The Secondary Aluminum NESHAP
Compliance Date HAS COME AND GONE
The compliance date for the National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Secondary Aluminum Production of March 23, 2003 has come and gone. EPA published the final version of this rule on March 23, 2000.
This NESHAP applies to secondary aluminum processing facilities (SAPF’s). A SAPF is defined as any establishment using clean scrap, post-consumer aluminum scrap, aluminum scrap, aluminum ingots, aluminum foundry returns, dross from aluminum production, or molten aluminum as the raw material and performing one or more of the following activities: scrap shredding, scrap drying/delacquering/decoating, thermal chip drying, in-line fluxing, dross cooling or furnace operations (melting, holding, refining, fluxing or alloying. Originally, EPA intended to regulate aluminum die casting facilities, aluminum foundries and aluminum extruders under the NESHAP only when they engaged in the same types of operation as other SAPF’s; however these facilities are now not considered to be SAPF’s if the only material melted is clean charge, customer returns or internal scrap, and of they do not operate sweat furnaces, thermal chip dryers or scrap dryers/delacquering kilns/decoating kilns
Owners of affected sources should have:
 | Installed the necessary controls and capture/collection systems to meet the hydrogen chloride (HCl), particulate matter (PM), total hydrocarbon (THC), dioxin and furan (D/F) and/or visible emission standards; |
| Conducted performance testing for the necessary pollutants (D/F for minor sources only) to demonstrate compliance and establish operating parameter values; |
| Implemented the operating and monitoring requirements, including labeling, control device parameter monitoring, fee/charge rate monitoring, et cetera; |
| Prepared the Operation, Maintenance and Monitoring (OM&M) Plan. The approved plan should have been submitted with the Notification of Compliance Status (NOCS) report due May 23, 2003; |
| Prepared the Startup, Shutdown and Malfunction (SSM) Plan. This plan should have also been submitted with the NOCS report due May 23, 2003. |
| Submitted the NOCS report. |
| Maintained the required records. |
Excess emission reports are to be submitted semi-annually (due August 29th for period covering January 1 through June 30 and February 28th for period covering July 1 through December 31) if any of the following conditions occurred during the reporting period:
| A corrective action specified in the OM&M Plan for a bag leak detection system or a continuous opacity monitor deviation was not initiated within an hour; |
| A corrective action for a specified in the OM&M Plan for visible emissions from an aluminum scrap shredder was not initiated within an hour; |
| An excursion of a process or operating parameter value occurred; |
| An action taken during a start-up, shutdown or malfunction was not consistent with the procedures in the SSM Plan; |
| An affected source was not operated according to the rule; |
| A deviation from the 3-day, 24-hour rolling average emission limit for a SAPU occurred. |
These reports are to be certified by the responsible official and should include 1) all required continuous monitoring system (CMS) measurements, 2) date and time when a CMS was inoperative or malfunctioning, 3) repairs or adjustments to the CMS, date, time, nature, cause and corrective action of each excess emission and parameter monitoring exceedance, 4) process operating time during reporting period.
For further information on this rule, please contact Kimberly Coy at kcoy@air-comp.com or by phone at 412-826-3636.
Author: Kimberly D. Coy, Senior Engineer
Date: 01/03/03