Engineering Analysis
ECOVERY LLC
Loxley, Alabama
Baldwin County
501-0048
Project Description
On April 23, 2015, ECOVERY submitted an air permit application for the construction of
a new 7.5 ton Holding Furnace and a new Melting Furnace with Lime and Activated
Carbon Injected Baghouse. The facility currently holds no air permits, and is located at
26320 Railroad Avenue, Loxley, AL 36551, Baldwin County. This site is currently an
electronics recycling facility owned by ECOVERY which utilizes a 10,000 lb/hr
electronics equipment shredder. A determination was made in March 2011 that no permit
was needed for the operations at this facility.
The proposed new process would take in scrap aluminum such as beverage cans to be
conveyed to a 7.0 MMBtu oxy fuel, natural gas fired melting furnace with baghouse in
order to melt and extract the aluminum, while retaining metals with higher melting points
in the furnace. The liquid aluminum would transfer to a 7.5 ton holding furnace before
being poured into ingot molds (sows) and transported off-site. The salt-cake generated
from the process would be cooled and disposed of in a landfill.
Emission Limits
ECOVERY requests a limit of the HCl emissions from the new rotary furnace. The HCl
limit will keep the facility wide emissions for HCl under the Title V threshold of 10 TPY
for any single HAP. The HCl limit is shown below:
Emission Source
Melting Furnace
Requested Limit
lb/hr
TPY
2.17
9.5
The allowable PM emissions for the rotary melting furnace is set by the process weight
rule and is shown below:
Emission Source
Allowable PM Emissions
Rotary Melting Furnace
lb/hr
TPY
9.74
41.47
Emissions
Pouring of aluminum and cooling of the salt cake would produce fugitive emissions. The
potential facility wide fugitive emissions, based on 8760 hours of operation, are shown
below:
Pollutant
Fugitives
lb/hr
0.7
0.64
0.07
0.08
0.04
0.56
PM
PM10
PM2.5
SO2
NOx
VOC
TPY
3.07
2.80
0.31
0.35
0.18
2.45
The potential emissions from the Rotary Melting Furnace with Baghouse are based on
requested limits, EIIP Volume II, Chapter 14, A-100 emission factors, and engineering
estimates. The potential emissions based on 8,760 hours of operation are shown below:
Pollutant
Melting Furnace with Baghouse
lb/hr
TPY
9.47
41.47
9.47
41.47
5.8
25.40
14.0
61.32
2.40
10.51
9.60
42.05
2.17
9.50
2.17
9.50
-8
3.10 x 10
1.40 x 10-7
5,288
PM
PM10
PM2.5
SO2
NOX
VOC
HAPs (total)
HCL
Dioxin/Furan
CO2e*
* For melting and holding furnace
ADEM Admin. Code r. 335-3
335-3-4-.01: Visible Emissions
ADEM Admin. Code r. 335-3-4-.01 states that no person shall discharge from any source
of emission, particulate of an opacity greater than twenty percent (20%), as determined
by a six (6) minute average. ADEM 335-4-.01(b) states that during one six (6) minute
period in any sixty (60) minute period a person may discharge into the atmosphere from
any source of emissions, particulate of an opacity not greater than that designated as forty
percent (40%) opacity.
The holding furnace emissions would not be captured and, as a result, this rule would not
apply to the proposed units. The aluminum melting furnace would be subject to this rule.
335-3-4-.04: Process Industries - General
ADEM Admin. Code r. 335-3-4-.04(1) limits particulate matter (PM) emissions from any
process to that which is calculated using the process weight equations for Class I
Counties,
E = 3.59P0.62
for P < 30 tons/hr
Where:
P = Process Weight Input (tons/hr);and
E = emission rate (lb/hr)
Since the PM emissions from the holding furnace would not be captured, it would not be
subject to this rule. The furnace would be subject to this rule.
Title V/PSD/NSPS/NESHAP/112g/Air Toxics
ECOVERY is a new facility with no sources of emissions currently. The facility
proposed to limit potential HCL emissions to remain a minor source in regards to Title V.
No other emissions at the facility would exceed major source thresholds. Therefore the
facility would be a minor source in regards to Title V. The potential to emit from the
melting furnace would be below the 100 TPY threshold for PSD, so ECOVERY would
not be subject to PSD. There are no New Source Performance Standards applicable to
the installation of the proposed Holding Furnace or the Rotary Melting Furnace. The
proposed melting furnace would be subject to 40 CFR 63 Subpart RRR “National
Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production”.
The holding furnace would not be subject to 40 CFR 63 Subpart RRR “National
Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production”
because this unit would be considered a group 2 furnace at an area source. 40 CFR 63
Subpart RRR does not apply to group 2 furnaces located at an area source.
Because a MACT applies to this source, an Air Toxics review would not be necessary.
Also, HAP emissions would not be expected to be above the major source threshold
(greater than 10 TPY of any single HAP or 25 TPY of any combination of HAPs) and
since a MACT exists for this source, a 112(g) case by case MACT review would not be
necessary. Emissions from the new holding and melting furnace would not be expected
to impact any Class I Area, the closest of which is more than 100 km from ECOVERY.
NESHAP RRR – Applicability
40 CFR 63 Subpart RRR – National Emission Standards for Hazardous Air Pollutants for
Secondary Aluminum Production applies to each new and existing secondary aluminum
processing unit (SAPU), containing one or more group 1 furnaces processing other than
clean charge, located at an area source. §63.1500(c)(4) states that the requirements of
this subpart pertaining to dioxin and furan (D/F) emissions and associated operating,
monitoring, reporting, and recordkeeping requirements apply to each new and existing
SAPU located at a secondary aluminum production facility that is an area source of
HAPs.
NESHAP RRR – Emission Standards
§63.1505(i) states that the owner or operator of a group 1 furnace must use the limits in
this paragraph to determine the emission standards for a SAPU. §63.1505(i)(3) gives the
limit of 15 µg of Dioxins/Furans (D/F) TEQ per Mg (2.1 x 10-4 grains of D/F TEQ per
ton) of feed/charge from a group 1 furnace at a secondary aluminum production facility
that is a major or area source.
NESHAP RRR – Operating and Monitoring Requirements
The facility must operate the melting furnace and baghouse in accordance with
§63.1506(a), (b), (c), (d), (m), and (p) of 40 CFR Part 63 Subpart RRR. The facility must
comply with the applicable monitoring requirements of §63.1510(a-f), (h-j), (s), and (w)
of 40 CFR Part 63 Subpart RRR.
The facility must prepare and implement a written operation, maintenance, and
monitoring (OM&M) plan for this unit according to the applicable portions of
§63.1510(b) of 40 CFR Part 63 Subpart RRR.
The facility must include, within the OM&M plan prepared in accordance with
§63.1510(b), the requirements contained in §63.1510(s) of 40 CFR Part 63 Subpart RRR.
The facility must provide and maintain easily visible labels for this unit according to
§63.1506(b) of 40 CFR Part 63 Subpart RRR.
The facility must inspect the labels associated with this unit at least once per calendar
month to confirm that posted labels are intact and legible (§63.1510(c)).
The facility must inspect the capture/collection system associated with this unit at least
each calendar year to ensure that the system is operating in accordance with the operating
requirements in §63.1506(c) of 40 CFR Part 63 Subpart RRR and record the results of
each inspection.
The facility must measure and record the total weight of feed/charge or aluminum
production according to the requirements in §63.1506(d) and §63.1510(e) of 40 CFR Part
63 Subpart RRR.
The bag leak detection system associated with this unit must be installed, calibrated, operated,
and maintained according to §63.1510(f)(1)(i–x) of 40 CFR Part 63 Subpart RRR.
The facility must operate and maintain the melting furnace with baghouse according to
the requirements in §63.1506(m) of 40 CFR Part 63 Subpart RRR.
The facility must install, calibrate, maintain, and operate a device to continuously
monitor and record the temperature of the fabric filter inlet gases associated with this unit
according to the requirements in §63.1510(h) of 40 CFR Part 63 Subpart RRR.
The facility must monitor and record the total reactive flux injection rate according to the
requirements in §63.1510(j) of 40 CFR Part 63 Subpart RRR.
The facility must design, install, operate, and maintain the capture and collection system
associated with this unit according to the requirements in §63.1506(c)(1)-(3) and
§63.1510(d)(1)-(2) of 40 CFR Part 63 Subpart RRR.
The facility must verify that lime is free-flowing to the fabric filter system associated
with this unit according to the requirements in §63.1510(i)(1) of 40 CFR Part 63 Subpart
RRR.
The facility must record the lime feeder settings on the continuous lime injection system
associated with this unit once each day of operation according to the requirements in
§63.1510(i)(2) of 40 CFR Part 63 Subpart RRR.
When a process parameter or add-on air pollution control device operating parameter
deviates from the value or range established during the performance test and incorporated
in the OM&M plan, the owner or operator must initiate corrective action. Corrective
action must restore operation of the affected source or emission unit (including the
process or control device) to its normal or usual mode of operation as expeditiously as
practicable in accordance with good air pollution control practices for minimizing
emissions. Corrective actions taken must include follow-ups actions necessary to return
the process or control device parameter level(s) to the value or range of values
established during the performance test and steps to prevent the likely recurrence of cause
of deviation.
NESHAP RRR – Recordkeeping and Reporting Requirements
The facility must comply with the applicable recordkeeping requirements of §63.1517(a)
and (b). The facility must comply with the applicable reporting requirements of
§63.1516(a), (b), and (c).
The facility must develop and implement a written startup, shutdown, and malfunction
plan according to the requirements in §63.1516(a) of 40 CFR Part 63 Subpart RRR.
The facility must submit semiannual reports within 60 days after the end of each 6-month
period according to the requirements in §63.1516(b) of 40 CFR Part 63 Subpart RRR.
The facility shall maintain files of all information (including all reports and notifications)
required by 40 CFR Part 63 Subpart RRR including the following records for this source:
(a) Records of the 15-minute block average inlet temperatures for the lime-injected
fabric filter, including any period when the 3-hour block average temperature
exceeds the compliant operating parameter value +14 C (+25 F), with a brief
explanation of the cause of the excursion and the corrective action taken.
(b) Records of the 15-minute block average weights of gaseous or liquid reactive
flux injection, total reactive flux injection rate and calculations (including
records of the identity, composition, and weight of each addition of gaseous,
liquid, or solid reactive flux), including records of any period the rate exceeds
the compliant operating parameter value and corrective action taken.
(c) For the bag leak detection system associated with this unit, records of the total
operating hours during each 6-month reporting period, records of each alarm,
the time of the alarm, the time corrective action was initiated and completed,
and a brief description of the cause of the alarm and the corrective action taken.
(d) Records of inspections at least once every 8-hour period verifying that lime is
present in the feeder hopper or silo and flowing, including any inspection where
blockage is found, with a brief explanation of the cause of the blockage and the
corrective action taken, and records of inspections at least once every 4-hour
period for the subsequent 3 days.
(e) Records of daily inspections of lime feeder settings, including records of any
deviation of the feeder settings from the settings used in the performance test,
with a brief explanation of the cause of the deviation and the corrective action
teaken.
(f) Records of feed/charge (or throughput) weights for each operating cycle or time
period used in the performance test.
(g) Records of monthly inspections for proper unit labeling for each unit subject to
labeling requirements.
(h) Records of annual inspections of emission capture/collection and closed vent
systems.
(i) Records for any approved alternative monitoring or test procedure.
Recommendation
Based upon the analysis presented in the previous paragraphs, I recommend issuing the
following Synthetic Minor Operating Permit for the 7.5 Ton Holding Furnace and
Melting Furnace with Baghouse for the proposed installation and operation at
ECOVERY LLC in Loxley, Alabama upon receipt of permitting fees and completion of
the required 15 day public notice period. These units are expected to meet all state and
federal air pollution regulations.
Permit Number
501-0048-X001
Tyler Phillips
Industrial Minerals Section
Energy Branch
Air Division
TBD
Date
Unit Description
7.5 Ton Holding Furnace and
Aluminum Melting Rotary Furnace
with Baghouse
Facility Wide Potential Emissions (Including Existing Equipment)
Pollutant
lb/hr
TPY
10.56
46.26
PM
10.50
45.99
PM10
5.87
25.71
PM2.5
14.08
61.67
SO2
2.44
10.69
NOX
9.64
42.22
VOC
2.17
9.50
HAPs (total)
2.17
9.50
HCL
3.10E-08
1.40E-07
Dioxin/Furan
1.68E-03
7.37E-03
Lead
4.84E-05
2.13E-04
Cadmium
1.72E-07
7.54E-07
Mercury
*
5,288
CO2e