliminate the need for, and emissions from, sweat furnaces in some 

applications

 Non-thermal (e.g., centrifugal) chip dryers

 May reduce the need for thermal chip dryers (may not be suitable for all 

situations)

22

DRAFT - Do not cite or quote 
Potential Regulatory Outcomes Based on Risk Results and 

the Estimated Costs of Those Outcomes

Process 

Units

Relevant 

HAPs

If cancer risks 

are < 1 in-amillion; & noncancer HI < 1

If cancer risks are between 1 

in-a-million to 100 in-a-million; 

or HIs are moderately > 1

If cancer risks > 100 in a 

million; or HIs are well 

above 1

Sweat 

Furnaces

D/F Propose no 

action.

No costs.

 Propose tighter limits to reduce 

emissions if economically 

feasible controls are identified

to achieve such reductions.

 The costs could range up to the 

amounts shown in the column 

to the right.

 Propose tighter limits that 

reflect baghouse with 

activated carbon injection 

(ACI). 

 Capital Costs = $64,000 per 

facility

 Annualized cost = $33,000 

per facility

Group 1 

Furnaces 

handling 

other than 

clean 

charge at 

major 

sources

PM (HAP 

metals)

Propose no 

action.

No costs.

 Propose tighter limits if 

economically feasible controls 

are identified.

 The costs could range up to the 

amounts shown in the column 

to the right.

 Propose tighter PM limits 

that reflect better baghouses. 

 Capital Costs = $49,000 to 

$100,000 per facility

 Annualized cost = $9,000 to 

$30,000 per facility 

23

HI = Hazard Index

DRAFT - Do not cite or quote 
Potential Regulatory Outcomes Based on Risk Results and 

the Estimated Costs of those Outcomes

Process 

Units

Relevant 

HAPs

If cancer risks 

are < 1 in-amillion; & 

noncancer HI 

< 1

If cancer risks are between 1 ina-million to 100 in-a-million; 

or HIs are moderately > 1

If cancer risks > 100 in a 

million; or HIs are well 

above 1

Group 1 

Furnaces 

handling 

other than 

clean charge 

at area 

sources

D/F Propose no 

action.

No costs.

 Propose tighter limits to reduce 

emissions if economically 

feasible controls are identified .

 The costs could range up to the 

amounts shown in the column to 

the right.

 Propose tighter limits that 

reflect adding ACI to existing 

baghouses. 

 Capital Costs = $25,000 to 

$50,000 per facility

 Annualized cost = $90,000 to 

$180,000 per facility 

Group 1 

Furnaces 

handling 

other than 

clean charge 

at major 

sources

D/F, THC Propose no 

action.

No costs.

 Propose tighter limits to reduce 

emissions if economically 

feasible controls are identified .

 The costs could range up to the 

amounts shown in the column to 

the right.

 Propose tighter limits that 

reflect adding ACI to existing 

baghouses. 

 Capital Costs = $25,000 to 

$50,000 per facility

 Annualized cost = $90,000 to 

$180,000 per facility 

24

DRAFT - Do not cite or quote 
Potential Regulatory Outcomes Based on Risk Results and 

the Estimated Costs of those Outcomes

Process Units Relevant 

HAPs

If cancer risks 

are < 1 in-amillion; & 

noncancer HI 

< 1

If cancer risks are between 1 in-amillion to 100 in-a-million; 

or HIs are moderately > 1

If cancer risks > 100 in a million; 

or HIs are well above 1

Group 1 

Furnaces 

handling 

other than 

clean charge 

at major 

sources, or 

in-line fluxers

at major 

sources.

HCl Propose no 

action.

No costs.

 Propose tighter limits to reduce 

emissions if economically 

feasible controls are identified .

 The costs could range up to the 

amounts shown in the column 

to the right.

 Propose tighter limits that 

reflect adding additional 

lime to existing lime 

injection systems

 Capital Costs = $0 per 

facility

 Annualized cost = $8,000 

per facility 

25

DRAFT - Do not cite or quote 

Notes: 

1) Annualized costs for ACI and additional lime injection include annual waste disposal costs of $2,000 and 

$4,000, respectively.

2) There are no small entity major sources having thermal chip dryers or scrap dryer/delacquering/decoating 

kilns.
 The EPA will focus mainly on the outcome of the risk analysis because, 

based on preliminary analyses, it is expected that the technology review 

will probably not result in significant changes for existing facilities under 

the 112(d)(6) review.

 However, the EPA will continue to assess potential impacts that the 

technology review or other possible rule amendments may have on 

regulated small entities as we review the data received. 

 If the EPA determines that it can certify that the proposed rule will not 

have a significant economic impact on a substantial number of directly 

regulated small entities, then this SBAR Panel will not be necessary and 

will be discontinued. 

26

Potential Impacts to Small Entities

DRAFT - Do not cite or quote 
RTR Secondary Aluminum –

Other Possible or Projected Regulatory Actions 

 Replace capture standards (Projected)

 Current rule requires capture based on American Conference of Governmental 

Industrial Hygienists (ACGIH) guidelines.

 Incorporated edition is out of print 

 The EPA intends to update this section using the latest edition

 Start-up and Shut-down (Projected)

 Revisions to the rule will likely be necessary due to the vacatur of the General 

Provisions (40 CFR §§ 63.6(f)(1) and 63.6(h)(1)).

 However, no economic impacts expected due to this change

 Uncontrolled group 1 furnaces (Possible)

 The EPA has been asked to look into adding emissions capturing requirements 

during performance testing

 We may possibly add provisions to account for these emissions

 Area sources would only be affected if they process anything other than clean 

charge

 We have not yet estimated the costs for these actions, but we expect that 

these actions are unlikely to pose significant economic burden to 

companies.

27

DRAFT - Do not cite or quote 
 Under section 112(f), facilities have 90 days to comply with 

standards developed to address Residual Risks at existing 

facilities

 However, this can be extended up to 2 years after the 

effective date for existing sources if that extra time is 

needed to install controls.

 For standards under section 112(d)(6) (technology review), 

we can provide up to 3 years for existing facilities to comply. 

 The timeline for compliance will be determined by the type 

of standards developed.

28

Possible Compliance Schedules

DRAFT - Do not cite or quote 
Secondary Aluminum RTR Schedule

 Small Business Outreach Meeting – July 11, 2011 

 Panel convened - August 8, 2011

 Panel meeting with SERs – August 22, 2011

 Written SER Comments – September 6-8, 2011

 Final report – October 7, 2011

 Administrator signature for proposal - November 30, 

2011 (court ordered) 

29

DRAFT - Do not cite or quote 
Appendices

30

 Appendix A

 Emission Limits (Sent as a separate 

document)

 Appendix B

 See Slides 31-39
Start-up and Shut-down 

31

 Start-up and Shut-down exemptions were 

vacated by court order in Sierra Club v. EPA, 

551 F.3d 1019 (D.C. Cir. 2008).

 No test data available for periods of Start-up 

and Shut-down

 Current limits apply during start-up and shutdown 

DRAFT - Do not cite or quote 
Start-up and Shut-down 

32

 Operating parameters established during worst case production are 

typically established during periodic testing.*

 gas flow to control device

 operating temperature of afterburner

 gas residence time in afterburner

 lime addition rate to fabric filter

 COMs, bag break detectors 

*As appropriate for controlled processes

 Testing requires minimum sampling periods, sample volumes and 

number of runs. Startup and shutdown durations are not long enough 

to conduct testing, determine numerical emission standards and 

establish operating parameters

DRAFT - Do not cite or quote 
Start-up and Shut-down 

33

 Emissions (mass/time) would be much lower during 

startup and shutdown than during normal operation 

because:

 no solid metal addition

 no dioxin precursor addition

 no flux addition

 Typical work practices:

 maintain flow to control device for controlled processes

 no fluxing

 no solid metal addition

DRAFT - Do not cite or quote 
Start-up and Shut-down 

34

 Impractical to measure emissions and establish 

operating parameters specific to during these 

periods

 Some startups, e. g. shredder, take place with the 

flip of a switch

 Emissions will be lower during these period than 

during normal operation.

 Maintenance of parameters will ensure 

maximum achievable control technology 

DRAFT - Do not cite or quote 
RTR Secondary Aluminum –

Other Possible Minor Projected Actions

 Reporting and recordkeeping requirements could 

change to reflect any new requirements

 Editorial Errors, Clarifications, Issues with 

Implementation or Compliance

 Typos, plus issues raised by States and regions

 Clarify language regarding “Worst” case 

performance testing as applied to different 

operating scenarios

 Improve EIS database – After the final rule, the 

corrected data will be input into the EIS database.

35

DRAFT - Do not cite or quote 
Secondary Aluminum ProductionBackground Information

 List of facilities sent an ICR based on:

 2007 risk modeling file for Secondary Aluminum, based on 2002 

NEI (National Emissions Inventory) (348 facilities) (List #1)

 List of facilities developed for 1999 MACT standards proposal (976 

facilities) (List #2)

 U.S. facilities listed in Metal Age magazine list of “Secondary 

Aluminum Smelters of the World” (317 facilities) (List #3)

 Added sweat furnace facilities from list maintained by sweat 

furnace servicing company (76 facilities) (List #4)

 Added facilities (mostly salvage yards) from EPA OTIS (Online 

Tracking Information System) database (~70 facilities) (List #5)

 Deliberate attempt to err on the side of sending to potential 

Subpart RRR sources

36

DRAFT - Do not cite or quote 
Secondary Aluminum ProductionBackground Information

 List of facilities sent an ICR determined by:

 Starting with facilities common to List #1, #2, and #3

 Adding facilities common to List #1 plus either #2 or #3

 Adding facilities common to List #2 and #3 (but not #1)

 Adding sweat furnaces from List #4

 Adding OTIS database facilities from List #5

 Total number of facilities sent ICR was 422

 Number of facilities sent ICR was much less than the 976 

facilities in List #2 because List #2 contained many 

duplicates and many foundries (that were subsequently 

not included in the Subpart RRR standards)

 2007 Economic Census reports 134 facilities for NAICS code 

331314 (facility IDs are confidential)

37

DRAFT - Do not cite or quote 
RTR Secondary Aluminum –

112(d)(6) Technology Review 

 Alternative controls, monitoring, or operating conditions 

 establish maximum fraction of painted material per cycle (1)

 carbon injection (4)

 COMs feedback to reduce firing rate (during excursions) (1)

 Control logic (afterburner temperature and in-furnace opacity) (1)

 Ammonia injection (5) (one source claims that this is for control of chlorine)

 Non-reactive flux (1)

 Wet scrubber for PM from shredder (1)

 Lime injection for PM control (2)

38

ICR responses were received regarding alternative controls, monitoring, 

or operating conditions for Subpart RRR MACT sources, and pollution 

prevention measures. 

DRAFT - Do not cite or quote 
RTR Secondary Aluminum –

112(d)(6) Technology Review 

 Pollution prevention measures

 Scrap selection, sorting, inspection, purchase specs, etc. (~28)

 Altered flux location (3) 

 Reduced or eliminated reactive flux (22)

 Door/afterburner interlock (2)

 Charge door/hearth temperature and Charge door/opacity interlock (2)

 Multichamber furnace uses no flux (1) 

 Ammonia addition to reduce HCl emissions (1)

 Low NOx burners (1) 

39

ICR responses were received regarding alternative controls, monitoring, 

or operating conditions for Subpart RRR MACT sources, and pollution 

prevention measures. 

DRAFT - Do not cite or quote 
Att. 2 p1

Appendix A

Affected source/ Emission unit Pollutant Limit Units

All new and existing affected sources and emission 

units that are controlled with a PM add-on control 

device and that choose to monitor with a 

Continuous Opacity Monitor (COM) and all new 

and existing aluminum scrap shredders that choose 

to monitor with a COM or to monitor visible 

emissions

Opacity 10 Percent

New and existing aluminum scrap shredder PM 0.01 gr/dscf

New and existing thermal chip dryer THC

D/Fa

0.80

2.50

lb/ton of feed

μg TEQ/Mg of feed

New and existing scrap dryer/delacquering 

kiln/decoating kiln

 Or

PM

HCl

THC

D/Fa

0.08

0.80

0.06

0.25

lb/ton of feed

lb/ton of feed

lb/ton of feed

μg TEQ/Mg of feed

Alternative limits if afterburner has a design 

residence time of at least 1 second and operates at a 

temperature of at least 1400 °F

PM

HCl

THC

D/Fa

0.30

1.50

0.20

5.0

lb/ton of feed

lb/ton of feed

lb/ton of feed

μg TEQ/Mg of feed

New and existing sweat furnace D/Fa0.80 ng TEQ/dscm @ 11% O2

b

New and existing dross-only furnace PM 0.30 lb/ton of feed

New and existing in-line fluxerc HCl

PM

0.04

0.01

lb/ton of feed

lb/ton of feed

New and existing in-line fluxer with no reactive 

fluxing

No limit Work practice: no reactive 

fluxing

New and existing rotary dross cooler PM 0.04 gr/dscf

New and existing clean furnace (Group 2) No limit Work practices: clean 

charge only and no reactive 

fluxing

New and existing group 1 melting/holding furnace 

(processing only clean charge)c

PM

HCl

0.80

0.40

or

10

lb/ton of feed

lb/ton of feed

percent of the HCl 

upstream of an add-on 

control device

New and existing group 1 furnacecPM

HCl

0.40

0.40

or

10

lb/ton of feed

lb/ton of feed

percent of the HCl 

upstream of an add-on 

control device

D/Fa15.0 μg TEQ/Mg of feed

New and existing group 1 furnacec with clean 

charge only

PM

HCl

0.40

0.40

or

lb/ton of feed

lb/ton of feed
Att. 2 p2

10 percent of the HCl 

upstream of an add-on 

control device

D/Fa No 

Limit

Clean charge only

New and existing secondary aluminum processing 

unita,d (consists of all existing group 1 furnaces and 

existing in-line flux boxes at the facility, or all 

simultaneously constructed new group 1 furnaces 

and new in-line fluxers)

PMe

 

 









 n

i

i

n

i

i i

t

T

L T

L

PM

PM

1

1

HClf

 

 









 n

i

i

n

i

i i

t

T

L T

L

HCl

HCl

1

1

D/Fg

 

 









 n

i

i

n

i

i i

t

T

L T

L

D F

D F

1

1

/

/

a D/F limit applies to a unit at a major or area source.

b

Sweat furnaces equipped with afterburners meeting the specifications of §63.1505(f)(1) are not required to conduct 

a performance test.

c These limits are also used to calculate the limits applicable to secondary aluminum processing units.

d Equation definitions: LiPM = the PM emission limit for individual emission unit i in the secondary aluminum 

processing unit [kg/Mg (lb/ton) of feed]; Ti = the feed rate for individual emission unit i in the secondary 

aluminum processing unit; LtPM = the overall PM emission limit for the secondary aluminum processing unit 

[kg/Mg (lb-ton) of feed]; LiHCl = the HCl emission limit for individual emission unit i in the secondary aluminum 

processing unit [kg/Mg (lb/ton) of feed]; LtHCl = the overall HCl emission limit for the secondary aluminum 

processing unit [kg/Mg (lb/ton) of feed]; LiD/F = the D/F emission limit for individual emission unit i [μg 

TEQ/Mg (gr TEQ/ton) of feed]; LtD/F = the overall D/F emission limit for the secondary aluminum processing 

unit [μg TEQ/Mg (gr TEQ/ton) of feed]; n = the number of units in the secondary aluminum processing unit.

e

In-line fluxers using no reactive flux materials cannot be included in this calculation since they are not subject to 

the PM limit.

f

In-line fluxers using no reactive flux materials cannot be included in this calculation since they are not subject to 

the HCl limit.

g Clean charge furnaces cannot be included in this calculation since they are not subject to the D/F limit.
Office of the Administrator

Office of Policy

Office of Regulatory Policy and Management

http://www.epa.gov/op/orpm.html

An Overview of the Small Business 

Advocacy Review Panel Process

Alexander Cristofaro, Small Business Advocacy Review Chair (SBAC)

Pre-Panel Outreach Meeting, July 11, 2011

Attachment 3
Today, I’ll answer these questions...

• What is a Small Business Advocacy Review (SBAR) 

Panel?

• How does a Panel fit into the rulemaking process?

• How do Small Entity Representatives (SERs) participate 

in the Panel process?

• What is the difference between this Pre-Panel meeting 

and the future Panel meeting?

• What does the Panel do with SER recommendations?

Attachment 3 2
What is an SBAR Panel?

• A Panel consists of representatives from 

the: 

 agency authoring the regulation (i.e., EPA),

 Office of Management and Budget (OMB), 

and

 Small Business Administration (SBA).

Title 5, section 609(b)(3), of the United States Code (USC). This is also known as section 609(b)(3) of the RFA.

Attachment 3 3
What is an SBAR Panel? (cont’d.)

• SBREFA amended the 1980 Regulatory 

Flexibility Act (RFA), which requires 

agencies to:

“assure that small entities have been given an 

opportunity to participate in the rulemaking process”1for 

any rule “which will have a significant economic impact 

on a substantial number of small entities.”2

1 5 USC 609(a)

2 5 USC 602(a)(1)

Attachment 3 4
Panel within the rulemaking process?

“the panel shall review any material the agency has prepared..., including 

any draft proposed rule, collect advice and recommendations of each 

individual small entity representative identified by the agency after consultation 

with the Chief Counsel for Advocacy of the Small Business Administration, on 

issues related to”1 the following:

 Who are the small entities to which the proposed rule will apply? 2

 What are the anticipated compliance requirements of the upcoming proposed 

rule? 3

 Are there any existing federal rules that may overlap or conflict with the 

regulation? 4

 Are there any significant regulatory alternatives that could minimize the impact 

on small entities? 5

5

1 5 USC 609(b)(4)

2 5 USC 603(b)(3)

3 5 USC 603(b)(4)

4 5 USC 603(b)(5)

5 5 USC 603(c)

Attachment 3
Panel within the rulemaking process? 

(cont’d.)

Let’s focus on “any material the agency has 

prepared” 

 For this Panel, EPA will not provide a proposed rule, though we 

expect to discuss regulatory alternatives in as great a detail as 

we can.

 It is EPA’s policy to host SBAR Panels like this one well before a 

proposed rule is written so we have adequate time to 

incorporate your advice and recommendations into senior 

management decision-making about the proposed rule.

 Participation in the Panel outreach meeting does not preclude or 

take the place of participation in the normal public comment 

period at the time the rule is proposed.

Attachment 3 6
How do SERs participate?

...Let’s focus on “collect advice and 

recommendations”

 This is how SERs help the Panel members.

• You’re invited to provide advice and recommendations on the 

materials shared today and at the future Panel outreach 

meeting.

• You will have an opportunity to submit written comments as 

well as the verbal comments you provide in the meetings.

 Those of you joining this meeting to assist the 

potential SERs are asked not to speak to allow the 

potential SERs ample time to talk.

Attachment 3 7
How do SERs participate? (cont’d.)

• As potential SERS, you are in a unique 

position during the Pre-Panel outreach and 

Panel outreach meetings

• You have the opportunity, because of your 

status as a small entity expected to be 

regulated by this rule, to influence the 

decisions senior EPA officials make about 

the forthcoming regulation

Attachment 3 8
Pre-Panel vs. Panel Outreach Mtg.?

• Pre-Panel Outreach Meeting

 Conducted by EPA with SBA and OMB as invitees

 Overview of the RFA, how the Panel process works, 

and the role of SERs

 Background and overview of proposed rulemaking 

• Panel Outreach Meeting

 Chaired by SBAC, but all Panel members have active 

role

 Bulk of meeting spent discussing regulatory 

alternatives and input of SERs

Attachment 3 9
What does the Panel do 

with your recommendations?

• EPA, OMB, and SBA prepare a joint Panel 

report:

 Submitted to the EPA Administrator

 Considered during senior-management decisionmaking prior to the issuance of the proposed rule

 Placed in the rule’s docket when the proposed rule is 

published

Attachment 3 10
Contact Information

• Contact my staff:

 Nathaniel Jutras, RFA/SBREFA staff contact

EPA Office of Policy

(202) 564-0301

Jutras.Nathaniel@epa.gov

 Lanelle Wiggins, RFA/SBREFA Team Leader

EPA Office of Policy

202-566-2372

Wiggins.Lanelle@epa.gov 

Attachment 3 11