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 S mall 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) 56 4.0965 (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 1 Attachment 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 quote6  

## 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 quote9



# 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 al l 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 cost effective 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 - a 

### million; & non cancer 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 - a 

### million; & 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 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 - a million; & 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 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  Ca pital 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 shut down

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 Production Background 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 Production Background 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 quoteAtt. 2 p 1 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 a nd 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/F a 0.80

2.50 l b/ton of feed μg TE Q/Mg of feed New and existing scrap dryer/delacquering kiln/decoating kiln

Or PM HCl THC D/F a 0.08

0.80 0.06 0.25 lb/ton of feed lb/ton of feed lb/ton of feed μ g 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/F a 0.30

1.50 0.20 5.0 lb/ton of feed lb/ton of feed lb/ton of feed μ g TEQ/Mg of feed New and existing sweat furnace D/F a 0.80 ng TEQ/dscm @ 11% O 2 b New and existing dross - only furnace PM 0.30 lb/ton of feed New and existing in - line fluxer c 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 r otary 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/to n of feed lb/ton of feed percent of the HCl upstream of an add - on control device New and existing group 1 furnace c PM 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/F a 15.0 μ g TEQ/Mg of f eed New and existing group 1 furnace c with clean charge only PM HCl 0.40

0.40 or lb/ton of feed lb/ton of feedAtt. 2 p 2 10 percent of the HCl upstream of an add - on control device D/F a No

Limit Clean charge only New and existing secondary aluminum processing unit a ,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) PM e

HCl f

D/F g

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: L iPM = the PM emission limit for individual emission unit i in the secondary aluminum processing unit [kg/Mg (lb/ton) of feed]; T i = the feed rate for individual emission unit i in the secondary aluminum processing unit; L tPM = the overall PM emission limit for the secondary aluminum processing unit [kg/Mg (lb - ton) of feed]; L iHCl = the HCl emission limit for individual emission unit i in the secondary aluminum processing unit [kg/Mg (lb/ton) of feed]; L tHCl = the overall HCl emission limit for the secondary aluminum processing unit [kg/Mg (lb/ton) of feed]; L iD/F = the D/F emission limit for individual emission unit i [μg TEQ/Mg (gr TEQ/ton) of feed]; L tD/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 sinc e 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?

2 Attachment 3

# 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. 3 Attachment 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” 1 

# for 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)
4 Attachment 3

# 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.
6 Attachment 3

# 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.
7 Attachment 3

# 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

8 Attachment 3

# 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 9 Attachment 3

# 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 decision making prior to the issuance of the proposed rule
 Placed in the rule’s docket when the proposed rule is published

10 Attachment 3

# 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

11 Attachment 3