Engineering Analysis
Grooms Aluminum Processing
Ashville, Alabama
St. Clair County
411-0041
Project Description
On April 23, 2015, Grooms Aluminum Processing submitted a revised air permit
application for the construction of a new Saturn Shear Shredder with wet suppression and
a new Rotary Melting Furnace with Baghouse with Lime and Powdered Activated
Carbon Injection. The facility currently holds air permit no. 411-0041-X001, and is
located at 615 Industrial Park Drive, Ashville, AL 35953, St. Clair County.
Grooms Aluminum Processing takes in scrap aluminum to include used beverage cans,
aluminum sheets, mixed low copper clips, turnings (shavings), transmissions,
transmission housings, motors, wheels, and dross. Scrap would be conveyed to a Saturn
shear shredder with a wet suppression system to control emissions. Following shredding,
wet scrap would be stored and allowed to dry in the building until the shredded material
is conveyed to a 5.0 MMBtu 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 be 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. The furnace burner would be fueled by natural gas.
Emission Limits
Grooms Aluminum Processing 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
major source threshold of 10 TPY for any single HAP. The HCl limit is shown below:
Emission Source
Rotary Melting Furnace
Requested HCl Limit
lb/hr
TPY
2.17
9.5
Grooms also requested a limit of PM emissions for the new rotary furnace. The PM limit
is shown below:
Emission Source
Allowable PM Emissions
Rotary Melting Furnace
lb/hr
TPY
5.00
21.9
Emissions
The shear shredder, pouring of aluminum, and cooling of the salt cake would produce
fugitive emissions. The potential facility wide fugitive emissions based on 8,760 hours of
operation are shown below:
Pollutant
PM
PM10
PM2.5
SO2
NOx
VOC
Potential Fugitive Emissions
lb/hr
TPY
0.93
4.07
0.86
3.77
0.25
1.12
0.08
0.35
0.04
0.17
0.56
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 and combustion of
natural gas, are shown below:
Pollutant
PM
PM10
PM2.5
SO2
NOX
CO
VOC
Melting Furnace with Baghouse
lb/hr
TPY
5.0
21.9
5.0
21.9
5.0
21.9
14.0
61.32
2.40
10.51
0.88
3.85
9.60
42.05
HAPs (total)
HCL
Dioxin/Furan
CO2e
2.17
2.17
8.82 x 10-7
---
9.5
9.5
3.86 x 10-6
2,644
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 shear shredder 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-.02: Fugitive Dust and Fugitive Emissions
This rule establishes that reasonable precautions to prevent particulate matter from
becoming airborne must be taken. Also, visible fugitive dust emissions must not be
discharged beyond the lot line of the property.
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 shear shredder 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
Grooms Aluminum Processing is a new facility with no sources of emissions currently.
The facility proposed to limit potential PM and 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. With the
proposed limits, the potential to emit from the melting furnace would be below the 100
TPY threshold for PSD for PM. No other emissions exceed PSD thresholds, so Grooms
Aluminum Processing would not be subject to PSD. There are no New Source
Performance Standards applicable to the installation of the proposed Saturn Shredder or
the Rotary Melting Furnace. The proposed furnace would be subject to 40 CFR 63
Subpart RRR “National Emission Standards for Hazardous Air Pollutants for Secondary
Aluminum Production”. The Saturn Shredder with wet suppression would not be subject
to 40 CFR 63 Subpart RRR “National Emission Standards for Hazardous Air Pollutants
for Secondary Aluminum Production” because it applies to aluminum scrap shredders
located at major sources and since Grooms Aluminum is a minor source Subpart RRR
does not apply to the shredder.
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 shredder and furnace would not be expected to
impact any Class I Area, the closest of which is more than 100 km from Grooms
Aluminum Processing.
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 Saturn Shear Shredder and Rotary
Melting Furnace with Baghouse for the proposed installation and operation at Grooms
Aluminum Processing in Ashville, Alabama upon receipt of permitting fees and
completion of the 15 day public notice period for Synthetic Minor Operating Permits.
These units are expected to meet all state and federal air pollution regulations.
Permit Number
411-0041-X001
_________________________
Tyler Phillips
Industrial Minerals Section
Energy Branch
Air Division
6-3-15
Date
Unit Description
Saturn Shear Shredder with Wet
Suppression and Rotary Melting Furnace
with Baghouse