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 firstalternatives 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