EPA Issues Final Rule for Secondary Aluminum NESHAP
September 29, 2015
The U.S. Environmental Protection Agency (EPA) issued the final residual risk and technology review (RTR) rule for the secondary aluminum national emission standards for hazardous air pollutants (NESHAP) on September 18 (80 Fed. Reg. 56700). EPA promulgated several revisions to improve the monitoring, compliance and implementation of the rule. In January, the AFS 10-E Environmental Committee for Air Issues submitted comments to EPA on the rule regarding specific issues impacting the metalcasting industry.
AFS had requested EPA to clarify the definition of furnace "clean charge" that is used to determine what requirements of the rule are triggered. Specifically, the comments requested that EPA clarify that the phrase in the definition of clean charge, "known by the owner or operator to be entirely free of paints, coatings, and lubricants" applies only to aluminum scrap and does not apply to charge materials such as T-bar, sow, ingot, billet, pig and alloying elements. In response, EPA did make this change to ensure the regulatory definition of "clean charge" is consistent with its current policy and guidance on this matter. This is a good victory and will allow AFS members to continue using best industry practices for introducing clean charge into secondary aluminum furnaces subject to the rule.
AFS also had requested some flexibility in the monitoring of annual air flow rate measurements because the existing regulation is too restrictive and difficult to meet consistently due to the inherent variability in flow rates and the repeatability of the measurement method. EPA did not modify the final rule as requested by AFS. EPA also rejected AFS’ request for additional flexibility in monitoring and measuring annual air flow for permanent total enclosures. Secondary aluminum furnaces subject to the rule will have to continue to maintain daily air flow measurements at or above the 90% indicator values.