secondary aluminum production industry maximum achievable control technology (mact) training 40 cfr...

Secondary AluminumProduction Industry

Maximum Achievable Control Technology

(MACT) Training

40 CFR Part 63 Subpart RRR

Secondary aluminum plants Secondary aluminum plants recover aluminum from scrap recover aluminum from scrap such as beverage cans, such as beverage cans, foundry returns, other foundry returns, other aluminum scrap, and dross. aluminum scrap, and dross. Air toxics are released from Air toxics are released from preprocessing operationspreprocessing operations

such assuch as aluminum scrap aluminum scrap shredding, thermal chip shredding, thermal chip drying, scrap drying, scrap drying/decoating/ drying/decoating/ delacquering; and furnace delacquering; and furnace operations (i.e., melting, operations (i.e., melting, holding, refining, fluxing, or holding, refining, fluxing, or alloying). alloying).

Secondary Aluminum Secondary Aluminum Production FacilityProduction Facility

Any establishment using clean Any establishment using clean charge, post-consumer charge, post-consumer aluminum scrap, aluminum aluminum scrap, aluminum ingots, aluminum foundry ingots, aluminum foundry returns, dross from returns, dross from

aluminum production, or aluminum production, or molten aluminum as the raw molten aluminum as the raw material and performing one material and performing one or more of the following or more of the following processes:processes:

• Scrap shreddingScrap shredding• Scrap Scrap drying/delacquering/decoatingdrying/delacquering/decoating• Thermal chip dryingThermal chip drying• Furnace operationsFurnace operations• In-line fluxingIn-line fluxing• Dross coolingDross cooling

Charge Melting Well Furnace (Sidewell) Hearth

Fabric Filter

Bla

ckD

ross

Wh

iteD

ross

Degassing

(N2, Cl, CO)

Salt Flux

Holding Furnace

(NaCl, KCl, Cryolite)

IngotCasting

DelacqueringKiln

ShreddedScrap

Afterburner

MoltenAluminum

Wh

iteD

ross

Nat. Gasor Fuel Oil

Feedstock

Solid Scrap

AlloyAgents

E1 E2

E3

XYZ AluminumCompany

Delacquering Kiln Feed RateShredded Scrap - 10 tons/hr

Reverb Furnace Feed RateScrap - 10 tons/hr

Holding Furnace Feed RateMolten Aluminum - 9.5 tons/hr

Fabric Filter

E4Lime

Example Secondary Example Secondary Aluminum FacilityAluminum Facility

Secondary Aluminum Secondary Aluminum SectorsSectors

• • Secondary aluminum companiesSecondary aluminum companies

• • Sweat furnace operatorsSweat furnace operators

• • May include die casters & May include die casters & foundriesfoundries

Estimated Number of Estimated Number of Secondary Aluminum Secondary Aluminum

Sources Potentially AffectedSources Potentially Affected

• • Approximately 400 (86 major)Approximately 400 (86 major)• • 320 die casting companies320 die casting companies• • 1500 foundries1500 foundries• • 1650 sweat furnaces1650 sweat furnaces

Types of Hazardous Air Types of Hazardous Air Pollutants (HAP’s) Pollutants (HAP’s)

EmittedEmitted

• • Organic HAP’s (e.g. benzene,Organic HAP’s (e.g. benzene, styrene, dioxins, and furans)styrene, dioxins, and furans)

• Inorganic gaseous HAP’s (e.g. Inorganic gaseous HAP’s (e.g. hydrogen chloride, hydrogen hydrogen chloride, hydrogen flouride, and chlorine)flouride, and chlorine)

• Particulate HAP metals (e.g. Particulate HAP metals (e.g. arsenic, lead, and chromium)arsenic, lead, and chromium)

History of Secondary History of Secondary Aluminum Production Aluminum Production

National Emission Standards National Emission Standards for Hazardous Air Pollutants for Hazardous Air Pollutants

(NESHAP)(NESHAP)• NESHAP was proposed, 2/11/99NESHAP was proposed, 2/11/99

History Cont’d.:History Cont’d.:

• Final rule was promulgated, Final rule was promulgated, 3/23/003/23/00

• Direct final rule; amendments, Direct final rule; amendments, 6/14/026/14/02

• Final rule; amendments, 9/24/02Final rule; amendments, 9/24/02• Final rule amendments 12/30/03Final rule amendments 12/30/03

Regulated Entities under Regulated Entities under Current RuleCurrent Rule

• Facilities that perform Facilities that perform secondary smelting and secondary smelting and alloying of aluminumalloying of aluminum

• Secondary aluminum Secondary aluminum production facility affected production facility affected sources collocated at: sources collocated at:

•Aluminum sheet, plate, and Aluminum sheet, plate, and foil manufacturing facilitiesfoil manufacturing facilities

•Aluminum extruded Aluminum extruded product manufacturing product manufacturing facilitiesfacilities

•Other aluminum rolling and Other aluminum rolling and drawing facilitiesdrawing facilities

•Primary aluminum Primary aluminum production facilitiesproduction facilities

•Aluminum die casting Aluminum die casting facilitiesfacilities

•Aluminum foundry facilities Aluminum foundry facilities

Regulated HAPsRegulated HAPs

• Particulate matter emissions Particulate matter emissions (PM) (surrogate for HAP (PM) (surrogate for HAP metals)metals)

• Total hydrocarbon (THC) Total hydrocarbon (THC) emissions - surrogate for HAP emissions - surrogate for HAP organics)organics)

• Hydrogen chloride (HCl) Hydrogen chloride (HCl) emissions - a HAP and a emissions - a HAP and a surrogate for inorganic HAP’s surrogate for inorganic HAP’s including hydrogen fluoride including hydrogen fluoride (HF) and chlorine (Cl(HF) and chlorine (Cl22))

• Dioxin and furan emissions at Dioxin and furan emissions at secondary aluminum secondary aluminum production facilities that are production facilities that are major or area sourcesmajor or area sources

Projected Environmental Projected Environmental BenefitsBenefits

• Reduce HAP emissions by about Reduce HAP emissions by about 12,420 tons/year, a 70% 12,420 tons/year, a 70% reduction from current levelsreduction from current levels

• Reduce HCl emissions by 12,370 Reduce HCl emissions by 12,370 tons/year, a 73% reductiontons/year, a 73% reduction

Projected Environmental Projected Environmental Benefits Benefits

(Continued)(Continued)

• Reduce metal emissions by 40 Reduce metal emissions by 40 tons/year, a 60% reductiontons/year, a 60% reduction

• Reduce dioxin/furan emissions Reduce dioxin/furan emissions by 0.88 pounds/year, a 79% by 0.88 pounds/year, a 79% reductionreduction

Projected Environmental Projected Environmental Benefits Benefits

(Continued)(Continued)

• Reduce polycyclic organic Reduce polycyclic organic matter emissions by 10 matter emissions by 10 tons/year, a 25% reductiontons/year, a 25% reduction

• Reduce PM emissions by 3,185 Reduce PM emissions by 3,185 tons/year, a 30% reductiontons/year, a 30% reduction

Rule RequirementsRule Requirements

• Emission standards and Emission standards and operating requirementsoperating requirements

• Monitoring and compliance Monitoring and compliance provisionsprovisions

• Notifications, reports, and Notifications, reports, and recordsrecords

Applicability and Applicability and Description of Affected Description of Affected

UnitsUnits§63.1500§63.1500

Applicability and Description Applicability and Description of Affected Unitsof Affected Units

• • Secondary aluminum Secondary aluminum productionproduction

operationsoperations

• • Affected sourcesAffected sourcesSecondary Aluminum Website:Secondary Aluminum Website:

http://www.epa.gov/ttn/uatw/http://www.epa.gov/ttn/uatw/alum2nd.htmlalum2nd.html

Secondary Secondary Aluminum Aluminum NESHAPS NESHAPS

Applicability Applicability FlowchartsFlowcharts

Secondary Aluminum Secondary Aluminum Production OperationsProduction Operations

• • Preprocessing of scrap aluminum Preprocessing of scrap aluminum (size reduction, removal of oils, (size reduction, removal of oils, coatings, and other contaminants)coatings, and other contaminants)

• Furnace operations (melting, Furnace operations (melting, in-furnace fluxing/refining, in-furnace fluxing/refining, tapping)tapping)

• Additional refining (in-line Additional refining (in-line fluxing)fluxing)

• Cooling of drossCooling of dross

Processing of Scrap Processing of Scrap AluminumAluminum

• • Crushing, shredding, and Crushing, shredding, and

grindinggrinding

• • DryingDrying

• • Heating in a dryer or kilnHeating in a dryer or kiln

• • Heating in a sweat furnaceHeating in a sweat furnace

Crushing, Shredding, Crushing, Shredding, and Grindingand Grinding

• To reduce the size of scrap To reduce the size of scrap

aluminumaluminum

• Emissions: Particulate matter Emissions: Particulate matter

(PM)(PM)

and HAP metals generated as and HAP metals generated as

dustdust

from coatings & other from coatings & other

contaminantscontaminants

Chip DryersChip Dryers

• To reduce the size of scrap To reduce the size of scrap

aluminumaluminum

• Emissions: Particulate matter Emissions: Particulate matter

(PM)(PM)

& HAP metals generated as dust & HAP metals generated as dust

fromfrom

coatings and other contaminantscoatings and other contaminants

Applicability and Applicability and Description of Affected Description of Affected

UnitsUnits

• • Secondary aluminum Secondary aluminum production operationsproduction operations

• Affected sourcesAffected sources

Secondary Aluminum Secondary Aluminum Production OperationsProduction Operations

• Preprocessing of scrap Preprocessing of scrap aluminum (size reduction, aluminum (size reduction, removal of oils, coatings, and removal of oils, coatings, and other contaminants)other contaminants)

• Furnace operations (melting, Furnace operations (melting, in-furnace fluxing/refining, in-furnace fluxing/refining, tapping)tapping)

• • Additional refining (in-line Additional refining (in-line fluxing)fluxing)

• • Cooling of drossCooling of dross

Preprocessing of Scrap Preprocessing of Scrap AluminumAluminum

• Crushing, shredding, and Crushing, shredding, and grindinggrinding

• DryingDrying

• Heating in a dryer or kilnHeating in a dryer or kiln

• Heating in a sweat furnaceHeating in a sweat furnace

Crushing, Shredding, and Crushing, Shredding, and GrindingGrinding

• TTo reduce the size of scrap o reduce the size of scrap aluminumaluminum

• Emissions: Particulate matter Emissions: Particulate matter (PM) and HAP metals generated (PM) and HAP metals generated as dust from coatings and other as dust from coatings and other contaminantscontaminants

Chip DryersChip Dryers

• Evaporates oil and moisture from Evaporates oil and moisture from uncoated aluminum chips & boringsuncoated aluminum chips & borings

• Generally operate at temperatures Generally operate at temperatures ranging between 300ranging between 300ooF to 750F to 750ooFF

• Emissions: Organic HAP’s including Emissions: Organic HAP’s including dioxins and furansdioxins and furans

Scrap Dryers/Delacquering Scrap Dryers/Delacquering Kilns/Decoating KilnsKilns/Decoating Kilns

• Remove coatings and other Remove coatings and other contaminants that may be present contaminants that may be present in scrap prior to melting (e.g., oil, in scrap prior to melting (e.g., oil, grease, lubricants, lacquers, grease, lubricants, lacquers, rubber, and plastic laminates) rubber, and plastic laminates)

• Heat scrap to exit temperature of Heat scrap to exit temperature of 1000 1000 °°FF

• • Emissions: Inorganic HAP’s Emissions: Inorganic HAP’s including particulate metal HAP’s including particulate metal HAP’s and hydrogen chloride and and hydrogen chloride and organic HAP’s including dioxins organic HAP’s including dioxins and furansand furans

Charging End of Delacquering Charging End of Delacquering KilnsKilns

Discharge End of Delacquering KilnsDischarge End of Delacquering Kilns

Sweat FurnacesSweat Furnaces

• Reclaim aluminum from scrap Reclaim aluminum from scrap with high levels of ironwith high levels of iron

• Operate in batch mode at a Operate in batch mode at a temperature high enough to temperature high enough to melt the aluminum but not the melt the aluminum but not the ironiron

• Molten aluminum can be cast Molten aluminum can be cast into sows, ingots, or T-bars into sows, ingots, or T-bars used as feedstock for melting used as feedstock for melting and refining furnacesand refining furnaces

• Emissions: Dioxins and furansEmissions: Dioxins and furans

Sweat Furnace ChargingSweat Furnace Charging

Sweat FurnaceSweat Furnace

Uncontrolled Sweat Furnace 1Uncontrolled Sweat Furnace 1

Uncontrolled Sweat Furnace 2Uncontrolled Sweat Furnace 2

Furnace OperationsFurnace Operations

• MeltingMelting

• Fluxing/refiningFluxing/refining

• TappingTapping

MeltingMelting

• • Begins with charging of scrap Begins with charging of scrap into furnaceinto furnace

• Chemistry of molten bath Chemistry of molten bath

adjusted by adding selected adjusted by adding selected scrap or alloying agents (e.g., scrap or alloying agents (e.g., silicon)silicon)

Charging Sidewell FurnaceCharging Sidewell Furnace

FluxingFluxing

• Done to refine molten Done to refine molten aluminum to improve product aluminum to improve product quality, achieve product quality, achieve product specifications, or reduce specifications, or reduce material lossmaterial loss

• Fluxes may be added to Fluxes may be added to remove impurities and remove impurities and reduce aluminum oxidationreduce aluminum oxidation

• May be performed in the May be performed in the furnace or outside the furnace or outside the furnace by an in-line fluxerfurnace by an in-line fluxer

Fluxing ProcessesFluxing Processes

• Addition of salts (cover flux)Addition of salts (cover flux)

• Addition of solventsAddition of solvents

• Injection of gasses Injection of gasses (demagging and degassing)(demagging and degassing)

Process FurnacesProcess Furnaces

• Refractory-lined metal Refractory-lined metal vessels heated by oil, gas, or vessels heated by oil, gas, or electricity that are used to electricity that are used to melt scrapmelt scrap

• Types include melting, Types include melting, holding, and refining holding, and refining furnacesfurnaces

• Charging of scrap can be Charging of scrap can be done from the side, front, or done from the side, front, or top of the furnacetop of the furnace

Examples of Process Examples of Process FurnacesFurnaces

• Top charging and front Top charging and front charging furnacescharging furnaces

• Sidewell melting furnace – a Sidewell melting furnace – a furnace with an open well furnace with an open well adjacent to the hearth used adjacent to the hearth used for charging scrap & solid flux for charging scrap & solid flux or salt to the furnace, or salt to the furnace, injecting fluxing agents, & injecting fluxing agents, & skimming drossskimming dross

Transferring Molten Aluminum Transferring Molten Aluminum to Holding Furnaceto Holding Furnace

Sidewell FurnaceSidewell Furnace

Examples of Process Furnaces - Examples of Process Furnaces - ContinuedContinued

• Induction furnaces – heating Induction furnaces – heating mechanism is electric energymechanism is electric energy

• Reverberatory furnaces – typically Reverberatory furnaces – typically gasgas

Process Furnace Process Furnace EmissionsEmissions

• HAP emissions from scrap and HAP emissions from scrap and fluxing agents include:fluxing agents include:

• • Particulate metal HAPsParticulate metal HAPs• Hydrogen chlorideHydrogen chloride• Dioxins and furansDioxins and furans

Dross-only FurnacesDross-only Furnaces

• Typically rotary barrel-Typically rotary barrel-designed furnaces dedicated designed furnaces dedicated to reclamation of aluminum to reclamation of aluminum from dross formed during from dross formed during melting, holding, alloying, or melting, holding, alloying, or fluxing operations carried out fluxing operations carried out in other process unitsin other process units

Dross-only Furnaces Cont’d.Dross-only Furnaces Cont’d.

• Dross and salt flux are sole Dross and salt flux are sole feedstocksfeedstocks

• Emissions: Particulate matter Emissions: Particulate matter including metal HAPsincluding metal HAPs

In-line FluxingIn-line Fluxing

• Fluxing performed in a device Fluxing performed in a device exterior to furnace, located in exterior to furnace, located in a transfer line from furnacea transfer line from furnace

• Involves injection of chlorine, Involves injection of chlorine, argon, nitrogen, or other argon, nitrogen, or other gases to achieve desired gases to achieve desired metal puritymetal purity

In-line Fluxing - ContinuedIn-line Fluxing - Continued

• Found primarily at facilities Found primarily at facilities that manufacture high quality that manufacture high quality aluminum or in facilities with aluminum or in facilities with no other means of degassingno other means of degassing

• Emissions: Hydrogen chloride Emissions: Hydrogen chloride and particulate matterand particulate matter

TappingTapping

• Transferring molten metal Transferring molten metal from melting furnace to from melting furnace to molds or to a ladlemolds or to a ladle

Cooling of DrossCooling of Dross

• ““Dross” - slags and skimmings Dross” - slags and skimmings from melting and refining from melting and refining consisting of fluxing agents, consisting of fluxing agents, impurities, and/or oxidized and impurities, and/or oxidized and non-oxidized aluminumnon-oxidized aluminum

Cooling of Dross - Cooling of Dross - ContinuedContinued

• Accomplished in rotating, Accomplished in rotating, water-cooled drumswater-cooled drums

• Sole feedstock to dross-only Sole feedstock to dross-only furnacesfurnaces

• Emissions: Particulate matter Emissions: Particulate matter including metal HAPsincluding metal HAPs

Rotary Dross CoolerRotary Dross Cooler

Affected Sources at Affected Sources at MajorMajor Sources of HAP’s - Sources of HAP’s -

§63.1500§63.1500• Each new and existing:Each new and existing:

– Aluminum scrap shredderAluminum scrap shredder– Thermal chip dryerThermal chip dryer– Scrap dryer/delacquering Scrap dryer/delacquering

kiln/decoating kilnkiln/decoating kiln

• Each new and existing group 2 Each new and existing group 2 furnace:furnace:– Melts, holds, or processes only Melts, holds, or processes only

clean chargeclean charge, and , and – Performs Performs nono fluxing, or fluxing, or – Performs fluxing using only Performs fluxing using only non-non-

reactive, non-HAP-containing/non-reactive, non-HAP-containing/non-HAP-generating gases or agentsHAP-generating gases or agents

• Each new and existing: Each new and existing: – Sweat furnaceSweat furnace– Dross-only furnaceDross-only furnace– Rotary dross coolerRotary dross cooler

• Each new and existing Each new and existing secondary aluminum secondary aluminum processing unit (SAPU)processing unit (SAPU)– Group 1 furnace: processes Group 1 furnace: processes

non-clean charge; or non-clean charge; or processes clean charge processes clean charge withwith reactive fluxingreactive fluxing

– Combination of all group 1 Combination of all group 1 furnaces and all in-line furnaces and all in-line fluxers within a secondary fluxers within a secondary aluminum production facilityaluminum production facility

Secondary Aluminum Secondary Aluminum Processing Units (SAPU)Processing Units (SAPU)

• Existing SAPU – all existing Existing SAPU – all existing group 1 furnaces and all group 1 furnaces and all existing in-line fluxers existing in-line fluxers

• New SAPU – any combination of New SAPU – any combination of new group 1 furnaces and new in-new group 1 furnaces and new in-line fluxers constructed after line fluxers constructed after 2/11/992/11/99

• Group 1 furnaces and in-line Group 1 furnaces and in-line fluxers are fluxers are emission unitsemission units within within an existing or new SAPUan existing or new SAPU

Affected Sources at Affected Sources at AreaArea Sources of HAPsSources of HAPs

• Emission limits for Emission limits for dioxins and dioxins and furansfurans and associated and associated operating, monitoring, operating, monitoring, reporting, and recordkeeping reporting, and recordkeeping requirements apply to affected requirements apply to affected sources located at area sourcessources located at area sources

Affected Sources at Affected Sources at AreaArea Sources of HAPs Cont’d.Sources of HAPs Cont’d.

• Each new and existing:Each new and existing:– Thermal chip dryerThermal chip dryer– Scrap dryer/delacquering Scrap dryer/delacquering

kiln/decoating kilnkiln/decoating kiln

Affected Sources at Affected Sources at AreaArea Sources of HAPs Cont’d.Sources of HAPs Cont’d.

– Sweat furnaceSweat furnace– SAPUSAPU with one or more with one or more

group 1 furnace emission group 1 furnace emission units processing other than units processing other than clean chargeclean charge

Affected SourcesAffected Sources

• Does not include aluminum die Does not include aluminum die casters, foundries, or extruders casters, foundries, or extruders that:that:– Melt only Melt only clean chargeclean charge and materials and materials

generated within the facility or generated within the facility or returned clean materials originally returned clean materials originally from facility, andfrom facility, and

Affected Sources Cont’d.Affected Sources Cont’d.

– Do not operate a thermal Do not operate a thermal chip dryer, sweat furnace, chip dryer, sweat furnace, or scrap dryer/delacquering or scrap dryer/delacquering kiln/decoating kiln kiln/decoating kiln

Clean ChargeClean Charge

• Molten aluminumMolten aluminum• T-bar, sow, ingot, billet, pigT-bar, sow, ingot, billet, pig• Alloying elementsAlloying elements• Uncoated/unpainted thermally Uncoated/unpainted thermally

dried chipsdried chips

Clean Charge - continuedClean Charge - continued

• Scrap dried at Scrap dried at ≥ ≥ 650 650 °°FF• Scrap delacquered/decoated Scrap delacquered/decoated

at at ≥ 900≥ 900°° F F• oil-, lubricant-free oil-, lubricant-free

unpainted/uncoated gates unpainted/uncoated gates and risersand risers

Clean Charge - continuedClean Charge - continued

• Oil- & lubricant-free Oil- & lubricant-free unpainted/uncoated scrap, unpainted/uncoated scrap, shapes, or products that have not shapes, or products that have not been processed in such a way that been processed in such a way that causes contaminationcauses contamination

Clean Charge - Clean Charge - continuedcontinued

• Runaround scrapRunaround scrap• Customer returns (clean material Customer returns (clean material

which contain no paint or other which contain no paint or other solid coatings) solid coatings)

Runaround ScrapRunaround Scrap

• Scrap generated on-site or Scrap generated on-site or returned that does not contain returned that does not contain paint or solid coatingpaint or solid coating

• Machining chips that have not Machining chips that have not been dried been dried ≥650≥650°° F, or by F, or by equivalent non-thermal drying equivalent non-thermal drying method, are method, are notnot runaround runaround

Emission Standards Emission Standards and Operating and Operating Requirements Requirements

§63.1505 and §63.1506§63.1505 and §63.1506

Emission Standards and Emission Standards and Operating RequirementsOperating Requirements

Emission StandardsEmission Standards

§63.1505§63.1505

Secondary Aluminum Website:Secondary Aluminum Website:www.epa.gov/ttn/uatw/alum2nd/require/www.epa.gov/ttn/uatw/alum2nd/require/

requirement_tables.htmlrequirement_tables.html

Pollutants RegulatedPollutants Regulated

• PM – surrogate for particulate metal HAPsPM – surrogate for particulate metal HAPs

• THC – surrogate for gaseous organic HAPsTHC – surrogate for gaseous organic HAPs

• D/F – limits apply to a major or area D/F – limits apply to a major or area sourcesource

• HCl – HAP & surrogate for chlorine & HFHCl – HAP & surrogate for chlorine & HF

• OpacityOpacity

Format of Emission Format of Emission StandardStandard

• Emission limitsEmission limits•Mass per unit (lb/ton) of Mass per unit (lb/ton) of feed/charge (or feed/charge (or production)production)

•Concentration (gr/dscf)Concentration (gr/dscf)•Percentage reductionPercentage reduction

Format of Emission Format of Emission Standard - ContinuedStandard - Continued

• Emission limitsEmission limits•D/F in units of TEQD/F in units of TEQ•International method of International method of expressing toxicity expressing toxicity equivalents for D/Fequivalents for D/F

Format of Emission Format of Emission Standard - ContinuedStandard - Continued

• Except for D/F, apply to major Except for D/F, apply to major sources onlysources only

• Apply to all new and existing Apply to all new and existing affected sources and emission affected sources and emission unitsunits

Opacity LimitOpacity Limit

• Sources with a PM add-on air Sources with a PM add-on air pollution control device -- pollution control device -- monitored with a continuous monitored with a continuous opacity monitor (COM)opacity monitor (COM)

Opacity Limit Cont’d.Opacity Limit Cont’d.

• Aluminum scrap shredders Aluminum scrap shredders monitored with a COM, or monitored with a COM, or monitored by visible monitored by visible emissions:emissions:

• • Opacity limit = 10 percentOpacity limit = 10 percent

Aluminum Scrap Aluminum Scrap ShreddersShredders

• 0.010 grain (gr) of PM per 0.010 grain (gr) of PM per dry standard cubic foot dry standard cubic foot (dscf)(dscf)

Thermal Chip DryersThermal Chip Dryers

• 0.80 lb of total hydrocarbon 0.80 lb of total hydrocarbon emissions (THC) per ton of feedemissions (THC) per ton of feed

• 2.50 micrograms of dioxins and 2.50 micrograms of dioxins and furans (D/F) toxicity furans (D/F) toxicity equivalents (TEQ) per equivalents (TEQ) per megagram (Mg) of feedmegagram (Mg) of feed

Thermal Chip Dryers Thermal Chip Dryers Cont’d.Cont’d.

• D/F limit for units at major or D/F limit for units at major or area sourcesarea sources

Scrap Dryers/Delacquering Scrap Dryers/Delacquering Kilns/Decoating KilnsKilns/Decoating Kilns

• 0.08 lb PM per ton of feed0.08 lb PM per ton of feed

• 0.80 lb HCl per ton of feed0.80 lb HCl per ton of feed

• 0.06 lb THC per ton of feed0.06 lb THC per ton of feed

• 0.25 micrograms of D/F TEQ per 0.25 micrograms of D/F TEQ per

Mg of feedMg of feed

Scrap Dryers/Delacquering Scrap Dryers/Delacquering Kilns/Decoating Kilns – Kilns/Decoating Kilns –

Alternate LimitAlternate Limit• Applies if afterburner has a Applies if afterburner has a

design residence time design residence time ≥≥ 1 1 second, and operates at a second, and operates at a temperature temperature ≥≥ 1400 1400ooFF

• 0.30 lb PM per ton of feed0.30 lb PM per ton of feed

Scrap Dryers/Delacquering Scrap Dryers/Delacquering Kilns/Decoating Kilns – Kilns/Decoating Kilns – Alternate Limit Cont’d.Alternate Limit Cont’d.

• 1.50 lb HCl per ton of feed1.50 lb HCl per ton of feed• 0.20 lb THC per ton of feed0.20 lb THC per ton of feed• 5.0 micrograms D/F TEQ per 5.0 micrograms D/F TEQ per

Mg of feedMg of feed

Sweat FurnacesSweat Furnaces

• 0.80 nanograms D/F TEQ per dry 0.80 nanograms D/F TEQ per dry standard cubic meter (dscm) at 11 standard cubic meter (dscm) at 11 percent oxygenpercent oxygen

• No test required if sweat furnace No test required if sweat furnace has afterburner with design has afterburner with design residence timeresidence time

≥≥ 2 seconds and operates at 2 seconds and operates at ≥≥ 16001600ooF F

Dross-only FurnacesDross-only Furnaces

• 0.30 lb PM per ton of feed0.30 lb PM per ton of feed

In-line FluxersIn-line Fluxers

• Limits are used to calculate Limits are used to calculate the standard applicable to the standard applicable to secondary aluminum secondary aluminum processing units (SAPU)processing units (SAPU)

• 0.04 lb HCl per ton of feed0.04 lb HCl per ton of feed• 0.01 lb PM per ton of feed0.01 lb PM per ton of feed

In-line Fluxers With No In-line Fluxers With No Reactive FluxingReactive Fluxing

• No HCl and PM limits applyNo HCl and PM limits apply

• Work practice – no reactive Work practice – no reactive

fluxingfluxing

Rotary Dross CoolersRotary Dross Coolers

• 0.04 gr of PM per dscf0.04 gr of PM per dscf

Clean Furnaces (Group 2)Clean Furnaces (Group 2)

• No emission limitsNo emission limits

• Work practices – clean charge Work practices – clean charge only and no reactive fluxing – only and no reactive fluxing – or elseor else

Group 1 Melting/Holding Group 1 Melting/Holding Furnaces (Clean Charge Furnaces (Clean Charge

Only)Only)• Limits are used to calculate Limits are used to calculate

the standard applicable to the standard applicable to secondary aluminum secondary aluminum processing units (SAPU)processing units (SAPU)

• 0.80 lb PM per ton of feed0.80 lb PM per ton of feed

Group 1 Melting/Holding Group 1 Melting/Holding Furnaces (Clean Charge Furnaces (Clean Charge

Only) – Cont’d.Only) – Cont’d.• 0.40 lb HCl per ton of feed, or 0.40 lb HCl per ton of feed, or

10 percent of the HCl upstream 10 percent of the HCl upstream of an add-on control device of an add-on control device

• No D/F limit for clean charge No D/F limit for clean charge furnaces – and only clean furnaces – and only clean charge can be usedcharge can be used

Group 1 FurnacesGroup 1 Furnaces

• Limits are used to Limits are used to calculate the standard calculate the standard applicable to secondary applicable to secondary aluminum processing aluminum processing units (SAPU)units (SAPU)

• 0.40 lb PM per ton of feed0.40 lb PM per ton of feed

Group 1 Furnaces Cont’d.Group 1 Furnaces Cont’d.

• 0.40 lb HCl per ton of feed, or 0.40 lb HCl per ton of feed, or 10 percent of the HCl 10 percent of the HCl upstream of an add-on control upstream of an add-on control devicedevice

• 15.0 micrograms of D/F TEQ 15.0 micrograms of D/F TEQ per Mg of feedper Mg of feed

Group 1 Furnaces (Clean Group 1 Furnaces (Clean Charge Only)Charge Only)

• Limits are used to calculate Limits are used to calculate the standard applicable to the standard applicable to secondary aluminum secondary aluminum processing units (SAPU)processing units (SAPU)

• 0.40 lb PM per ton of feed0.40 lb PM per ton of feed

• 0.40 lb HCl per ton of feed, or 0.40 lb HCl per ton of feed, or 10 percent of the HCl upstream 10 percent of the HCl upstream of an add-on control deviceof an add-on control device

• No limit on D/F – clean charge No limit on D/F – clean charge onlyonly

Sidewell Group 1 Sidewell Group 1 FurnaceFurnace

• If reactive fluxing (except If reactive fluxing (except cover flux) is donecover flux) is done

-- In the hearth, orIn the hearth, or-- In the sidewell when metal In the sidewell when metal level falls below top of level falls below top of passage between sidewell passage between sidewell and hearth, thenand hearth, then

Sidewell Group 1 Furnace Sidewell Group 1 Furnace Cont’d.Cont’d.

• Then, limits for sidewell Then, limits for sidewell apply for apply for combinedcombined hearth & hearth & sidewell emissionssidewell emissions

Secondary Aluminum Secondary Aluminum Processing Units (SAPU)Processing Units (SAPU)

• No 3-day, 24-hour rolling No 3-day, 24-hour rolling average emissions of PM, HCl, average emissions of PM, HCl, or D/F in excess of the or D/F in excess of the production-weighted emission production-weighted emission limit for all units in the SAPUlimit for all units in the SAPU

Secondary Aluminum Secondary Aluminum Processing Units (SAPU) Processing Units (SAPU)

Cont’d.Cont’d.• SAPU may comply by SAPU may comply by

demonstrating compliance of demonstrating compliance of each emission unit with its each emission unit with its applicable emission limitapplicable emission limit

Emission Standards Emission Standards and Operating and Operating Requirements - Requirements -

ContinuedContinuedOperating RequirementsOperating Requirements

§63.1506§63.1506

Capture/Collection Capture/Collection SystemsSystems

• All sources and emission All sources and emission units with an add-on air units with an add-on air pollution control device pollution control device (APCD): (APCD):

•Design and install a Design and install a capture and collection capture and collection system in accordance with system in accordance with American Conference of American Conference of Governmental Industrial Governmental Industrial Hygienists (ACGIH) Hygienists (ACGIH) guidelinesguidelines

• Industrial Ventilation: A Manual Industrial Ventilation: A Manual of Recommended Practiceof Recommended Practice

- Chapter 3: Local Exhaust - Chapter 3: Local Exhaust HoodsHoods

- Chapter 5: Exhaust System- Chapter 5: Exhaust System

Design ProcedureDesign Procedure

• Vent captured emissions Vent captured emissions through a closed system through a closed system (except dilution air fabric (except dilution air fabric filter temperature control)filter temperature control)

• Operate in accordance with Operate in accordance with operation, maintenance, and operation, maintenance, and monitoring (OM&M) planmonitoring (OM&M) plan

Feed/Charge Weight Feed/Charge Weight MeasurementMeasurement

• All sources and emission units All sources and emission units subject to production-based subject to production-based (lb/ton of feed) emission limits:(lb/ton of feed) emission limits:

- - Operate a device that records Operate a device that records

the weight each charge, or the weight each charge, or

production weightproduction weight

•Operate in accordance with Operate in accordance with OM&M planOM&M plan

• May use production basis May use production basis instead of feed if:instead of feed if:

• • Production is measured Production is measured for all for all

emission units within a emission units within a SAPUSAPU

•All emission limit All emission limit compliance calculations for compliance calculations for SAPUs are based on SAPUs are based on productionproduction

LabelingLabeling

• Post visible labels at each:Post visible labels at each:

- group 1 furnace- group 1 furnace

- group 2 furnace- group 2 furnace

- in-line fluxer- in-line fluxer

- scrap dryer/delacquering - scrap dryer/delacquering kiln/decoating kiln kiln/decoating kiln

• Labels identify emission limits and Labels identify emission limits and means of compliance, including:means of compliance, including:

-- Type of source or emission unitType of source or emission unit

- Applicable operational - Applicable operational standardsstandards

and control methodsand control methods

- Afterburner operating - Afterburner operating temperature temperature

and residence time and residence time

Affected Sources and Affected Sources and Emission Units with Emission Units with

Fabric FiltersFabric Filters• Scrap shreddersScrap shredders• Scrap dryer/delacquering Scrap dryer/delacquering

kiln/decoating kilnkiln/decoating kiln• Dross-only furnaceDross-only furnace• Rotary dross coolerRotary dross cooler• In-line fluxerIn-line fluxer

• Group 1 furnaceGroup 1 furnace• Must operate a bag leak detection Must operate a bag leak detection

system or continuous opacity system or continuous opacity monitormonitor

• Except scrap shredders may Except scrap shredders may alternatively choose to monitor VEalternatively choose to monitor VE

Fabric Filter with Bag Fabric Filter with Bag Leak DetectorLeak Detector

• Initiate corrective action within Initiate corrective action within 1 hour of alarm1 hour of alarm

• Follow OM&M planFollow OM&M plan• Operate so that alarm does not Operate so that alarm does not

sound more than 5% of sound more than 5% of operating time in 6-month operating time in 6-month periodperiod

Fabric Filter with COMFabric Filter with COM

• Initiate corrective action Initiate corrective action within 1 hour of a 6-minute within 1 hour of a 6-minute average opacity average opacity 5% 5%

• Complete corrective actions Complete corrective actions in accordance with OM&M in accordance with OM&M planplan

Aluminum Scrap Shredder Aluminum Scrap Shredder with Fabric Filter – VE with Fabric Filter – VE

AlternativeAlternative• Initiate corrective action Initiate corrective action

within 1 hr of any observed within 1 hr of any observed VEVE

• Complete corrective action Complete corrective action in accordance with OM&M in accordance with OM&M planplan

Thermal Chip Dryer with Thermal Chip Dryer with AfterburnerAfterburner

• Maintain average operating Maintain average operating temperature for each 3-hr temperature for each 3-hr period period average operating average operating temperature during temperature during performance testperformance test

• Operate afterburner in Operate afterburner in accordance with OM&M planaccordance with OM&M plan

• Operate dryer using only Operate dryer using only unpainted aluminum chipsunpainted aluminum chips

Scrap Scrap Dryer/Delacquering Dryer/Delacquering Kiln/Decoating Kiln Kiln/Decoating Kiln - Afterburner and - Afterburner and

Lime-injected Lime-injected Fabric FilterFabric Filter

• Maintain afterburner average Maintain afterburner average operating temperature for operating temperature for each 3-hr period each 3-hr period than than average operating average operating temperature from temperature from performance testperformance test

• Operate afterburner in Operate afterburner in accordance with OM&M planaccordance with OM&M plan

• Maintain average fabric filter Maintain average fabric filter inlet temperature for each 3-inlet temperature for each 3-hr period hr period average average temperature during temperature during performance test (+ 25performance test (+ 25ooF)F)

• For continuous lime injection For continuous lime injection systems: systems:

•Maintain free-flowing lime Maintain free-flowing lime in the hopper or silo at all in the hopper or silo at all timestimes

•Maintain lime feeder at Maintain lime feeder at setting established during setting established during performance testperformance test

Sweat Furnace with Sweat Furnace with AfterburnerAfterburner

• If performance tested, If performance tested, maintain each 3-hr. average maintain each 3-hr. average temperature temperature operating operating temperature of performance temperature of performance testtest

• If not tested, afterburner If not tested, afterburner design residence time must design residence time must be be 2 seconds and operate 2 seconds and operate at at 1600 1600ooFF

• Existing sweat furnaces must Existing sweat furnaces must meet operating requirements meet operating requirements by the compliance dateby the compliance date

• New sweat furnaces must New sweat furnaces must meet operating requirements meet operating requirements by March 23, 2000 or upon by March 23, 2000 or upon startup, whichever is laterstartup, whichever is later

• Operate in accordance withOperate in accordance with OM&M planOM&M plan

Dross-only Furnace with Dross-only Furnace with Fabric FilterFabric Filter

• Must have bag leak detector Must have bag leak detector or COMor COM

• Operate using only dross as Operate using only dross as feed materialfeed material

In-line Fluxer with Lime-In-line Fluxer with Lime-injected Fabric Filterinjected Fabric Filter

• For continuous lime injection For continuous lime injection systems:systems:

- Maintain free-flowing lime in - Maintain free-flowing lime in the the

hopper or silo at all times forhopper or silo at all times for

continuous injection systemscontinuous injection systems

- - Maintain lime feeder at setting Maintain lime feeder at setting

established during established during performance performance

testtest• Maintain reactive flux injection Maintain reactive flux injection

rate rate performance test rate for performance test rate for each operating cycle or time each operating cycle or time period used in performance testperiod used in performance test

In-line Fluxer Using No In-line Fluxer Using No Reactive Flux MaterialReactive Flux Material

• Use no reactive fluxUse no reactive flux

Group 1 Furnace with Group 1 Furnace with Lime-injected Fabric Lime-injected Fabric

FilterFilter• Maintain average fabric filter Maintain average fabric filter

inlet temperature for each 3-hr inlet temperature for each 3-hr period period average temperature average temperature during performance test (+ 25during performance test (+ 25ooF)F)

• Maintain reactive flux injection Maintain reactive flux injection rate at or below performance rate at or below performance test rate for each furnace cycletest rate for each furnace cycle

• For continuous injection systems:For continuous injection systems:

• • Maintain free-flowing lime in theMaintain free-flowing lime in the

hopper or silo at all timeshopper or silo at all times•Maintain lime feeder at setting Maintain lime feeder at setting established during performance established during performance testtest

• For sidewell furnaces:For sidewell furnaces: - - Operate so level of molten Operate so level of molten

aluminumaluminum is above the top of passage is above the top of passage

between between sidewell and hearth during sidewell and hearth during

reactivereactive flux injection, unless hearth is also flux injection, unless hearth is also controlled controlled

• For sidewell furnaces Cont’d.:For sidewell furnaces Cont’d.:

•Add reactive flux only to Add reactive flux only to sidewell of the furnace sidewell of the furnace unless the hearth is also unless the hearth is also controlledcontrolled

Group 1 Furnace Without Group 1 Furnace Without Add-on ControlsAdd-on Controls

• Maintain reactive flux Maintain reactive flux injection rate injection rate performance performance test rate for each operating test rate for each operating cycle or time period used in cycle or time period used in performance testperformance test

• Operate furnace within range Operate furnace within range of charge materials, of charge materials, contaminant levels, and contaminant levels, and parameter values established parameter values established in site-specific monitoring planin site-specific monitoring plan

• Use only clean charge Use only clean charge (melting/holding furnace)(melting/holding furnace)

Site-specific Monitoring Site-specific Monitoring PlanPlan

• For group 1 furnaces without For group 1 furnaces without control devices - OM&M plan must control devices - OM&M plan must include a section that documents include a section that documents work practices and pollution work practices and pollution prevention measures, including prevention measures, including procedures for scrap inspectionprocedures for scrap inspection

• Site-specific monitoring plan Site-specific monitoring plan and testing to demonstrate and testing to demonstrate adequacy of the monitoring adequacy of the monitoring plan must be developed in plan must be developed in coordination with, and coordination with, and approved by, the permitting approved by, the permitting authorityauthority

Clean (Group 2) FurnaceClean (Group 2) Furnace

• Use only clean chargeUse only clean charge

• Use no reactive fluxUse no reactive flux