National Emission Standards for Hazardous Air Pollutants for Source Categories; National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production
Federal RegisterFeb 11, 1999
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SUMMARY: This action proposes national emission standards for hazardous
air pollutants (NESHAP) for new and existing sources at secondary
aluminum production facilities. Hazardous air pollutants (HAPs) emitted
by the facilities that would be regulated by this proposed rule include
HAP organics, inorganic HAPs (hydrogen chloride, hydrogen fluoride, and
chlorine), and particulate HAP metals. Some of these pollutants,
including 2,3,7,8-tetrachlorodibenzo-p-dioxin, are considered to be
known or suspected carcinogens and all can cause toxic effects
following sufficient exposure. Emissions of other pollutants include
particulate matter and volatile organic compounds.
The standards are proposed under the authority of section 112(d) of
the Clean Air Act (the Act) and are based on the Administrator's
determination that secondary aluminum production plants are major
sources of HAP emissions and emit several of the HAPs listed in section
112(b) of the Act from the various process operations found within the
industry. The proposed NESHAP would reduce risks to public health and
environment by requiring secondary aluminum production plants to meet
emission standards reflecting application of the maximum available
control technology (MACT). Secondary aluminum production plants that
are area sources would be subject to limitations on emissions of
dioxins and furans (D/F) only. Implementation of the proposed NESHAP
would reduce emissions of HAPs and other pollutants by about 16,600
megagrams per year (Mg/yr) (18,300 tons per year (tpy)).
DATES: Comments. The EPA will accept comments on the proposed rule
until April 12, 1999.
Public Hearing. If anyone contacts EPA requesting to speak at a
public hearing by March 4, 1999, a public hearing will be held on March
15, 1999 beginning at 10 a.m., at the EPA Office of Administration
Auditorium, Research Triangle Park, NC. For more information, see
section VII.B of the SUPPLEMENTARY INFORMATION section.
ADDRESSES: Comments. Interested parties may submit written comments (in
duplicate, if possible) to Docket No. A-92-61 at the following address:
Air and Radiation Docket and Information Center (6102), U.S.
Environmental Protection Agency, 401 M Street, SW., Washington, DC
20460. The EPA requests that a separate copy of the comments also be
sent to the contact person listed below. The docket is located at the
above address in Room M-1500, Waterside Mall (ground floor).
A copy of today's document, technical background information, and
other materials relating to this rulemaking are available for review in
the docket. Copies of this information may be obtained by request from
the Air Docket by calling (202) 260-7548. A reasonable fee may be
charged for copying docket materials.
Public Hearing. If anyone contacts the EPA requesting a public
hearing by the required date (see DATES), the public hearing will be
held at the EPA Office of Administration Auditorium, Research Triangle
Park, NC. Persons interested in making oral presentations should notify
Ms. Tanya Medley, Minerals and Inorganic Chemicals Group, Emission
Standards Division (MD-13), U. S. Environmental Protection Agency,
Research Triangle Park, NC 27711, telephone number (919) 541-5422.
FOR FURTHER INFORMATION CONTACT: For information concerning the
proposed regulation, contact Juan Santiago, Minerals and Inorganic
Chemicals Group, U.S. Environmental Protection Agency, Research
Triangle Park, NC 27711, telephone number (919) 541-1084, facsimile
number (919) 541-5600, electronic mail address,
``[email protected].''
SUPPLEMENTARY INFORMATION:
Regulated Entities
Entities potentially regulated by this action are ``secondary
aluminum production facilities'' using post-consumer scrap, aluminum
scrap, ingots, foundry returns, and/or dross as the raw material and
operating one or more of the following affected sources: Scrap
shredders, scrap dryer/delacquering/decoating kilns, chip dryers, group
2 process furnaces (i.e., clean charge furnaces using no reactive
flux), sweat furnaces, dross-only furnaces, rotary dross coolers,
secondary aluminum processing units, new and reconstructed group 1
furnaces (i. e., melting, holding, fluxing, refining or alloying), and
new and reconstructed in-line fluxers. The EPA identified more than 400
facilities which include one or more of these affected sources, 86 of
which are estimated to be major sources. Most establishments are
included in SIC 3341 (Secondary Smelting and Refining of Nonferrous
Metals), although others may fall in SIC 3353 (Aluminum Sheet, Plate,
and Foil), SIC 3354 (Aluminum Extruded Products), and SIC 3355
(Aluminum Rolling and Drawing NEC). Affected sources at facilities that
are major sources of HAPs would be regulated under the proposed
standards. In addition, emissions of dioxins and furans (D/F) from
affected sources at facilities that are area sources of HAPs would also
be regulated.
The proposed standards would not apply to facilities in SIC 336
(Nonferrous Foundries/Casting), such as manufacturers of aluminum die
castings (SIC 3363) that use only clean aluminum and aluminum foundries
(SIC 3365) that process only clean aluminum. Secondary aluminum
production facilities that are collocated with primary aluminum
production are regulated under the proposed standard.
Regulated categories and entities include:
------------------------------------------------------------------------
Category Examples of regulated entities
------------------------------------------------------------------------
Industry............................... Owners or operators of
secondary aluminum production
facilities in SIC 3341, 3353,
3354, 3355, or that are
collocated with primary
aluminum production
facilities, that are major
sources of HAPs, or that emit
dioxins and furans and are
area sources of HAPs.
------------------------------------------------------------------------
This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be regulated by this
action. This table lists the types of entities that the Agency is now
aware could potentially be regulated by this action. Other types of
entities not listed in the table also could be regulated. To determine
whether your facility is regulated by this action, you should carefully
examine the applicability criteria in Sec. 63.1500 of the proposed
rule. If you have questions regarding the applicability of this action
to a particular entity, consult the person listed in the preceding FOR
FURTHER INFORMATION CONTACT section.
Technology Transfer Network
The proposed regulatory text also is available on the Technology
Transfer Network (TTN), one of EPA's electronic bulletin boards. The
TTN provides information and technology exchange in various areas of
air pollution control.
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The service is free, except for the cost of a phone call. Dial (919)
541-5742 for up to a 14,400 BPS modem. The TTN also is accessible
through the Internet at ``TELNET ttnbbs.rtpnc.epa.gov.'' If more
information on the TTN is needed, call the HELP line at (919) 541-5384.
The help desk is staffed from 11 a.m. to 5 p.m.; a voice menu system is
available at other times.
Electronic Access and Filing Addresses
The official record for this rulemaking, as well as the public
version, has been established under Docket No. A-92-61 (including
comments and data submitted electronically). A public version of this
record, including printed, paper versions of electronic comments, which
does not include any information claimed as confidential business
information (CBI), is available for inspection from 8 a.m. to 5:30
p.m., Monday through Friday, excluding legal holidays. The official
rulemaking record is located at the address in ADDRESSES at the
beginning of this document.
Electronic comments can be sent directly to the EPA's Air and
Radiation Docket and Information Center at: ``A-and-R-
D[email protected].'' Electronic comments must be submitted as an
ASCII file avoiding the use of special characters and any form of
encryption. Comments and data will also be accepted on disks in
Wordperfect 5.1 file format or ASCII file format. All comments and data
in electronic form must be identified by the docket number (A-92-61).
Electronic comments may be filed online at many Federal Depository
Libraries.
Outline
The information in this preamble is organized as shown below.
I. Statutory Authority
II. Introduction
A. Background
B. NESHAP for Source Categories
C. Health Effects of Pollutants
D. Secondary Aluminum Industry
III. Summary of Proposed Standards
A. Applicability
B. Emission Limits and Requirements
C. Operating and Monitoring Requirements
IV. Selection of Proposed Standards
A. Selection of Source Category
B. Selection of Emission Sources and Pollutants
C. Selection of Proposed Standards for Existing and New Sources
1. Background
2. Selection of MACT Floor Technology
3. Consideration of Beyond-the-Floor Technologies
4. Selection of Emission Limits
D. Selection of Operating and Monitoring Requirements
1. Operating and Monitoring Requirements and Options for
Affected Sources and Emission Units
2. Operating and Monitoring Requirements and Options for
Affected Sources and Emission Units Equipped with a Fabric Filter
and Subject to PM Limits
3. Other Operating and Monitoring Requirements and Procedures
E. Selection of Performance Test Methods and Requirements
1. Rationale for Performance Test Methods, Procedures and
Surrogates
2. General Requirements
3. Performance Test Requirements and Options for Affected
Sources and Emission Units
4. Performance Test Requirements and Options for Affected
Sources and Emission Units Equipped with a Fabric Filter or Lime-
Injected Fabric Filter
F. Notification, Recordkeeping and Reporting Requirements
V. Summary of Impacts of Proposed Standards
A. Air Quality Impacts
B. Cost Impacts
C. Economic Impacts
D. Non-air Health and Environmental Impacts
E. Energy Impacts
VI. Request for Comments
VII. Administrative Requirements
A. Docket
B. Public Hearing
C. Executive Order 12866
D. Executive Order 13045
E. Enhancing the Intergovernmental Partnership Under Executive
Order 12875
F. Executive Order 13084: Consultation and Coordination with
Indian Tribal Governments
G. Unfunded Mandates Act
H. Regulatory Flexibility Act
I. Paperwork Reduction Act
J. National Technology Transfer and Advancement Act
K. Pollution Prevention Act
L. Clean Air Act
I. Statutory Authority
The statutory authority for this proposal is provided by sections
101, 112, 114, 116, and 301 of the Clean Air Act, as amended (42 U.S.C.
7401, 7412, 7414, 7416, and 7601).
II. Introduction
A. Background
The EPA estimates that about 28,600 Mg/yr (31,500 tpy) of HAPs and
other air pollutants are released from production processes in 86
major-source secondary aluminum production facilities. The HAPs in
these emissions consist of several organic compounds, including
2,3,7,8-TCDD (a compound in the dioxin/furans (D/F) group); inorganic
``acid gas'' compounds such as hydrogen chloride (HCl), hydrogen
fluroride (HF), and chlorine (Cl2); and 11 nonvolatile HAP
metals. NonHAP particulate matter (PM) and volatile organic compounds
(VOCs) are also emitted.
The proposed standard reduces emissions of HAPs and other
pollutants using a combination of emission limits and pollution
prevention/work practice standards based on MACT floor controls.
Depending on the type of affected source, plants affected by the
standards could achieve the proposed requirements by upgrading or
installing a fabric filter or a lime-injected fabric filter (i.e., a
fabric filter to which lime or other alkaline reagent is continuously
injected). Or, plants may be required to add a thermal incinerator
(also known as an afterburner), a thermal incinerator followed by a
lime-injected fabric filter, and/or apply pollution prevention
techniques to limit the type of scrap charged and the type and amount
of fluxing agents used. Raising the control performance of affected
sources with MACT-level standards would reduce emissions of HAPs by 70
percent and other pollutants by about 42 percent from the current
level, with higher reductions achieved at particular sites. Emissions
of HCl would be decreased by about 74 percent.
The nationwide total capital and annualized costs of control
equipment are estimated at $148 million and $68 million/yr,
respectively. An additional $5.1 million per year is estimated for
monitoring/implementation costs for the first 3 years following
promulgation. The economic impacts of the proposed regulation are
expected to be minimal with price increases and production decreases of
less than one percent. The regulation is not expected to result in a
significant economic impact for a substantial number of small entities.
Only one of the 33 small entities is anticipated to experience
significantly adverse economic impacts as a result of this regulation.
The proposed NESHAP was developed by EPA with input from industry
representatives and associated groups including the Aluminum
Association and STAPPA/ALAPCO (State and Territorial Air Pollution
Program Administrators Association/Association of Local Air Pollution
Control Officials). The rule development process included a cooperative
effort with the industry in identifying data needs; collecting
additional data; planning and conducting emission tests; and meeting
with these representatives to share technical information and resolve
issues.
B. NESHAP for Source Categories
Section 112 of the Act requires that EPA promulgate regulations for
the
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control of HAP emissions from both new and existing major sources. The
regulations must reflect the maximum degree of reduction in emissions
of HAPs that is achievable taking into consideration the cost of
achieving the emission reduction, any nonair quality health and
environmental impacts, and energy requirements. This level of control
is commonly referred to as MACT.
The control of HAPs is achieved through the promulgation of
technology-based emission standards under sections 112(d) and 112(f)
and work practice standards under 112(h) for categories of sources that
emit HAPs. Emission reductions may be accomplished through the
application of measures, processes, methods, systems, or techniques
including, but not limited to: (1) Reducing the volume of, or
eliminating emissions of, such pollutants through process changes,
substitution of materials, or other modifications; (2) enclosing
systems or processes to eliminate emissions; (3) collecting, capturing,
or treating such pollutants when released from a process, stack,
storage or fugitive emissions point; (4) design, equipment, work
practice, or operational standards (including requirements for operator
training or certification) as provided in section (h); or (5) a
combination of the above. (See section 112(d)(2).)
C. Health Effects of Pollutants
The Clean Air Act was created in part to protect and enhance the
quality of the Nation's air resources so as to promote the public
health and welfare and the productive capacity of its population. (See
section 101(b)(1).) Section 112(b) of the Act contains a list of HAPs
believed to cause adverse health or environmental effects. Section
112(d) of the Act requires that emission standards be promulgated for
all categories and subcategories of major sources of these HAPs and for
many smaller ``area'' sources listed for regulation under section
112(c) in accordance with the schedules listed under section 112(c).
Major sources are defined as those that emit or have the potential to
emit at least 10 tons per year (tpy) of any single HAP or 25 tpy of any
combination of HAPs.
In the 1990 Amendments to the Clean Air Act, Congress specified
that each standard for major sources must require the maximum reduction
in emissions of HAPs that EPA determines is achievable considering
cost, health and environmental impacts, and energy impacts. In essence,
these MACT standards would ensure that all major sources of air toxic
emissions achieve the level of control already being achieved by the
better controlled and lower emitting sources in each category. This
approach provides assurance to citizens that each major source of toxic
air pollution will be required to effectively control its emissions. At
the same time, this approach provides a ``level economic playing
field,'' ensuring that facilities that employ cleaner processes and
good emissions control are not disadvantaged relative to competitors
with poorer controls.
Emission data, collected during development of this NESHAP, show
that pollutants listed in section 112(b)(1) are emitted by secondary
aluminum production processes and include organic HAPs (e.g., D/F,
benzene, styrene, xylene, acrylonitrile, methylene chloride,
naphthalene, and formaldehyde); inorganic HAPs (HCl, HF, and
Cl2), and HAP metals (antimony, arsenic, lead, manganese,
beryllium, cadmium, chromium, cobalt, mercury, nickel, and selenium).
Emissions of these pollutants would be decreased by implementation of
the proposed emission limits. Some of these pollutants are either known
or probable human carcinogens when inhaled, and can cause reversible
and irreversible toxic effects other than cancer following sufficient
exposure. These effects include respiratory and skin irritation,
effects upon the eye, various systemic effects including effects upon
the liver, kidney, heart and circulatory system, neurotoxic effects,
and in extreme cases, death. Following is a summary of the potential
health and environmental effects associated with exposures, at some
level, to emitted pollutants that would be reduced by the standard.
Almost all metals appearing on the section 112(b) list of HAPs are
emitted from affected sources in secondary aluminum plants. These
metals can cause a range of effects including irritation of the
respiratory tract; gastrointestinal effects; nervous system disorders
(including loss of coordination and mental retardation); skin
irritation; and reproductive and developmental disorders. Additionally,
these metals accumulate in the environment and several of them
accumulate in the human body, and may cause adverse health effects
after exposure has ceased. Cadmium, for example, is a cumulative
pollutant that can cause kidney effects after the cessation of
exposure. Similarly, the onset of effects from beryllium exposure may
be delayed by months to years. Many of the metal compounds also are
known (arsenic, chromium (VI)) or probable (cadmium, nickel carbonyl,
lead, and beryllium) human carcinogens.
Each HAP organic compound has a range of potential health effects
associated with exposures above toxic thresholds. Effects generally
associated with short-term inhalation exposure to these pollutants
include irritation of the eyes, skin, and respiratory tract; central
nervous system effects (e.g., drowsiness, dizziness, headaches,
depression, nausea, abnormal electrocardiograms); and reproductive and
developmental effects. Health effects associated with long-term
inhalation exposure in humans to the organic compounds which will
potentially be decreased by the proposed standard may include mild
symptoms such as nausea, headache, weakness, insomnia, gastrointestinal
effects, and burning eyes; disorders of the blood; toxicity to the
immune system; reproductive disorders in women (e.g., menstrual
irregularity or increased risk of spontaneous abortion); developmental
effects; and injury to the liver and kidneys. In addition to non-cancer
effects, some of the organic HAPs that would be controlled under this
proposed NESHAP are either known or probable human carcinogens.
Hydrogen chloride is highly corrosive to the eyes, skin, and mucous
membranes. Short-term inhalation of HCl by humans may cause coughing,
hoarseness, inflammation and ulceration of the respiratory tract, as
well as chest pain and pulmonary edema. Long-term occupational exposure
of humans to HCl has been reported to cause inflammation of the
stomach, skin, and lungs, and photosensitization.
Acute exposure to hydrogen fluoride will result in irritation,
burns, ulcerous lesions, and necrosis of the eyes, skin, and mucous
membranes. Total destruction of the eyes is possible. Other effects
include nausea, vomiting, diarrhea, pneumonitis (inflammation of the
lungs), and circulatory collapse. Ingestion of an estimated 1.5 grams
produced sudden death without gross pathological damage. Repeated
ingestion of small amounts resulted in moderately advanced hardening of
the bones. Contact of skin with anhydrous liquid produces severe burns.
Inhalation of anhydrous hydrogen fluoride or hydrogen fluoride mist or
vapors can cause severe respiratory tract irritation that may be fatal.
The irritating properties of Cl2 make this HAP a serious
acute respiratory hazard, as well as a skin, eye, and throat irritant.
Prolonged exposure to low concentrations can cause respiratory
problems, tooth corrosion, inflammation
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of the mucous membranes, and susceptibility to tuberculosis. Prolonged
exposure at moderate concentrations can cause decreased lung capacity.
Several of the HAP whose emissions will be reduced by this rule
have been found to cause serious developmental effects in animals or
humans. For example, children are more sensitive than adults to the
neurotoxic effects of lead, suffering neurobehavioral deficits such as
loss of IQ at relatively low exposures. Chlorinated dibenzodioxins and
furans are now understood to be potent developmental toxins, disrupting
a wide variety of developmental events in embryos of numerous
vertebrate species at exposures that are not toxic to adults. Although
this rule is based on emission reduction technology rather than risk
reduction per se, EPA anticipates that reductions in emissions of
developmentally-toxic HAP will especially benefit children.
In addition to the HAPs, the proposed NESHAP also would reduce some
of the pollutants whose emissions are controlled under the National
Ambient Air Quality Standards (NAAQS) program. These pollutants include
particulate matter (PM), volatile organic compounds (VOC--precursors to
tropospheric ozone formation), and lead (also a HAP metal). The health
effects of lead, PM, and VOC are described in EPA's Criteria Documents,
which support the NAAQS. Briefly, PM emissions have been associated
with aggravation of existing respiratory and cardiovascular disease and
increased risk of premature death. At elevated levels, ozone has been
shown in human laboratory and community studies to be responsible for
the reduction of lung function, respiratory symptoms (e.g., cough,
chest pain, throat and nose irritation), increased hospital admissions
for respiratory causes, and increased lung inflammation. Animal studies
have shown increased susceptibility to respiratory infection and lung
structure changes. Exposure to ozone also has been linked to harmful
effects on agricultural crops and forests. Depending on the degree of
exposure, lead can cause subtle effects on behavior and cognition
(particularly in children), increased blood pressure, reproductive
effects, seizures, and even death.
The EPA recognizes that the degree of adverse effects to health can
range from mild to severe. The extent and degree to which the health
effects may be experienced is dependent upon: (1) The ambient
concentrations observed in the area, (e.g., as influenced by emission
rates, meteorological conditions, and terrain), (2) the frequency of
and duration of exposures, (3) characteristics of exposed individuals
(e.g., genetics, age, pre-existing health conditions, and lifestyle)
which vary significantly with the population, and (4) pollutant-
specific characteristics (e.g., toxicity, half-life in the environment,
bioaccumulation, and persistence).
D. Secondary Aluminum Industry
At least 400 facilities which include one or more secondary
aluminum affected sources currently operate in 36 States. Based on
industry responses to EPA's information collection request (ICR) and
responses to a voluntary supplemental industry/EPA survey, the 86
facilities identified as major sources operate at least 69 scrap
shredders, 5 chip dryers, 44 scrap dryers/decoating kilns/delacquering
kilns, 12 sweat furnaces, 15 dross-only furnaces, 86 secondary aluminum
processing units, and 26 rotary dross coolers.
III. Summary of Proposed Standards
A. Applicability
The proposed NESHAP applies to each new, existing or reconstructed
scrap shredder, chip dryer, scrap dryer/ delacquering kiln/decoating
kiln, group 2 furnace, sweat furnace, dross-only furnace, and rotary
dross cooler; each secondary aluminum processing unit (composed of all
existing group 1 furnace emission units and all existing in-line fluxer
emission units); and each new or reconstructed group 1 furnace and in-
line fluxer located at a secondary aluminum production plant that is a
major source of HAP. The proposed NESHAP also applies to each new,
existing or reconstructed chip dryer, scrap dryer/delacquering kiln/
decoating kiln, and sweat furnace; each secondary aluminum processing
unit and each new or reconstructed group 1 furnace and in-line fluxer
located at a secondary aluminum production plant that is an area source
of HAP. The proposed NESHAP also applies to these secondary aluminum
production affected sources if they are collocated at a primary
aluminum production facility that is a major source of HAP.
As discussed further in section IV of this document, the EPA
categorized process furnaces into two classes. A group 1 furnace
includes any furnace that processes aluminum scrap containing paint,
lubricants, coatings, or other foreign materials or within which
reactive fluxing is performed, regardless of the type of scrap charged.
Reactive fluxing means the use of any gas, liquid, or solid flux
(including chlorine gas or magnesium chloride) that results in a HAP
emission.
Group 2 (``clean charge'') furnaces process only molten aluminum,
T-bar, sow, ingot, alloying elements, noncoated runaround scrap,
uncoated aluminum chips dried at 343 deg.C (650 deg.F) or higher, and
aluminum scrap dried, decoated, or delacquered at a temperature at
482 deg.C (900 deg.F) or higher. A group 2 furnace performs no fluxing
or performs fluxing using only nonreactive, nonHAP-containing/nonHAP-
generating gases such as argon and nitrogen.
B. Emission Limits and Requirements
The proposed NESHAP for secondary aluminum production applies to
major sources. In addition, affected sources located at area sources of
HAPs, which emit D/F are regulated for emissions of D/F. The proposed
limits are summarized in Table 1.
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PM emission limits would apply to new, reconstructed and existing
scrap shredders, scrap dryer/delacquering/decoating kilns, dross-only
furnaces, rotary dross coolers; secondary aluminum processing units;
and new and reconstructed in-line fluxers, and group 1 furnaces at
secondary aluminum production facilities that are major sources.
Controlling PM emissions would also control emissions of HAP metals. A
surrogate approach to emission limits is used to allow easier and less
expensive measurement and monitoring requirements.
The proposed rule limits total hydrocarbon emissions (THC) from new
and existing chip dryers and from new and existing scrap dryer/
delacquering/decoating kilns at secondary aluminum production
facilities that are major sources. THC represents emissions of HAP
organics. HCl emission limits would apply to new, reconstructed and
existing scrap dryer/delacquering/decoating kilns; new and
reconstructed in-line fluxers and Group 1 furnaces; and secondary
aluminum processing units at secondary aluminum production facilities
that are major sources. HCl serves as a surrogate measure of HAP
inorganics including hydrogen fluoride (HF) and chlorine
(Cl2) emissions. The proposed rule limits emissions of D/F
from new, reconstructed and existing chip dryers, scrap dryer/
delacquering/decoating kilns and sweat furnaces; new and reconstructed
group 1 furnaces; and secondary aluminum processing units at secondary
aluminum production facilities that are major or area sources. No
surrogate is used for D/F emissions. A detailed explanation of the
proposed limits and the rationale for their selection is given in
section IV.C. of this document.
C. Operating and Monitoring Requirements
The proposed NESHAP includes operating and monitoring requirements
for each affected source and emission unit within a secondary aluminum
processing unit to ensure continuous compliance with the emissions
standards. The proposed standard would incorporate all requirements of
the NESHAP general provisions (40 CFR part 63, subpart A). The proposed
operating and monitoring requirements are summarized in Table 2. A
detailed explanation of the monitoring requirements and the rationale
for their selection is given in section IV.D. of this document. \1/
2\Federal Register
Table 2.--Summary of Proposed Operating and Monitoring Requirements for Affected Sources and Emission Units
----------------------------------------------------------------------------------------------------------------
Monitor type/
Affected source/emission unit operation/process Operating requirements Monitoring requirements
----------------------------------------------------------------------------------------------------------------
All affected sources and emission Labeling............. Identification, emission Check monthly to confirm
units. limits and means of that labels are intact
compliance posted on all and legible.
affected sources and
emission units.
All affected sources and emission Emission capture and Design and install in Annual inspection of all
units with add-on control device. collection system. accordance with emission capture,
Industrial Ventilation: A collection, and
Handbook of Recommended transport systems to
Practice; operate in ensure that systems
accordance with O, M & M continue to operate in
plan.b accordance with ACGIH
standards.
All affected sources and emission Charge/feed weight... Operate a device or use an Record the weight of each
units subject to production based equivalent procedure to charge; weight
[lb/ton of feed] emission limits record the weight of each measurement device or
a. charge; operate in other procedure accuracy
accordance with O, M, & M of 1
plan. percent; calibration
every 3 months.
Scrap shredder with fabric filter. Bag leak detector.... Initiate corrective action Install and operate in
within 1 hour of alarm accordance with ``Fabric
and complete in Filter Bag Leak
accordance with O, M, & M Detection Guidance'' and
plan; b operate such that record voltage output
alarm does not sound more from bag leak detector.
than 5% of operating time
in 6-month period.
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or
COM.................. Initiate corrective action Design and install in
within 1-hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with O, M, & M plan; b. calculate and record 6-
minute block averages.
or
VE................... Initiate corrective action Conduct and record
within 1 hour of any results of 30 minute
observed VE and complete daily test in accordance
in accordance with the O, with Method 9.
M, & M plan.b
Chip Dryer with afterburner....... Afterburner operating Maintain average Continuous measurement
temperature. temperature, averaged device to meet EPA
over each 3-hour period, specifications;
at or above the average calculate and record
operating temperature average temperature for
during the performance each 15-minute block;
test. determine 3-hour block
averages; calibrate
every 3 months.
Afterburner operation Operate in accordance with Conduct annual inspection
O, M, and M plan.b of afterburner internal
parts to maintain good
working order.
Feed material........ Operate using only Record identity of charge
unpainted aluminum chips. daily; certify charge
materials every 6
months.
Scrap dryer/delacquering/decoating Afterburner operating Maintain average Continuous measurement
kiln with afterburner and lime temperature. temperature, averaged device to meet EPA
injected fabric filter. over each 3-hour period, specifications; record
at or above the average temperatures in 15-
operating temperature minute block averages;
during the performance calculate 3-hour block
test. averages; calibration
every 3 months.
Afterburner operation Operate in accordance with Annual inspection of
O, M, & M plan.b afterburner internal
parts; complete repairs
in 10 days.
Bag leak detector.... Initiate corrective action Install and operate in
within 1 hour of alarm accordance with ``Fabric
and complete in Filter Bag Leak
accordance with the O, M, Detection Guidance'' and
& M plan; b operate such record voltage output
that alarm does not sound from bag leak detector.
more than 5% of operating
time in 6-month period.
or
COM.................. Initiate corrective action Design and install in
within 1 hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with the O, M, & M plan.b calculate and record 6-
minute block averages.
Lime injection rate Maintain free-flowing lime Inspect each feed hopper
and schedule. in the feed hopper or or silo every 8 hours to
silo at all times. verify that lime is free-
flowing; record results
of each inspection. If
blockage occurs, inspect
every 4 hours for 3
days; return to 8-hour
inspections if
corrective action
results in no further
blockage during 3-day
period.
Maintain average lime Weight measurement device
injection rate (lb/hr) at accuracy of 1 percent;
during the successful calibration every 3
compliance test and months; record weight of
adhere to the same lime lime injected for each
injection schedule used 15-minute block period
during the performance and determine 3-hour
test for each 3-hour block averages or;
period or
Maintain average lime Weight measurement device
injection rate (lb/ton of accuracy of 1 percent;
rate used during the calibrate every 3
performance test and months; record weight of
adhere to the same lime lime added or injected
injection schedule used for each 15-minute block
during the performance period and determine
test for each operating lime injection rate (lb/
cycle or time period used ton of feed) for each
in performance test or operating cycle or time
period used in
performance test or;
Maintain feeder setting at Record feeder setting
level established at daily.
performance test.
[[Page 6955]]
Fabric filter inlet Maintain average fabric Continuous measurement
temperature. filter inlet temperature device to meet EPA
at or below the average specifications; record
temperature during the temperatures in 15
successful compliance minute block averages;
test +14 deg.C (25 calculate 3 hour block
deg.F) for each three averages; calibration
hour period. every three months.
Sweat furnace with afterburner.... Afterburner operating Maintain average Continuous measurement
temperature. temperature, averaged device to meet EPA
over each 3-hour period, specifications; record
at or above the average temperatures in 15-
operating temperature minute block averages;
during the performance calculate 3-hour block
test. averages; calibration
every 3 months.
Afterburner operation Operate in accordance with Annual inspection of
O, M, & M plan.b afterburner internal
parts; complete repairs
in 10 days.
Dross-only furnace with fabric Bag leak detector.... Initiate corrective action Installation and
filter. within 1 hour of alarm operation requirements
and complete in in accordance with
accordance with the O, M, ``Fabric Filter Bag Leak
& M plan; b operate such Detection Guidance'' and
that alarm does not sound record voltage output
more than 5% of operating from bag leak detector.
time in 6-month period.
or
COM.................. Initiate corrective action Design and install in
within 1 hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with the O, M, & M plan.b calculate and record 6-
minute block averages.
Feed/charge material. Operate using only dross Record identity of each
as the feed material. charge; certify charge
materials every 6
months.
Rotary dross cooler with fabric Bag leak detector.... Initiate corrective action Install and operate in
filter. within 1 hour of alarm accordance with ``Fabric
and complete in Filter Bag Leak
accordance with the O, M, Detection Guidance'' and
& M plan; b operate such record voltage output
that alarm does not sound from bag leak detector.
more than 5% of operating
time in 6-month period.
or
COM.................. Initiate corrective action Design and install in
within 1 hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with the O, M, & M plan.b calculate and record 6-
minute block averages.
In-line fluxer with lime injected Bag leak detector.... Initiate corrective action Install and operate in
fabric filter (including those within 1 hour of alarm accordance with ``Fabric
that are part of a secondary and complete in Filter Bag Leak
aluminum processing unit). accordance with the O, M, Detection Guidance'' and
& M plan; b operate such record voltage output
that alarm does not sound from bag leak detector.
more than 5% of operating
time in 6-month period.
or
COM.................. Initiate corrective action Design and install in
within 1 hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with the O, M, & M plan.b calculate and record 6-
minute block averages.
Reactive flux Maintain the reactive flux Weight measurement device
injection rate and injection rate at or accuracy of 1 percent;
injection rate used calibration every 3
during the performance months; record weight
test and adhere to the and type of reactive
same flux injection flux added or injected
schedule used during the for each 15-minute block
test. period.
Lime injection rate Maintain free-flowing lime Inspect each feed hopper
and schedule. in the feed hopper or or silo every 8 hours to
silo at all times. verify that lime is free-
flowing; record results
of each inspection. If
blockage occurs, inspect
every 4 hours for 3
days; return to 8-hour
inspections if
corrective action
results in no further
blockage during 3-day
period.
[[Page 6956]]
In-line fluxer with lime Maintain average lime Weight measurement device
injected fabric filter (including injection rate (lb/hr) at accuracy of 1 percent;
secondary aluminum processing during the performance calibrate every 3
unit) cont'd test and adhere to the months; record weight of
same lime injection lime injected for each
schedule used during the 15-minute block period
test for each 3-hour and determine 3 hour
period or. block averages or;
Maintain average lime Weight measurement device
injection rate (1b/ton of accuracy of 1 percent;
rate used during the calibrate every 3
performance test and months; record weight of
adhere to the same lime lime injected for each
injection schedule used 15-minute block period
during the test for each and determine lime
operating cycle or time injection rate (lb/ton
period used in of feed) for each
performance test or. operating cycle or time
period used in
performance test or;
Maintain feeder setting at Record feeder setting
level established at daily.
performance test.
Fabric filter inlet Maintain average fabric Continuous measurement
temperature. filter inlet temperature device to meet EPA
at or below the average specifications; record
temperature during the temperatures in 15-
performance test +14 minute block averages;
deg.C (25 deg.F) for each calculate 3-hour block
3-hour period. averages; calibrate
every 3 months.
Clean (group 2) furnace........... Charge materials..... Use only clean charge..... Record identity of all
charge materials;
certify every 6 months.
Flux materials....... Use no reactive flux...... Record identity of all
flux materials; certify
every 6 months that no
reactive flux was used.
Group 1 furnace with lime injected Bag leak detector.... Initiate corrective action Install and operate in
fabric filter (including those within 1 hour of alarm accordance with ``Fabric
that are part of a secondary and complete in Filter Bag Leak
aluminum processing unit). accordance with the O, M, Detection Guidance'' and
& M plan; b operate such record voltage output
that alarm does not sound from bag leak detector.
more than 5% of operating
time in 6-month period.
or
COM.................. Initiate corrective action Design and install in
within 1 hour of a 6- accordance with PS-1;
minute average opacity collect data in
reading of 5% or more and accordance with subpart
complete in accordance A of 40 CFR 63;
with the O, M, & M plan.b calculate and record 6-
minute block averages.
Lime injection rate Maintain free-flowing lime Inspect each feed hopper
and schedule. in the feed hopper or or silo every 8 hours to
silo at all times. verify that lime is free-
flowing; record results
of each inspection. If
blockage occurs, inspect
every 4 hours for 3
days; return to 8-hour
inspections if
corrective action
results in no further
blockage during 3-day
period.
Maintain average lime Weight measurement device
injection rate (lb/hr) at accuracy of 1 percent;
during the performance calibrate every 3
test and adhere to the months; record weight of
same lime injection lime injected for each
schedule used during the 15-minute block period
test for each 3-hour and determine 3-hour
period or; block averages.
Maintain average lime Weight measurement device
injection rate (lb/ton of accuracy of 1 percent;
rate used during the calibrate every 3
performance test and months; record weight of
adhere to the same lime lime injected for each
injection schedule used 15-minute block period
during the test for each and determine lime
operating cycle or time injection rate (lb/ton
period used in of feed) for each
performance test or; operating cycle or time
period used in
performance test or;
Maintain feeder setting at Record feeder setting
level established at daily.
performance test.
Reactive flux Maintain the reactive flux Weight measurement device
injection rate and injection rate at or accuracy of 1 percent;
injection rate used calibrate every 3
during the performance months; record weight
test. and type of reactive
flux added or injected
for each 15-minute block
period.
[[Page 6957]]
Fabric filter inlet Maintain average fabric Continuous measurement
temperature. filter inlet temperature device to meet EPA
at or below the average specifications; record
temperature during the temperature in 15-minute
performance test +14 block averages;
deg.C (25 deg.F) for calculate 3-hour block
each 3 hour period. averages; calibrate
every 3 months.
Maintain molten Operate side-well furnaces Maintain aluminum level
aluminum level. such that the level of operating log; certify
molten metal is above the every 6 months.
top of the passage
between side well and
hearth during reactive
flux injection.
Fluxing in sidewell Add reactive flux only to Maintain flux addition
furnace hearth. the sidewell of the operating log; certify
furnace unless the hearth every 6 months.
is also controlled.
Group 1 furnace without add-on Reactive flux Maintain the reactive flux Weight measurement device
controls (including those that injection rate and injection rate at or accuracy of 1 percent;
processing unit). injection rate used calibrate every 3
during the performance months; record weight
test and adhere to same and type of reactive
flux injection schedule flux added or injected
used in performance test. for each 15-minute block
period.
Feed material (melter/ .......................... Record identity of each
holder). charge; certify charge
materials every 6
months.
Site-specific Operate furnace within the Demonstration of site-
monitoring plan range of charge specific monitoring plan
(approved by materials, contaminant to provide data and show
permitting agency). levels, and parameter correlation of emissions
values established in the across the range of
site-specific monitoring charge and flux
plan.c materials and furnace
operating parameters.
----------------------------------------------------------------------------------------------------------------
a Chip dryers, scrap dryers/delacquering kilns/decoating kilns, dross-only furnaces, in-line fluxers (including
those that are part of a secondary aluminum processing unit) and group 1 furnaces including melter holders
(including those that are part of a secondary aluminum processing unit).
b O, M, & M plan--Operation, maintenance, and monitoring plan.
c Site-specific monitoring plan--Owner/operators of group 1 furnaces without control devices must develop a site-
specific monitoring plan that identifies process or feed parameter-based operating requirements. This plan
would be part of the O, M, & M plan. This plan and the testing to demonstrate adequacy of the monitoring plan
and correlation of parameters over the range of charge materials and fluxing practices must be developed in
coordination with and be approved by the permitting authority.
IV. Selection of Proposed Standards
A. Selection of Source Category
Section 112(c) of the Act directs the EPA to list each category of
major and area sources, as appropriate, emitting one or more of the
HAPs listed in section 112(b) of the Act. The EPA published an initial
list of source categories on July 16, 1992 (57 FR 31576), and may amend
the list at any time. ``Secondary Aluminum Production'' is one of the
174 categories of sources included on the revised list of source
categories (63 FR 7155, February 12, 1998). This list includes major
and area sources of HAPs for which the EPA intends to issue regulations
between November 1992 and November 2000. The category as defined in the
EPA report, ``Documentation for Developing the Initial Source Category
List'' (docket item II-A-6) for the listing includes any facility
engaged in the cleaning, melting, refining, alloying, and pouring of
aluminum recovered from scrap, foundry returns, and dross.
The listing of the secondary aluminum production major source
category was based on the Administrator's determination that some
secondary aluminum production facilities would be major sources of
HAPs. These facilities are known to emit HAPs, including PM metal HAP
(including antimony, arsenic, beryllium, cadmium, chromium, cobalt,
lead, manganese, mercury, and nickel), gaseous organic HAPs (including
dioxins, furans, polycyclic organic matter, benzene and formaldehyde)
and gaseous inorganic HAPs (including hydrogen chloride, hydrogen
fluoride, and chlorine).
A major source must have the potential to emit 9.1 Mg/yr (10 tpy)
or more of a single HAP or 23 Mg/yr (25 tpy) or more of a combination
of HAPs. The EPA has estimated that there are approximately 86 major
source facilities that practice one or more secondary aluminum
production processes.
Section 112(c)(6) of the Act states that by November 15, 2000, EPA
must list and promulgate section 112(d)(2) or (d)(4) standards (i.e.,
standards reflecting MACT) for categories (and subcategories) of
sources emitting seven specific pollutants, including 2,3,7,8
tetrachlorodibenzofurans and 2,3,7,8 tetrachlorodibenzo-p-dioxin which
are emitted by secondary aluminum production affected sources. The EPA
must assure that source categories accounting for not less than 90
percent of the aggregated emissions of the enumerated pollutant are
subject to MACT standards. Congress (docket item II-I-13, p. 155 to 156
(cement) singled out the HAPs enumerated in section 112(c)(6) as being
of ``specific concern'' not just because of their toxicity but because
of their propensity to cause substantial harm to human health and the
environment via indirect exposure pathways (i.e., from the air through
other media, such as water, soil, food uptake, etc.). Furthermore,
these pollutants have exhibited special potential to bioaccumulate,
causing pervasive environmental harm in biota (and, ultimately, human
health risks).
The EPA estimates that secondary aluminum production facilities
emit in aggregate approximately 0.4 lb per year of D/F (from June 20,
1997; 62 FR 33635), or 3.5 percent (from April 10, 1998; 63 FR 17849),
of the total national anthropogenic emissions of D/F per year
[[Page 6958]]
(docket item II-J-2, docket item II-J-4). To assure that this pollutant
is subject to MACT, EPA has added the secondary aluminum production
area source category to the list of source categories and subcategories
listed pursuant to section 112(c)(6). (See 63 FR 17838, 17849; April
10, 1998.) The EPA has done so because area and major source secondary
aluminum D/F emitting processes emit this HAP at about equal rates per
ton of feed, because the D/F emitted by area sources are equally toxic
per amount of emissions as that emitted by major sources (i.e., the
distribution of dioxin and furan isomers is the same for both area and
major sources), and because this is a particularly toxic class of HAP.
In addition, EPA's strategy for assuring 90 percent of these pollutants
are addressed includes control of these pollutants from secondary
aluminum production facility area sources through the MACT process.
(See 62 FR 33635, 33636; June 20, 1997.)
The EPA notes, however, as it did in the April 10th document, that
although the section 112(c)(6) listing process makes sources subject to
standards under subsection (d)(2) or (d)(4), the language of section
112(c)(6) does not specify either a particular degree of emissions
control or a reduction in emissions of these specific pollutants to be
achieved by such regulations. Rather, the specific control requirements
will result from determining the appropriate level of control under
MACT (section 112(d)(2), or section 112(d)(4)), and this interpretation
will be made during the section 112(d) rulemakings affecting the
particular source category, not as part of the section 112(c)(6)
listing process. (See 63 FR 17841; April 10, 1998.)
As noted above, EPA is interpreting section 112(c)(6) to require
the EPA to establish standards under section 112(d)(2) or 112(d)(4) for
all sources listed pursuant to section 112(c)(6), whether such sources
are major or area sources. This interpretation reflects the express
language of section 112(c)(6) that sources * * * of each such pollutant
are subject to standards under subsection (d)(2) or (d)(4) and is in
accord with the function of section 112(c)(6):
* * * to assure that sources emitting significant amounts of the
most dangerous HAPs are subject to the rigorous MACT standard-setting
process.
(See S. Rep. No. 228, 101st Cong. 1st Sess., pp. 155, 166.)
In addition, the EPA is interpreting section 112(c)(6) to require
that, for sources listed under section 112(c)(6), MACT (or section
112(d)(4)) controls apply only to the section 112(c)(6) HAPs emitted by
the source. Thus, in this proposed rule, secondary aluminum production
area sources would be subject only to the D/F emission limitations of
the MACT standards. (Since the language of section 112(c)(6) is
ambiguous as to whether the entire source must comply with MACT, or
just for the HAPs enumerated in section 112(c)(6), (see 61 FR 17365, n.
12), either interpretation is legally permissible.) Applying the
provision to the entire source could result in applying MACT to all
HAPs emitted by area sources under circumstances where control would
not otherwise be warranted. The EPA specifically requests comments and
data regarding the decision to include area sources of D/F in this
proposed rule. The Agency seeks information and data regarding the
level of emissions from area sources, the degree to which controls are
in place, and the burden that would be imposed on affected sources.
B. Selection of Emission Sources and Pollutants
The secondary aluminum production source category consists of the
following operations:
(1) Preprocessing of scrap aluminum, including size reduction and
removal of oils, coatings, and other contaminants;
(2) Furnace operations including melting, in-furnace refining,
fluxing, and tapping;
(3) Additional refining, by means of in-line fluxing; and
(4) Cooling of dross.
The following sections include descriptions of the affected sources
in the secondary aluminum production source category, the origin of HAP
emissions from these affected sources, and factors affecting the
emissions. The affected sources for which MACT standards are being
proposed include new, reconstructed and existing scrap shredders, chip
dryers, scrap dryers/delacquering/decoating kilns, group 2 furnaces,
sweat furnaces and dross coolers; secondary aluminum processing units
(composed of all existing group 1 furnace emission units and all
existing in-line fluxer emission units); and new and reconstructed
group 1 furnaces and in-line fluxers. Each of these affected sources
emits one or more of the HAPs listed in section 112 of the Act.
Scrap aluminum is often preprocessed prior to melting.
Preprocessing steps may include shredding to reduce the size of
aluminum scrap; drying of oily scrap such as machine turnings and
borings; and/or heating in a scrap dryer, delacquering kiln or
decoating kiln to remove coatings or other contaminants that may be
present on the scrap. Heating of high iron content scrap in a sweat
furnace to reclaim the aluminum content is also a preprocessing
operation.
Crushing, shredding, and grinding operations are used to reduce the
size of scrap aluminum. Emissions of PM and HAP metals are generated as
dust from coatings and other contaminants contained in the scrap
aluminum. A typical shredder with a capacity of 90,900 Mg/yr (100,000
tpy), is estimated to produce 190 Mg/yr (212 tpy) of PM, before
controls (See docket item II-B-16, impacts memo). PM emitted from
shredders contains HAP metals.
A chip dryer is used to evaporate oil and/or moisture from uncoated
aluminum chips and borings. Chip dryers typically operate at
temperatures ranging between 150 deg.C to 400 deg.C (300 deg.F to
750 deg.F). An uncontrolled chip dryer with a typical capacity of
36,400 Mg/yr (40,000 tons/yr), is estimated to emit 2.4 g TEQ/yr (.0053
lb/yr) of D/F, and 385 Mg/yr (424 tpy) of THC (of which some fraction
is organic HAP) (See docket item II-B-16, impacts memo).
Painted and/or coated materials are processed in a scrap dryer/
delacquering kiln/decoating kiln to remove coatings and other
contaminants that may be present in the scrap prior to melting.
Coatings, oils, grease, and lubricants represent up to 20 percent of
the total weight of these materials. Organic HAPs, D/F, and inorganic
HAPs including particulate metal HAP are emitted during the drying/
delacquering/decoating process.
Used beverage containers (UBC) comprise a major portion of the
recycled aluminum scrap used as feedstock by the industry. In scrap
drying/delacquering/decoating operations, UBC and other post-consumer,
coated products (e.g., aluminum siding) are heated to an exit
temperature of up to 540 deg.C (1,000 deg.F) to volatilize and remove
various organic contaminants such as paints, oils, lacquers, rubber,
and plastic laminates prior to melting. An uncontrolled scrap dryer/
delacquering kiln/decoating kiln with a typical capacity of 45,500 Mg/
yr (50,000 tpy) is estimated to emit 43.3 Mg/yr (47.7 tpy) PM (of which
some fraction is particulate metal HAP), 76.0 Mg/yr (83.6 tpy) HCl, 68
Mg/yr (75 tpy) THC (of which some fraction is organic HAP), and 3.5 g
TEQ/yr (0.0077 lb TEQ/yr) of D/F (See docket item II-B-16, impacts
memo).
A sweat furnace is typically used to reclaim (or ``sweat'') the
aluminum from scrap with high levels of iron. These furnaces operate in
batch mode at a
[[Page 6959]]
temperature that is high enough to melt the aluminum but not high
enough to melt the iron. The aluminum melts and flows out of the
furnace while the iron remains in the furnace in solid form. The molten
aluminum can be cast into sows, ingots, or T-bars that are used as
feedstock for aluminum melting and refining furnaces. Alternately,
molten aluminum can be fed directly to a melting or refining furnace.
An uncontrolled sweat furnace, with a typical capacity of 4,500 Mg/yr
(5,000 tpy) is estimated to emit 0.071 g TEQ/yr (0.00016 lb TEQ/yr) of
D/F (See docket item II-B-16, impacts memo).
Process (i. e. melting, holding or refining) furnaces are
refractory-lined metal vessels heated by an oil or gas burner to
achieve a metal temperature of about 760 deg.C (1,400 deg.F). The
melting process begins with the charging of scrap into the furnace. A
gaseous (typically, chlorine) or salt flux may be added to remove
impurities and reduce aluminum oxidation. Once molten, the chemistry of
the bath is adjusted by adding selected scrap or alloying agents, such
as silicon. Salt and other fluxes contain chloride and fluoride
compounds that may be released when introduced to the bath. HCl may
also be released when chlorine-containing contaminants (such as
polyvinyl chloride coatings) present in some types of scrap are
introduced to the bath. Argon and nitrogen fluxes are not reactive and
do not produce HAPs. In a sidewell melting furnace, fluxing is
performed in the sidewell and fluxing emissions from the sidewell are
controlled. In this type of furnace, fluxing is not typically done in
the hearth and hearth emissions (which include products of combustion
from the oil and gas fired furnaces) are typically uncontrolled.
Process furnaces may process contaminated scrap which can result in
HAP emissions. In addition, fluxing agents may contain HAPs, some
fraction of which is emitted from the furnace. Process furnaces are
large sources of HAP emissions in the secondary aluminum industry. An
uncontrolled melting furnace with a typical capacity of 18,100 Mg/year
(20,000 tpy) which processes contaminated scrap and uses reactive
fluxes is estimated to emit 177 Mg/yr (195 tpy) of PM (of which
approximately 0.80 Mg/yr [0.88 tpy] is particulate metal HAP), 29.7 Mg/
yr (32.6 tpy) of HCl, and 8 g TEQ/yr (0.018 lb TEQ/yr) D/F (See docket
item II-B-16, impacts memo).
As described in section IV.C.1 of this document, process furnaces
have been divided into group 1 (unrestricted scrap content,
unrestricted fluxing) and group 2 (clean charge, no reactive flux).
Existing group 1 furnaces are emission units within the secondary
aluminum processing unit affected source.
Dross-only furnaces are furnaces dedicated to reclamation of
aluminum from drosses formed during the melting/holding/alloying
operations carried out in other furnaces. Exposure to the atmosphere
causes the molten aluminum to oxidize, and the flotation of the
impurities to the surface along with any salt flux creates ``dross''.
Prior to tapping, the dross is periodically skimmed from the surface of
the aluminum bath, and cooled. Dross-only furnaces are typically rotary
barrel furnaces (also known as salt furnaces). A dross only furnace
without controls with a typical capacity of 18,200 Mg/yr (20,000 tpy)
is estimated to emit 113 Mg/yr (125 tpy) of PM (of which some fraction
is particulate metal HAP (See docket item II-B-16, impacts memo).
Rotary dross coolers are devices used to cool dross in a rotating,
water-cooled drum. A rotary dross cooler without controls with a
typical capacity of 9,090 Mg/yr (10,000 tpy) is expected to emit 15.4
Mg/yr (17.0 tpy) of PM (of which some fraction is particulate metal
HAP) (See docket item II-B-16, impacts memo, docket item II-B-15,
Peters Risk Memo 3/27/97).
In-line fluxers are devices used for aluminum refining, including
degassing, outside the furnace. The process involves the injection of
chlorine, argon, nitrogen or other gases to achieve the desired metal
purity. Argon and nitrogen are not reactive and do not produce HAPs.
In-line fluxers are found primarily at facilities that manufacture very
high quality aluminum or in facilities with no other means of
degassing. An in-line fluxer operating without emission controls, of
typical capacity of 45,500 Mg/yr (50,000 tpy) is estimated to emit 60.8
Mg/yr (66.8 tpy) of HCl and 1.9 Mg/yr (2.1 tpy) of PM (see docket item
II-B-16, impacts memo). Existing in-line fluxers are emission units
within the secondary aluminum processing unit affected source.
Given that these processes release significant quantities of HAPs
and the availability of emission control systems, the EPA selected to
develop and propose NESHAP for the following emission sources: New,
reconstructed and existing scrap shredders, chip dryers, scrap dryer/
delacquering/decoating kilns, sweat furnaces, dross-only furnaces,
rotary dross coolers, and group 2 (clean charge, no reactive flux)
furnaces; new and reconstructed group 1 furnaces and in-line fluxers;
and secondary aluminum processing units (composed of existing group 1
furnaces and in-line fluxers).
The proposed standards would limit emissions of metal HAPs, organic
HAPs (including D/F), and HCl from secondary aluminum production
facilities. (Pollutant health effects were discussed in section II.C.
of this document). As described above, these HAPs are emitted in
significant quantities from secondary aluminum production sources.
C. Selection of Proposed Standards for Existing and New Sources
1. Background
After the EPA has identified the specific source categories or
subcategories of major sources to regulate under section 112, MACT
standards must be set for each category or subcategory. Section 112
establishes a minimum baseline or ``floor'' for standards. For new
sources, the standards for a source category or subcategory cannot be
less stringent than the emission control that is achieved in practice
by the best-controlled similar source. (See section 112(d)(3).) The
standards for existing sources can be less stringent than standards for
new sources, but they cannot be less stringent than the average
emission limitation achieved by the best-performing 12 percent of
existing sources for categories and subcategories with 30 or more
sources, or the average or median of the best-performing five sources
for categories or subcategories with fewer than 30 sources.
After the floor has been determined for a new or existing source in
a source category or subcategory, the Administrator must set MACT
standards that are no less stringent than the floor. Such standards
must then be met by all sources within the category or subcategory. In
establishing the standards, the EPA may distinguish among classes,
types, and sizes of sources within a category or subcategory. (See
section 112(d)(1).)
The next step in establishing MACT standards is to investigate
regulatory alternatives. With MACT standards, only alternatives at
least as stringent as the floor may be selected. Information about the
industry is analyzed to develop model plants for projecting national
impacts, including HAP emission reduction levels and cost, energy, and
secondary impacts. Regulatory alternatives (which may be different
levels of emissions control, equal to or more stringent than the floor
levels) are then evaluated to select the regulatory alternative that
best reflects the appropriate MACT level. The
[[Page 6960]]
selected alternative may be more stringent than the MACT floor, but the
control level selected must be technologically achievable. The
regulatory alternatives and emission limits selected for new and
existing sources may be different because of different MACT floors.
The Agency may consider going beyond the floor to require more
stringent controls. Here, the EPA considers the achievable emission
reductions of HAPs (and possibly other pollutants that are co-
controlled) and the cost impacts.
Subcategorization within a source category may be considered when
there is enough evidence to demonstrate clearly that there are
significant differences among the subcategories. The criteria to
consider include process operations (including differences between
batch and continuous operations), emission characteristics, control
device applicability, safety, and opportunities for pollution
prevention.
The EPA examined the processes, the process operations, and other
factors to determine if separate classes of units, operations, or other
criteria have an effect on air emissions from emission sources, or the
controllability of those emissions. Based on differences in emissions,
the type of materials processed and the fluxing practices employed, the
EPA has distinguished two specific classes of melting, holding, and
refining furnaces. Because HAP emission potential is strongly
influenced by the contaminants present in the materials that are melted
and the type and amount of flux added, these furnaces would be subject
to separate standards under the proposed rule.
The classes of process furnaces which are characterized by the
types of scrap charged to the furnace and the operations carried out in
the furnace are: (1) Group 1 (all process furnaces except group 2)
furnaces and (2) group 2 (``clean charge/no reactive flux'') furnaces.
Dross-only furnaces and sweat furnaces are distinctly different
from the other types because they each specialize in recovering
aluminum from a particular type of raw material. As the name implies,
``dross-only'' furnaces charge only dross collected from other furnace
operations. Sweat furnaces recover aluminum from materials with a high
iron (or other ferrous material) content. Both of these furnaces are
unique in their method of operation and are treated as separate sources
in development of the proposed NESHAP.
2. Selection of MACT Floor Technology
In establishing these proposed emission standards, the technology
representative of the MACT floor level of control was determined for
each affected source. Add-on control technologies were considered as
well as work practices and pollution prevention techniques. Data
related to operating procedures and emissions for secondary aluminum
plants were obtained through a combination of site visits, an ICR, an
EPA/industry voluntary follow-up questionnaire, and emissions tests.
Emission tests were conducted at 12 facilities to measure
uncontrolled and controlled emissions from selected production
processes and to evaluate the effectiveness of the technology
representative of the MACT floor level of control. Sites for these
tests were selected jointly by the EPA and industry as operating
technology representative of the MACT floor level of control. Funding
for tests was provided by the EPA, The Aluminum Association, and
individual facilities. The EPA also met frequently with industry
representatives to discuss the test program and available data, and to
identify and resolve issues. In addition to the data from the emission
testing program, the Agency also used emissions data from the ICR
database (docket item II-D-105, ICR database). Data from all these
sources were considered in the selection of emission limits for
individual emission points at secondary aluminum plants. Additional
details on the emission test data can be found in the docket. (See
Docket Item II-B-17. Memorandum. M. Wright, Research Triangle
Institute, to J. Santiago, EPA:MICG. Summary of Emissions Data. 1998.)
One important aspect of the more effective control technologies is
the system that captures and collects the HAPs generated by each of the
processes. Well-designed hoods and their proper placement, adequate air
flows or ventilation rates, and adequately sized ductwork and fans, in
well-maintained systems are representative of the MACT floor technology
control systems. These well-designed capture and collection systems can
be achieved by following the design standards in the American
Conference of Governmental Industrial Hygienists (ACGIH) ``Industrial
Ventilation: A Manual of Recommended Practice.'' The standards
described in Chapters 3 and 5 of this manual are incorporated by
reference in the rule as a requirement applicable to affected sources
equipped with add-on control devices.
Scrap shredders. Based on information provided in the ICR
responses, the EPA identified 69 shredding and crushing operations at
51 facilities. Emissions test measurements show that shredders and
crushers are sources of PM (containing particulate metal HAP). Fabric
filters are used to control emissions at 49 of the 69 shredders and
crushers in the industry. The best performing 12 percent of the
existing 69 scrap shredders and crushers are equipped with a fabric
filter for controlling PM and HAP metals. Therefore, the floor level of
control for existing sources is determined by the average/median of the
best performing 8 sources within the category. This median level of
control is represented by a well designed and operated pulse-jet fabric
filter using fiberglass bags with an air to cloth ratio of about 6.0.
This same level of control is also the MACT floor for new sources
since it is also the level of control achieved by the best controlled
source.
Chip dryers. The EPA identified five chip dryers based on
information provided in the ICR responses. Emissions test measurements
show that these sources emit THC (containing organic HAP) and D/F. Four
of these five dryers are equipped with an afterburner. The MACT floor,
for categories of less than 30 sources is determined by the median of
the five best controlled sources in the category. The best performing 4
of the existing 5 chip dryers are equipped with an afterburner for
organics (i.e., THC and D/F) control. Therefore, the floor level of
control for existing sources is determined by the median of the best
performing 5 sources within the category. This median level of control
is represented by a well designed and operated afterburner with a
minimum of 1-second residence time and operated at a temperature of
1,200 deg.F.
The same level of control which represents the existing source MACT
is also the MACT floor for new sources since it is also the level of
control achieved by the best controlled source.
Scrap dryers/delacquering kilns/decoating kilns. Based on
information provided in the ICR responses, the EPA identified 46 scrap
dryers, delacquering kilns, and decoating kilns. Emissions test
measurements show that these sources emit PM (containing particulate
metal HAP), HCl, THC (containing organic HAP) and D/F.
Afterburners followed by a lime injected fabric filter system are
used to control emissions at 13 of the 46 scrap dryers/delacquering
kilns/decoating kilns in the industry. The best performing 12 percent
of the existing 46 scrap dryers/delacquering kilns/decoating kilns are
equipped with an
[[Page 6961]]
afterburner for organics (i.e., THC and D/F) control and a lime
injected fabric filter for controlling HCl, D/F, PM and HAP metals.
Therefore, the floor level of control for existing sources is
determined by the average/median of the best performing 6 sources
within the category. This median level of control is represented by a
well designed and operated afterburner with a minimum of 1-second
residence time and operated at a temperature of 1400 deg.F followed by
a pulse-jet fabric filter using fiberglass bags with an air to cloth
ratio of about 4.0 and continuous lime injection.
The existing source MACT is also the MACT floor for new sources
since it is also the level of control achieved by the best controlled
source.
Sweat furnaces. Based on data provided in the ICR responses, the
EPA identified 12 sweat furnaces in the industry. These sources reclaim
aluminum from scrap containing high levels of iron by heating the scrap
to a temperature above the melting point of aluminum but below that of
iron. Emissions test measurements show that these sources emit THC and
D/F. Six of the 12 sweat furnaces are equipped with afterburners to
control THC and D/F. The MACT floor, for categories of less than 30
sources is determined by the median of the five best controlled sources
in the category. Therefore, afterburners represent the MACT floor level
of control for existing sweat furnaces. An afterburner representative
of this median level of control is designed for a minimum of 1-second
residence time and operated at a temperature of 1600 deg.F.
The existing source MACT is also the MACT floor for new sources
since it is also the level of control achieved by the best controlled
source.
Group 1 furnaces. Existing group 1 furnaces are emission units
within a secondary aluminum processing unit affected source. Each new
and reconstructed group 1 furnaces is a separate affected source. The
EPA identified 528 Group 1 furnaces based on information provided in
the ICR responses. Approximately one-half of these furnaces operate
with no add-on air pollution control devices. Emissions test
measurements show that these sources emit PM (containing particulate
metal HAP), HCl, and D/F. The add-on controls used on group 1 furnaces
include fabric filters, lime coated fabric filters, lime injected
fabric filters, cyclones, incinerators and wet scrubbers.
Other furnaces in group 1 limit emissions through the use of work
practices, design practices, and pollution prevention approaches. These
techniques include, but are not limited to, charging only clean scrap
to the furnaces and design and work practice approaches for fluxing,
limiting oil and coatings content of furnace charges through the use of
scrap purchasing specifications and scrap inspection, fluxing only in
holding furnaces, fluxing in in-line fluxers, and limiting the use of
reactive fluxes. Work practices and pollution prevention approaches may
also be combined with add-on controls to achieve HAP reductions.
Lime injected fabric filter systems are used to control emissions
at 68 of the 528 group 1 furnaces in the industry. The best performing
12 percent of the existing 528 group 1 furnaces are equipped with a
lime injected fabric filter for controlling HCl, PM and HAP metals, and
for controlling D/F from those furnaces which process scrap containing
oil and coatings. Therefore, the floor level of control achievable by
existing emission units is determined by the average/median of the best
performing 63 sources within the category. This median level of control
is represented by a well designed and operated pulse jet fabric filter
with an air to cloth ratio of about 6.5 and continuous lime injection.
The level of control achievable by existing emission units
represents the MACT floor for new sources since it is also the level of
control achieved by the best controlled source.
Group 2 furnaces. Based on the ICR data, the EPA estimates that
about 75 group 2 furnaces are currently in operation. None of the
furnaces in group 2 are equipped with add-on air pollution control
devices. Emissions from these furnaces are typically controlled by work
practices that require charging only clean charge materials, coupled
with fluxing operations using only non-reactive agents (i.e. fluxes
which do not contain or produce HAPs). Since emissions from these units
are at very low levels and considering the cost of emissions testing,
the application of emission measurement methodology and setting
specific emissions limits for this particular class of source is not
practicable due to economic limitations. Thus, work practice procedures
under section 112(h) of the Act (limitations on type of charge and type
of flux used) constitute the MACT floor level of control for existing
Group 2 furnaces as well as MACT for new group 2 furnaces.
Dross-only furnaces. Based on the information reported in the ICR,
the EPA identified 15 dross-only furnaces. Emissions test measurements
show that these sources emit PM (containing particulate metal HAP). All
dross-only furnaces are equipped with control systems that include a
fabric filter, some of which have lime injection systems. The MACT
floor, for categories of less than 30 sources is determined by the
median of the five best controlled sources in the category. The ICR
data show that the control technology in place at the five best-
controlled sources is a lime injected fabric filter. Therefore, lime
injected fabric filters represent the MACT floor level of control for
existing dross-only furnaces. The technology at the median level of
control is represented by a well designed and operated fabric filter
with polyester bags at an air to cloth ratio of 6.5 to 1 with
continuous lime injection.
The existing source MACT floor is also the MACT floor for new
sources since it is also the level of control achieved by the best
controlled source.
Rotary dross coolers. The EPA identified 26 rotary dross coolers
based on the information provided in the ICR responses. Emissions test
measurements show that these sources emit PM (containing particulate
metal HAP). All 26 rotary coolers are equipped with fabric filters. The
MACT floor, for categories of less than 30 sources is determined by the
median of the five best controlled sources in the category. Therefore,
fabric filters represent the MACT floor level of control for existing
rotary dross coolers. A fabric filter representative of the median of
the best 5 controlled sources is a well designed and operated pulse-jet
fabric filter system using polyester bags with an air to cloth ratio of
3.0.
The existing source MACT floor is also the MACT floor for new
sources since it is also the level of control achieved by the best
controlled source.
In-line fluxers. Existing in-line fluxers are emission units within
a secondary aluminum processing unit affected source. Each new and
reconstructed in-line fluxer is a separate affected source. The EPA
identified a total of 120 in-line fluxers (also referred to as
degassing boxes) from the information reported in the ICR responses.
Emissions test measurements show that in-line fluxers are sources of
low concentrations of PM (containing particulate metal HAP) and HCl.
Eleven in-line fluxers are controlled by fabric filters and 7 of these
have lime (or other alkaline reagent) injection systems. The average of
the best performing 12 percent of the existing 120 in-line fluxers is
represented by a lime injected fabric filter for controlling HCl, PM
and HAP metals. The level of control achievable by existing emission
units is represented by a well designed and operated pulse-jet fabric
filter using
[[Page 6962]]
fiberglass bags with an air to cloth ratio of about 7.0 and continuous
lime injection.
The level of control achievable by existing emission units
represents the MACT floor for new sources since it is also the level of
control achieved by the best controlled emission unit.
Secondary aluminum processing units. A secondary aluminum
processing unit consists of all of the existing group 1 furnace
emission units and all of the existing in-line fluxer emission units at
a secondary aluminum production facility. The MACT floor level of
control is determined by applying the level of control achievable to
each emission unit within the affected source. As described in the
paragraphs in this section of the document which address the
determination of the MACT floor for group 1 furnaces and in-line
fluxers, this is represented by the level of control achieved by a lime
injected fabric filter of appropriate design, coupled with continuous
lime injection. Each new or reconstructed group 1 furnace or in-line
fluxer is a separate affected source subject to the MACT floor emission
limitations as described in the paragraphs in this section of the
document which address the determination of the MACT floor for group 1
furnaces and in-line fluxers.
3. Consideration of Beyond-the-Floor Technologies
The EPA investigated beyond-the-floor controls for each pollutant
and affected source regulated by the proposed rule. For each of the
cases evaluated, the Agency did not identify cost-effective emission
control technologies that would accomplish additional emission
reductions to a level below that achieved by the MACT floor technology.
Therefore, the Agency is proposing emission limits at the MACT floor
level of control.
4. Selection of Emission Limits
The EPA and industry conducted comprehensive emission tests at 12
facilities to characterize uncontrolled and controlled emissions from
the various processes and to evaluate the effectiveness of existing
control devices and work practice and pollution prevention approaches.
Sites with add-on control technologies selected for emission testing
represented the use of technology identified by the EPA as the MACT
floor technology. Other sites were tested where work practice and
pollution prevention approaches were used to achieve HAP emission
reductions. Data from these sites showed that work practices and
pollution prevention approaches could achieve HAP emission levels
similar to those achieved with add-on MACT floor technologies.
Therefore, the EPA is proposing a combination of work practice/
pollution prevention based standards and MACT floor control technology
based numerical emission limits for control of HAP from affected
sources subject to the proposed rule.
The EPA is, in most cases, proposing emission limits in a mass per
unit (e.g., kg/Mg or lb/ton) of feed format. This format provides
several advantages. For example, for process units that release
emissions from more than one stack and where multiple similar affected
sources are controlled by a common control device, total emission rates
can be determined by measuring emissions for a particular pollutant
from each stack or discharge point, e.g. lbs/hr, adding those, and
dividing by the sum of all affected source feed rates, e.g. tons/hr. In
addition, this format is tied to production and the emission limits are
unaffected by dilution. In specific cases, concentration based
numerical emission limits, or minimum percentage reduction standards
are appropriate; the format of these standards is explained in the
discussion of these emission standards.
All limits on particulate metal HAP emissions are expressed in
terms of a surrogate pollutant, PM. The use of the surrogate PM
emissions limit will require the installation and operation of the
appropriate MACT floor technology for metal HAPs control from new and
existing sources. Use of PM as a surrogate for metal HAPs also has the
advantage of simplifying and reducing the cost of performance testing
and monitoring.
Except for D/F which merits special consideration due to high
toxicity, all emission standards for gaseous organic HAPs are expressed
in terms of a surrogate pollutant, THC. The use of a surrogate THC
emissions limit for gaseous organic HAPs will require facilities to
install and operate the appropriate MACT floor technology for gaseous
organic HAPs from new and existing sources.
All limits on D/F emissions are expressed in units of toxic
equivalent (TEQ). Toxic equivalent refers to the international method
of expressing toxicity equivalents for dioxins and furans as defined in
the EPA report, ``Interim Procedures for Estimating Risks Associated
with Exposures to Mixtures of Chlorinated Dibenzo-p-dioxins and -
dibenzofurans (CDDs and CDFs) and 1989 Update'' (docket item II-A-1).
In addition to the emission limits discussed below, the EPA is also
proposing a 10 percent opacity limit applicable to affected sources
with fabric filter control devices that choose to monitor with a COM
and affected scrap shredders that choose to monitor with a COM or by
visible emissions monitoring. During the course of many emission tests
conducted at secondary aluminum facilities, the EPA has determined that
the exhaust gases from properly designed, operated, and maintained
fabric filters have essentially zero opacity. An opacity of 10 percent
or greater following a successful performance test on a fabric filter
controlled affected source is a clear indication that the control
device is not functioning properly.
Scrap shredders. The proposed PM limit for scrap shredders and
crushers of 23 mg/dscm, (0.010 gr/dscf) is based on test results from
four facilities equipped with well designed and operated fabric filters
representative of the MACT floor technology for new and existing
sources where PM measured emissions ranged from 0.0002 gr/dscf to
0.0069 gr/dscf. The EPA took into consideration the wide variation in
controlled emissions for the four MACT floor fabric filter systems in
selection of the emission limits of 23 mg/dscm (0.010 gr/dscf). Such a
range in performance represents the typical variations associated with
the process and with application of the floor technology. The proposed
PM emission limit represents a level that can be achieved by all scrap
shredders and crushers using the MACT floor technology. The supporting
emissions data are presented in Figure 1 and Table 3 below.
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Table 3.--Summary of Scrap Shredders and Crushers Particulate Emissions Test Data
----------------------------------------------------------------------------------------------------------------
Average PM emissions
Plant Control device -------------------------------
PM (gr/dscf) PM (mg/dscm)
----------------------------------------------------------------------------------------------------------------
24......................................... Fabric Filter...................... 0.0022 5.0
25......................................... Fabric Filter...................... 0.0069 15.8
26......................................... Fabric Filter...................... 0.0002 0.46
27......................................... Fabric Filter...................... 0.0008 1.8
----------------------------------------------------------------------------------------------------------------
For this affected source, a concentration format is appropriate
because PM concentration is easily and reliably measured from these
sources and PM concentration reflects fabric filter performance, the
technology representative of MACT for new and existing sources.
The EPA is also proposing a 10 percent opacity limit applicable to
fabric filters applied to scrap shredder waste gas streams if the owner
or operator chooses to monitor either with a COM or by visible
emissions monitoring. As noted above, the EPA has determined that the
presence of a 10 percent or greater opacity discharge from a fabric
filter following a successful performance test is a clear indication
that the device is not functioning properly.
Chip dryers. One chip dryer with a well designed and operated
afterburner representative of the MACT floor was tested. The controlled
THC emissions from tests at this facility averaged 0.21 kg/Mg (0.42 lb/
ton) of feed and the D/F emissions averaged 1.3 /Mg D/F TEQ
(1.7 x 10 -5 gr/ton) of feed. The data are shown in Figure 2
below.
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[[Page 6965]]
Based on these data the EPA is proposing a THC limit of 0.40 kg/Mg
(0.80 lb/ton) of feed and a D/F (TEQ) limit of 2.5 ``g/Mg (3.5
x 10-5 gr/ton) of feed.
Scrap dryers/delacquering kilns/decoating kilns.
The same process equipment can function as a scrap dryer, a
delacquering kiln, or a decoating kiln. Equipment of an identical
design is capable of performing different functions by changing the
operating temperature and charge make-up. In addition, the control
technology representative of MACT for new and existing sources is the
same for kilns operating as scrap dryers and kilns operating as
delacquering/decoating kilns. The EPA/industry task group spent
considerable effort trying to define scrap dryers and delacquering/
decoating kilns such that separate emission standards could be set for
each. Despite this substantive effort, the task group was unable to
develop consistent, unambiguous definitions which would permit the
establishment of different classes of scrap dryers, delacquering kilns,
or decoating kilns. In recognition of the different operating modes
applicable to these affected sources such as operating temperatures,
charge make-up, difference in uncontrolled emission levels; to provide
operational flexibility; and to ensure that the technology
representative of the MACT floor for new and existing sources is
installed and properly operated at these sources, the EPA is proposing
two alternate sets of emission standards.
One set of emission standards is based on emissions data obtained
from a kiln operating as a delacquering/decoating kiln with an
operating temperature about 1,000 deg.F and processing only coated
materials, such as painted siding and used beverage containers, and
operating a well designed afterburner/lime injected fabric filter
system representative of MACT for new and existing sources. This set of
standards for PM, HCl, THC, and D/F is summarized in Table 4.
Table 4. Summary of Emission Limits for Scrap Dryers, Delacquering Kilns, and Decoating Kilns Operating as
Delacquering Kilns
----------------------------------------------------------------------------------------------------------------
PM (lb/ton of HCl (lb/ton of THC (lb/ton of D/F (g/
Process feed) feed) feed) Mg of feed)
----------------------------------------------------------------------------------------------------------------
Scrap Dryer, Delacquering Kiln, Decoating
Kiln....................................... 0.080 0.80 0.060 0.25
----------------------------------------------------------------------------------------------------------------
The other set of emission standards is based on the emissions data
obtained from a kiln that had an operating temperature of about
700 deg.F and was processing scrap with oils, coatings, paints,
insulation, etc. The control technology in use was an afterburner/lime
injected fabric filter system representative of MACT for new and
existing sources. That set of standards and control device design and
operating requirements is summarized in Table 5.
Table 5.--Summary of Alternate Emission Limits and Control Equipment Requirements for Scrap Dryers, Delacquering Kilns, and Decoating Kilns Operating as
Scrap Dryers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Afterburner design and operating
requirements
Process PM (lb/ton of HCl (lb/ton of THC (lb/ton of D/F (g/---------------------------------
feed) feed) feed) Mg of feed) Temperature ( Residence timea
deg.F) (seconds)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Scrap Dryer, Delacquering Kiln, Decoating Kiln.... 0.30 1.50 0.20 5.0 1,400 1.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
a Afterburner design residence time.
The first set of proposed emission limits for scrap dryers,
delacquering kilns, decoating kilns in Table 4 is supported by the
delacquering emissions data summarized in Table 6 and Figure 3. Under
this set of standards an operator is required to meet a more stringent
set of emission limits, but the afterburner design parameters are not
requirements.
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Table 6.--Summary of Scrap Dryer, Delacquering Kiln, Decoating Kiln Emissions Data With MACT Controls
----------------------------------------------------------------------------------------------------------------
D/F (g/Mg of
feed) feed) feed) feed)
----------------------------------------------------------------------------------------------------------------
2--Scrap Dryer.................................. 0.167 0.827 .............. ..............
3--Scrap Dryer.................................. 0.214 1.26 a 0.072 a 2.66
4--Delacquering................................. b 0.00057 b 0.544 b 0.006 b 0.118
5--Delacquering................................. c 0.024 .............. c 0.037 ..............
d 0.051 .............. d 0.035 ..............
----------------------------------------------------------------------------------------------------------------
a Calculated by applying the afterburner efficiency to the uncontrolled fugitive emissions escaping from the
kiln product discharge point. These emissions are supposed to be captured and controlled by the afterburner
but problems during testing allowed emissions to escape from the kiln end where material leaves the process.
b Emissions test of kiln processing used beverage containers for D/F test and painted siding for all other
tests.
c Emissions test of kiln processing used beverage containers.
d Emissions test of kiln processing painted siding.
Because of the lower level of uncontrolled emissions generated when
a kiln is operated as a delacquering kiln (i.e., operating temperature
of about 1,000 deg.F and processing used beverage containers and
painted siding only), an operator could conceivably operate a kiln
primarily as a delacquering/decoating kiln but add a small amount of
materials, such as oils or insulation, and classify it as a scrap
dryer. In this case the operator could thereby operate with less than
the MACT floor control equipment 1400 deg.F and 1 second residence time
afterburner design, while only reducing emissions to the level of the
less stringent alternate emission
limits. To preclude this, the EPA is specifying minimum afterburner
design and operating requirements of 1 second residence time and
1400 deg.F, MACT floor technology, for those operators electing to
process material with oils, coatings, and insulation, in addition to
used beverage containers and painted siding, thus operating the
equipment as a scrap dryer rather than a delacquering/decoating kiln.
The EPA is proposing the second, or alternate, set of emission
standards based on data obtained from a kiln being operated as a scrap
dryer. These alternate limits are combined with control device design
and operating requirements to ensure that
control technology representative of MACT is used when an operator
chooses to comply with the higher, or less stringent, emission limits
associated with a scrap dryer processing scrap with oils, coatings,
paints, etc.
As noted above, the emissions data supporting the second or
alternate emission limits were obtained from a kiln operating as a
scrap dryer at a temperature of about 700 deg.F. These data are
summarized in Table 6 and shown in Figure 4. The control technology in
use was an afterburner/lime injected fabric filter system
representative of MACT for new and existing sources.
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The EPA is also proposing a 10 percent opacity limit applicable to
fabric filters applied to scrap dryer, and delacquering and decoating
kiln waste gas streams if a COM is chosen as the monitoring option. As
noted above, the EPA has determined that the presence of a 10 percent
or greater opacity discharge from a fabric filter following a
successful performance test is a clear indication that the device is
not functioning properly.
Sweat furnaces. EPA tested one sweat furnace equipped with a well
designed and operated afterburner representative of MACT for new and
existing sources.
Controlled D/F emissions averaged 0.35 ng/dscm (1.5 x
10-10 gr/dscf) and are shown in Figure 5. Based on these
data, the EPA is proposing a D/F limit for sweat furnaces of 0.80 ng/
dscm D/F TEQ (3.5 x 10-10 gr/dscf) corrected to an 11
percent oxygen basis.
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A concentration limit, as opposed to a production based limit, is
proposed for this source because materials charged to these furnaces
are typically introduced in a random fashion without being weighed.
Consequently, determining an emission rate per unit of feed is not a
practical option as a format for the emission limit.
Dross-only furnaces. The EPA/industry tested one dross only furnace
equipped with a well designed and operated fabric filter representative
of the MACT floor for new and existing sources. The PM emissions from
tests at this facility averaged 0.104 kg/Mg of feed (0.207 lb/ton).
Based on these data as shown in Figure 6, the EPA is proposing a PM
limit of 0.15 kg/Mg of feed (0.30 lb/ton).
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The EPA is also proposing a 10 percent opacity limit applicable to
fabric filters applied to dross-only furnace waste gas streams if a COM
is chosen as the monitoring option. As noted above, the EPA has
determined that the presence of a 10 percent or greater opacity
discharge from a fabric filter following a successful performance test
is a clear indication that the device is not functioning properly.
Rotary dross coolers. The EPA/industry tested two rotary dross
coolers equipped with a well designed and operated fabric filter
representative of the MACT floor technology for new and existing
sources. The PM emissions from tests at these facilities averaged 2.29
and 75.5 mg/dscm (0.001 and 0.033 gr/dscf), respectively. These data
are summarized in Table 7 and Figure 7.
Table 7.--Summary of Rotary Dross Cooler Emission Data
------------------------------------------------------------------------
PM (gr/
Plant PM (mg/dscm) dscf)
------------------------------------------------------------------------
21........................................... 2.29 0.001
22........................................... a 75.5 a 0.033
------------------------------------------------------------------------
a Plant 22 is equipped with a lime-injected fabric filter.
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Based on these data the EPA is proposing a PM limit of 92 mg/dscm
(0.040 gr/dscf). The proposed PM emission limit represents a level that
can be achieved by all rotary dross coolers using the floor technology
for new and existing sources.
The EPA is also proposing a 10 percent opacity limit applicable to
fabric filters applied to rotary dross cooler waste gas streams if a
COM is chosen as the monitoring option. As noted above, the EPA has
determined that the presence of a 10 percent or greater opacity
discharge from a fabric filter following a successful performance test
is a clear indication that the device is not functioning properly.
In-line fluxers. The EPA/industry tested one in-line fluxer
equipped with a well designed and operated fabric filter with
continuous lime injection representative of the control which is
achievable for these emission units. Additional performance test data
from the same in-line fluxer was also available (see docket item II-B-
19, historical data memo). The PM emissions from tests performed at
this facility averaged 0.00170 kg/Mg (0.00340 lb/ton) of feed and are
shown in Figure 8. Based on these data the EPA is proposing a PM limit
of 0.005 kg/Mg (0.01 lb/ton) of feed for new and reconstructed in-line
fluxers. The HCl emissions from tests at this facility averaged 0.0072
kg/Mg (0.014 lb/ton) of feed and are also shown in Figure 8. Based on
these data the EPA is proposing an HCl limit of 0.02 kg/Mg (0.040 lb/
ton) of feed for new and reconstructed in-line fluxers.
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The EPA is also proposing a 10 percent opacity limit applicable to
fabric filters applied to in-line fluxer waste gas streams if a COM is
chosen as the monitoring option. As noted above, the EPA has determined
that the presence of a 10 percent or greater opacity discharge from a
fabric filter following a successful performance test is a clear
indication that the device is not functioning properly.
Furnace Operations The EPA spent considerable effort analyzing ICR
data and emissions data to evaluate the need for different classes for
the remaining furnace types and configurations. Operating practices,
control practices, work practices, pollution prevention efforts,
furnace charge materials, flux rates and methods, and emissions vary
widely within the industry. All of these factors entered into the
consideration of different classes (Ref. ICR database, emission data
summaries). In addition, there were many meetings and discussions with
the industry to discuss and evaluate a multitude of options and issues
associated with each factor. At one time, as many as five potential
classes were under consideration and discussion. As analyses of the
potential classes progressed, many issues were raised regarding
definitions of the classes, process operating practices, and control
approaches. Further, as potential emissions limits for these classes
were discussed, it became evident to the EPA that these furnaces could
be compressed into two classes. Therefore, based on evaluation of these
options, the EPA is proposing two classes for process furnace
operations:
Group 2 furnaces--clean charge materials with no reactive
fluxing.
Group 1 furnaces--furnaces charging different gradations
of clean materials with reactive fluxing to dirty materials with
various fluxing amounts/techniques.
Group 2 furnaces. For group 2 furnaces the EPA is proposing work
practice/pollution prevention practices under section 112(h) of the
Act. Section 112(h) of the Act provides for the establishment of work
practice standards where it is not feasible to prescribe or enforce an
emission standard.
The MACT floor for new and existing sources for this group of
furnaces consists of work practices/pollution prevention practices
including charging and melting only ``clean'' charge materials, as
defined in the proposed regulation (molten aluminum, T-bar, sow, ingot,
alloying elements, uncoated aluminum chips, aluminum scrap dried/
delacquered/decoated, and noncoated runaround scrap), and no reactive
fluxing. Compliance with the standard would be demonstrated by labeling
of the furnace as group 2, and record keeping of charge and flux
materials along with certification every six months that only clean
charges were used and that no reactive flux was used in the furnace.
The Administrator has determined it is not feasible to prescribe an
emission standard for this class of furnaces because the application of
measurement methodology is not practicable due to economic limitations.
Group 1 furnaces. Group 1 furnaces consist of all process (melting,
holding, refining) furnaces that do not meet the requirements for a
group 2 furnace. These include combinations of:
(1) Dirty furnace charge materials and fluxing with or without
reactive fluxes, and
(2) Clean furnace charge materials (work practices) with use of
reactive fluxing.
The achievable emissions limitation for group 1 furnace emission
units and the standard for new and reconstructed group 1 furnaces is
based on furnaces in which dirty charge materials and unlimited fluxing
are used, and that are equipped with the MACT floor control technology,
a fabric filter with a continuous lime injection system. The proposed
limits for new and reconstructed group 1 furnaces are shown in Table 8.
The basis and rationale for these limits are provided in the emission
test data graphs and discussion below.
Table 8.--Summary of Group 1 Furnace Emission Limits for New and Reconstructed Sources (Except Melter/Holders
Processing Clean Charge)
----------------------------------------------------------------------------------------------------------------
HCla
Process PM (lb/ton) D/F (g ---------------------------------
TEQ/Mg) (lb/ton) Removal (%)
----------------------------------------------------------------------------------------------------------------
Group 1 Furnaces............................ 0.40 15 0.40 90
----------------------------------------------------------------------------------------------------------------
a Facilities with add-on control devices will choose which requirement to comply with.
To meet the emission limits based on MACT floor technology, not all
new and reconstructed group 1 furnaces will have to be equipped with
lime injected fabric filter systems. Work practices, pollution
prevention practices, process design changes, charging clean or almost
clean materials, and reduced use of reactive fluxes while controlling
the reactive flux injection rate are some control approaches that may
be applied to some group 1 furnace installations with varying add-on
control approaches such that the resulting HCl and other HAP emissions
are below the emission limits being proposed.
To determine the emissions limitations achievable by group 1
furnace emission units and to establish the emission limits for new and
reconstructed group 1 furnaces, the EPA and industry tested furnaces in
6 facilities (Plants 6 through 11) with the MACT floor technology
applied. The emissions data are presented in Figures 9, 10, and 11
below. The furnace emissions data with control status labeled as ``lime
baghouse'' were equipped with the MACT floor technology.
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In addition, the EPA and industry tested group 1 furnaces that had
no add-on control technologies, but used work practices/pollution
prevention practices such as process design changes that allowed
reduced levels of reactive fluxing, as well as selective scrap charging
(but not ``clean charge''), to achieve lower levels of HAP emissions.
Both melting and holding furnaces were included in these tests. These
results are also shown in Figures 9, 10, and 11. These furnace data are
labeled with control status as ``work practice.''
All of the data in Figures 9, 10, 11 were considered in determining
the achievable emissions limitations for group 1 furnace emission units
and in establishing the proposed emission limits for new and
reconstructed individual Group 1 furnaces that are listed in Table 8
above. Some of the variations in the work practice/ pollution
prevention emissions are due to different design of process, work
practice, and pollution prevention alternatives, and the fact that
these emissions will vary with the differing grades of aluminum
produced.
Average PM emission levels from group 1 furnaces equipped with MACT
floor add-on air pollution control devices varied from a low of 0.029
to a high of 0.28 lb/ton of feed. Average HCl emission levels from
furnaces equipped with MACT floor add-on air pollution control devices
varied from a low of 0.07 to a high of 0.36 lb/ton of feed. The
equivalent ranges of emissions for the work practice/pollution
prevention practice furnaces were 0.019 to 0.37 lb/ton and 0.001 to
0.36 lb/ton of PM and HCl, respectively.
The three test results for average D/F emissions from group 1
furnaces equipped with MACT floor add-on air pollution control devices
ranged from a low value of 0.46 to a high value of 4.5 g D/F
TEQ/Mg of feed. For the four work practice/pollution prevention
practice furnaces, the range was 0.21 to 0.41 g D/F TEQ/Mg.
To provide another perspective on the achievable D/F emission
limitation, the 15 g/Mg of feed emission limit (proposed for
new and reconstructed group 1 furnaces) expressed on a concentration
basis for the furnaces tested would be about 0.9 to 15.5 ng D/F TEQ/
dscm depending on the quantity of waste gas flow from the furnace.
The proposed standards for new and reconstructed group 1 furnaces
shown in Table 8 provide the option of achieving a 90 percent emission
reduction in HCl discharged from the furnace in lieu of meeting an
emission limit of 0.40 lb/ton. The EPA considered that group 1 furnaces
can be used to process a wide variety of scrap types (i.e., clean, with
insulation, oils, coated, painted, etc.) and perform various fluxing
operations with multiple agents including HAP producing and non-HAP
producing fluxes (i.e., salts, chlorine gas, nitrogen/chlorine bi-gas,
etc.) to produce a wide range of aluminum alloys. Because of the
potential differences in charge make-up, fluxing, work practices, and
final aluminum properties, there is potential for variability in HCl,
organic HAPs, particulate metal HAPs, and D/F emitted by the group 1
furnaces. In recognition of the different operating modes applicable to
these emission units and affected sources and to promote the most cost-
effective and economical approach to MACT controls while achieving the
MACT add-on air pollution control device equivalent reductions, the EPA
is proposing a dual HCl emission standard for new and reconstructed
group 1 furnaces. Both a numerical emission limit and an alternate
percent reduction requirement are being proposed. Some furnaces process
scrap that contains relatively large amounts of chloride compounds.
This factor in combination with high fluxing rates necessary to refine
some aluminum can yield control device inlet HCl quantities in excess
of 4 lbs/ton of feed. In these circumstances the floor technology may
not be able to meet the limit of 0.40 lb/ton, but can comply with the
90 percent removal requirement which is representative of what the MACT
floor technology is capable of achieving. Test results from Plants 7,
9, and 10, shown in Figure 10, indicated that HCl efficiencies in
excess of 90 percent removal were achieved. The range of variation in
measured efficiencies was significant at two facilities with some test
results below 90 percent. In these tests the lime usage rates were not
adequately controlled to achieve consistent HCl removal, hence a wide
variation in HCl removals resulted.
The level of removal achievable became an issue with the industry
and to resolve this issue the EPA tested another group 1 furnace in
Plant 11 with a lime injected fabric filter. During these tests the
lime injection rate was controlled to consistently achieve greater than
90 percent removal of HCl. Individual test results for this furnace are
shown in Table 9. These and other data demonstrate that fabric filters
operated with continuous lime injection into the gas stream upstream of
the fabric filter inlet are capable of consistently achieving at least
90 percent removal.
Table 9.--Plant 11 HC1 Individual Test Results
------------------------------------------------------------------------
Inlet lb/ Outlet Percent
Test No. ton lb/ton removal
------------------------------------------------------------------------
1...................................... 2.64 .018 99.3
2...................................... 2.66 0.020 99.2
3...................................... 1.31 0.050 96.2
4...................................... 2.10 0.028 98.7
------------------------------------------------------------------------
New and reconstructed group 1 furnaces processing clean charge
materials only, that perform both melting and holding functions
including reactive fluxing within the same unit (i.e., melter/holder),
and that do not transfer molten aluminum to or from another furnace
would be subject to alternate standards. These units perform the
operations normally carried out in two or more separate furnaces within
the confines of one furnace. Emission data obtained from tests on a
melter/holder furnace are shown in Figure 12.
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Emission limits are proposed for PM and HCl emissions from new and
reconstructed group 1 melter/holders. Those limits are shown in Table
10. The PM standard for new and reconstructed group 1 melter/holder
furnaces processing only clean charge materials is 0.40 kg/Mg (0.80 lb/
ton) of charge and the alternate HCl standard is 0.20 kg/Mg (0.40 lb/
ton) of charge.
Table 10.--Summary of New and Reconstructed Group 1 Melter/Holder Emission Limits
----------------------------------------------------------------------------------------------------------------
D/Fb (g TEQ/Mg) HCl (lb/ton)
----------------------------------------------------------------------------------------------------------------
Group 1 Melter/Holder Furnaces a. 0.80 .............. 0.40 or 90 percent removal.
----------------------------------------------------------------------------------------------------------------
a Performing both melting and holding functions in the same furnace and processing only clean charge materials.
b No dioxin limit because this furnace uses clean charge.
[[Page 6981]]
Operators of group 1 side-well furnaces would be permitted to
conduct reactive fluxing operations in the furnace side-well only. If
reactive fluxing operations are conducted in the furnace hearth, those
emissions must be captured and ducted to a control device. In this
event total furnace emissions (hearth plus side-well) would be subject
to the new and reconstructed group 1 furnace emission limits.
In addition to the above standards, the EPA is also proposing a 10
percent opacity limit applicable to the waste gas discharge from any
fabric filter applied to a group 1 furnace if a COM is chosen as the
monitoring option. As noted above, the EPA has determined that the
presence of a 10 percent or greater opacity discharge from a fabric
filter following a successful performance test is a clear indication
that the device is not functioning properly.
Secondary aluminum processing units. Available data from existing
group 1 furnace emission units and existing in-line fluxers were
analyzed to determine the emissions limitations which could be realized
through the application of add-on control devices and pollution
prevention/work practices. These data have been presented in the
paragraphs in this section of this document relating to group 1
furnaces and in-line fluxers. A secondary aluminum processing unit is
composed of all of the existing group 1 furnace emission units and all
of the existing in-line fluxer emission units at a secondary aluminum
production facility. Emission standards for this affected source have
been proposed, based on throughput weighted processing of material in
emission units controlled to achievable emission limitations. Limits
for PM, HCl and D/F have been proposed on a production basis.
(Operators of group 1 furnaces with very high potential HCl emissions
may choose to calculate the HCl limit for any or all individual group 1
furnace emission units on the basis of achieving a 90 percent reduction
in potential HCl emissions.) Based on the emissions achievable by
individual emission units, the following standards are proposed:
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Where:
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].
Operators may choose to calculate this limit on the basis of 90 percent
reduction in potential HCl emissions.
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
[g/Mg (gr/ton) of feed]
LtD/F=the overall D/F emission limit for the secondary
aluminum processing unit [g/Mg (gr/ton) of feed], and
n=the number of units in the secondary aluminum processing unit.
The emissions limits LiPM, LiHCl, and
LiD/F to be used in calculating the proposed standards for
secondary aluminum processing units are those proposed for individual
new and reconstructed in-line fluxers and group 1 furnaces. Production
in clean charge group 1 furnaces can not be included in calculating the
overall D/F emission limit, because it is assumed that these furnaces
are capable of operation with no D/F emissions, and because these
emission units are not subject to D/F limits. In-line fluxers that
operate using no reactive flux materials cannot be included in the
calculations of the overall PM and HCl emission limits since they are
not subject to emission limits for PM and HCl.
In addition to the above standards, the EPA is also proposing a 10
percent opacity limit applicable to the waste gas discharged from any
fabric filter applied to a furnace process train if a COM is chosen as
the monitoring option. As noted above, the EPA has determined that the
presence of a 10 percent or greater opacity discharge from a fabric
filter following a successful performance test is a clear indication
that the device is not functioning properly.
D. Selection of Operating and Monitoring Requirements
The EPA identified and analyzed the hierarchy of monitoring options
available for this source category. The array of monitoring options
includes the direct measurement of HAP or HAP surrogates by a CEM or
COM, periodic performance tests, continuous monitoring of process or
control device operating parameters that are related to emissions of
HAP, and recordkeeping and certification requirements. Each option that
was relevant to a process or add-on control device was evaluated
relative to its technical feasibility and cost.
A CEM provides a direct measurement of emissions of HAP or HAP
surrogates. CEMs are commercially available for HCl and THC. PM CEMs
are also available, however, the technical feasibility of these devices
for monitoring affected sources and emission units in this source
category has not yet been demonstrated, and the estimated capital cost
of PM monitoring systems is $213,000 with annual costs of $66,000 (see
docket item II-B-24, enhanced monitoring options memo). These costs are
significantly higher than those of other available options.
Continuous opacity monitoring systems (COMs) do not provide a
direct measurement of PM emissions but do provide continuous indication
of fabric filter performance. These devices are presently in use on
affected sources and emission units within this source category. Bag
leak detection systems also provide a continuous indication of fabric
filter performance and are less expensive to install and operate than
COMs.
Periodic performance tests by established EPA test methods are
required by the proposed rule. These tests provide important
information about HAP emissions. The expense of conducting performance
tests (see docket item II-B-24, enhanced monitoring options memo)
limits their usefulness as a means of ensuring continuous compliance
with an emission standard.
Another option for compliance assurance is monitoring control
device operating parameters coupled with repeat emission tests prior to
permit renewal (i.e., every 5 years). Control
[[Page 6982]]
device operating parameters can be monitored to ensure continued good
operation and maintenance. Test data and operating experience have
shown that maintaining operating parameters within a specified range of
values (those established based on existing data or performance tests)
can be used to ensure that the control device is operating properly and
is well maintained. Operating parameters and defined work practices
consistent with pollution prevention can also be used to maintain
emissions within limits.
In selecting monitoring requirements to ensure continuous
compliance with the proposed emission standards, the EPA has considered
technical feasibility and cost for all applicable options for each
combination of pollutant, affected source and control technique. In
some cases, where several monitoring options are technically feasible
and equally reliable, and where the operator has already installed a
particular type of monitor, the proposed rule allows the owner or
operator to select a monitoring technique such that a presently
installed, appropriate monitor may continue to be used.
Finally, the proposed rule recognizes that the owner or operator
may, through performance testing under varying conditions, be able to
devise and demonstrate the feasibility of certain monitoring parameters
and procedures. The proposed rule provides a procedure by which site-
specific monitoring plans for certain affected sources and emission
units can be submitted with appropriate documentation for consideration
by the permitting authority. A site-specific monitoring plan, when
approved, would provide alternate monitoring procedures and parameter
levels for secondary aluminum processing units, emission units and
combinations of emission units. Performance testing requirements,
discussed in section IV. E. of this preamble, are proposed to ensure
that each affected source is capable of meeting the applicable emission
standards for HAP or HAP surrogates. Operating requirements are
proposed to ensure that affected sources continuously meet these
emission standards. Monitoring requirements are proposed to ensure that
each owner or operator can demonstrate that the operating requirements
have been met.
1. Operating and Monitoring Requirements and Options for Affected
Sources and Emission Units
Owners or operators of affected sources would be required to submit
an O, M, & M plan as part of their applications for a part 70 or part
71 permit. The plan would include procedures for the proper operation
and maintenance of affected sources and control devices used to comply
with the emission limits as well as the corrective actions to be taken
when control devices or process parameters deviate from allowable
levels established during performance testing. The plan would also
identify the procedures for proper operation and maintenance of
monitoring devices including periodic calibration and verification of
accuracy.
Operating requirements. The proposed rule provides specific
operating requirements for each affected source, and for emission units
within a secondary aluminum processing unit, which are necessary to
ensure that the conditions during initial and periodic performance
tests are not changed between performance tests in such a way as to
increase emissions beyond the proposed standards. Owners or operators
of affected sources are required to operate the affected source and
controls within established parameter ranges. In addition, the proposed
operating requirements incorporate the applicable provisions of the
site-specific O, M, & M plan. These plans include specific corrective
actions to be taken to maintain emissions within acceptable levels.
Operating requirements are also proposed which specify work
practices for group 2 ``clean charge'' furnaces; require labeling of
all affected sources and emission units to facilitate compliance
assurance; specify capture system design and operating parameters for
all affected sources and emission units with add-on control devices;
restrict operation and fluxing practices conducted in group 1 sidewell
furnaces; and establish a means by which site-specific operating plans
for group 1 furnaces without add-on control devices can be developed
and approved.
Monitoring requirements. The EPA is proposing monitoring procedures
for each emission limitation proposed under the rule. The EPA is not
requiring the use of CEMs. PM CEMs have not been demonstrated for use
with affected sources and emission units in this source category. PM
CEMs, as well as HCl CEMs and THC CEMs, are substantially more
expensive than other effective monitoring methods (see docket item II-
B-24, enhanced monitoring options memo).
(a) Scrap Shredder. The proposed monitoring alternatives for scrap
shredders are COMs, bag leak detectors or daily visual emissions
testing by EPA Method 9 of appendix A to 40 CFR part 60. Continuous
opacity monitoring systems (COMs) provide a continuous indication of
fabric filter performance. These devices are presently in use on
affected sources within this source category. Bag leak detection
systems also provide a continuous indication of fabric filter
performance and are less expensive to install and operate than COMs.
Requirements for COMs and bag leak detectors are discussed in section
IV.D.2 of this document, Operating and Monitoring Requirements and
Options for Affected Sources and Emission Units Equipped with Fabric
Filters or Lime Injected Fabric Filters.
Under the visible emission monitoring option, a certified observer
would perform daily visible emissions observations (five 6-minute
readings in a 30-minute period) for each fabric filter according to the
requirements of Method 9 of appendix A to 40 CFR part 60 and the
general provisions in subpart A of 40 CFR part 63. If any visible
emissions were observed, the owner or operator would be required to
initiate corrective actions in accordance with the O, M, & M plan
within 1-hour to correct the cause of the emissions. Visual emissions
monitoring by Method 9 is an appropriate monitoring option for scrap
shredders because these affected sources are intermittently operated
and Method 9 can be used to determine opacity during periods of
operation.
(b) Chip Dryer. Monitoring requirements for chip dryers under the
proposed NESHAP include feed/charge weight monitoring as discussed in
section IV.D.3 of this document, Other Operating Requirements,
Monitoring Systems and Procedures: Feed/Charge Weight, afterburner
temperature monitoring as discussed in section V.D.3 of this document,
Other Operating Requirements, Monitoring Systems and Procedures:
Afterburner Operating Temperature. The identity (i.e. uncoated,
unpainted aluminum chips) of each batch of material charged must be
recorded to ensure compliance with the requirement to process only
uncoated, unpainted aluminum chips.
(c) Scrap Dryer/delacquering kiln/decoating kiln.
Monitoring requirements for scrap dryers/delacquering kilns/
decoating kilns under the proposed NESHAP include feed/charge weight
monitoring as discussed in section IV.D.3 of this document, Other
Operating Requirements, Monitoring Systems and Procedures: Feed/Charge
Weight, afterburner temperature monitoring as discussed in section
IV.D.3 of this document, Other Operating Requirements, Monitoring
Systems and Procedures: Afterburner Operating Temperature, and fabric
filter
[[Page 6983]]
monitoring as discussed in section IV.D.2 of this document, Operating
and Monitoring Requirements and Options for Process Units Equipped with
Fabric Filters or Lime-injected Fabric Filters.
(d) Clean Charge (Group 2) Furnace. Monitoring requirements for
clean charge (group 2) furnaces under the proposed NESHAP are charge
makeup and flux identity recordkeeping, and periodic certification that
only clean charge has been processed and that no reactive flux has been
used. No numerical emission limits are proposed for clean charge
furnaces as discussed in section D.2. of this document, Selection of
MACT Floor Technologies: Group 2 furnaces. Recordkeeping and
certification requirements are necessary to ensure that the affected
sources are operating as clean charge (group 2) furnaces.
(e) Sweat Furnace. The monitoring requirement for sweat furnaces
under the proposed NESHAP is afterburner temperature monitoring as
discussed in section IV.D.3 of this document, Other Operating
Requirements, Monitoring Systems and Procedures: Afterburner Operating
Temperature.
(f) Dross-only Furnace. Monitoring requirements for dross-only
furnaces under the proposed NESHAP include feed/charge recordkeeping as
described in section IV.D.3 of this document, Other Operating
Requirements, Monitoring Systems and Procedures: Feed/Charge Weight,
and fabric filter monitoring, (bag leak detection systems or COMs) as
discussed in section IV.D.2 of this document, Operating and Monitoring
Requirements and Options for Process Units Equipped with Fabric Filters
and Lime-injected Fabric Filters.
(g) In-line Fluxer. Monitoring requirements for in-line fluxers
under the proposed NESHAP include feed/charge weight monitoring as
discussed in section IV.D.3 of this document, Other Operating
Requirements, Monitoring Systems and Procedures: Feed/Charge Weight,
monitoring of chlorine injection rate as described in section IV.D.3 of
this document, Other Operating Requirements, Monitoring Systems and
Procedures: Total reactive chlorine flux injection rate and schedule,
and, for in-line fluxers equipped with add-on control devices, fabric
filter monitoring as discussed in section IV.D.2 of this document,
Operating and Monitoring Requirements and Options for Process Units
Equipped with Fabric Filters and Lime-injected Fabric Filters.
(h) Rotary Dross Cooler. Monitoring requirements for rotary dross
coolers are to comply with one of two monitoring options to demonstrate
continuous compliance with the PM standard. These options (bag leak
detection systems or COMs), and the applicable monitoring requirements,
are discussed in section IV.D.2 of this document, Operating and
Monitoring Requirements and Options for Process Units Equipped with
Fabric Filters and Lime-injected Fabric Filters.
(i) Group 1 Furnace With Add-on Controls. Monitoring requirements
for group 1 furnaces with add-on controls under the proposed NESHAP
include feed/charge weight monitoring as discussed in section IV.D.3 of
this document, Other Operating Requirements, Monitoring Systems and
Procedures: Feed/Charge Weight, monitoring of chlorine injection rate
as described in section IV.D.3 of this document, Other Monitoring
Systems and Procedures: Total reactive chlorine flux injection rate and
schedule, and fabric filter monitoring as discussed in section IV.D.2
of this document, Operating and Monitoring Requirements and Options for
Process Units Equipped with Fabric Filters and Lime-injected Fabric
Filters.
(j) Group 1 Furnace Without Add-on Controls and Using Pollution
Prevention/Work Practices (Processing Only Clean Charge). Monitoring
requirements for group 1 furnaces without add-on controls (processing
only clean charge) and employing pollution prevention/work practices to
limit emissions under the proposed NESHAP include feed/charge weight
monitoring as discussed in section IV.D.3 of this document, Other
Operating Requirements, Monitoring Systems and Procedures: Feed/Charge
Weight, monitoring of chlorine injection rate as described in section
IV.D.3 of this document, Other Operating Requirements, Monitoring
Systems and Procedures: Total reactive chlorine flux injection rate and
schedule and a semi-annual certification that only clean charge had
been processed.
(k) Group 1 Furnace Without Add-on Controls Using Pollution
Prevention/Work Practices Processing Scrap Other Than Clean Charge.
Proposed monitoring requirements for group 1 furnaces not equipped add-
on controls using pollution prevention/work practices and processing
scrap other than clean charge include feed/charge weight monitoring as
discussed in section IV.D.3 of this document, Other Operating
Requirements, Monitoring Systems and Procedures: Feed/Charge Weight and
monitoring of chlorine injection rate as described in section IV.D.3 of
this document, Other Operating Requirements, Monitoring Systems and
Procedures: Total reactive chlorine flux injection rate and schedule.
Operators of these furnaces would be required to develop a site-
specific monitoring plan acceptable to the permitting authority. The
plan would include additional parameters to be monitored, based on
supporting information provided by the operator and developed in
coordination with the permitting authority, which demonstrates the
correlation between these parameters and the actual emissions from
these furnaces.
If the site-specific monitoring plan includes scrap sampling as a
means of monitoring, the scrap sampling program must, at a minimum,
include the elements described in section IV.D.3 of this document,
Other Operating Requirements, Monitoring Systems and Procedures: Scrap
inspection program. If the site-specific monitoring plan includes the
use of CEMs, the operator must install, operate and maintain the CEMs
as described in section IV.D.3 of this document, Other Operating
Requirements, Monitoring Systems and Procedures: Continuous emission
monitoring systems. If the site-specific monitoring plan includes
limitations on the chlorine injection rate, the operator must monitor
reactive flux injection as described in section IV.D.3 of this
document, Other Operating Requirements, Monitoring Systems and
Procedures: Total reactive chlorine flux injection rate and schedule.
The specific parameters monitored under a site-specific monitoring plan
must be proposed by the owner or operator along with supporting
documentation and approved by the permitting authority.
(l) Secondary Aluminum Processing Units. All of the existing group
1 furnaces and all of the existing in-line fluxers within a facility
make up the secondary aluminum processing unit. Each g
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