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III. Applicability and Description of Affected Units

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... aluminum can be cast into sows, ingots, or T-bars used as ... T-bar, sow, ingot, billet, pig. Alloying elements. Uncoated/unpainted thermally dried chips ... – PowerPoint PPT presentation

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Title: III. Applicability and Description of Affected Units


1
Secondary AluminumProduction Industry Maximum
Achievable Control Technology (MACT) Training 40
CFR Part 63 Subpart RRR
2
Secondary aluminum plants recover aluminum from
scrap such as beverage cans, foundry returns,
other aluminum scrap, and dross. Air toxics are
released from preprocessing operations
3
such as aluminum scrap shredding, thermal chip
drying, scrap drying/decoating/ delacquering and
furnace operations (i.e., melting, holding,
refining, fluxing, or alloying).
4
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5
Secondary Aluminum Production Facility
  • Any establishment using clean charge,
    post-consumer aluminum scrap, aluminum ingots,
    aluminum foundry returns, dross from

6
aluminum production, or molten aluminum as the
raw material and performing one or more of the
following processes
7
  • Scrap shredding
  • Scrap drying/delacquering/decoating
  • Thermal chip drying
  • Furnace operations
  • In-line fluxing
  • Dross cooling

8
Example Secondary Aluminum Facility
9
(No Transcript)
10
Secondary Aluminum Sectors
  • Secondary aluminum companies
  • Sweat furnace operators
  • May include die casters foundries

11
Estimated Number of Secondary Aluminum Sources
Potentially Affected
  • Approximately 400 (86 major)
  • 320 die casting companies
  • 1500 foundries
  • 1650 sweat furnaces

12
(No Transcript)
13
Types of Hazardous Air Pollutants (HAPs) Emitted
  • Organic HAPs (e.g. benzene,
  • styrene, dioxins, and furans)

14
  • Inorganic gaseous HAPs (e.g. hydrogen chloride,
    hydrogen flouride, and chlorine)
  • Particulate HAP metals (e.g. arsenic, lead, and
    chromium)

15
(No Transcript)
16
History of Secondary Aluminum Production National
Emission Standards for Hazardous Air Pollutants
(NESHAP)
  • NESHAP was proposed, 2/11/99

17
  • History Contd.
  • Final rule was promulgated, 3/23/00
  • Direct final rule amendments, 6/14/02
  • Final rule amendments, 9/24/02
  • Final rule amendments 12/30/03

18
(No Transcript)
19
Regulated Entities under Current Rule
  • Facilities that perform secondary smelting and
    alloying of aluminum

20
  • Secondary aluminum production facility affected
    sources collocated at
  • Aluminum sheet, plate, and foil manufacturing
    facilities
  • Aluminum extruded product manufacturing facilities

21
  • Other aluminum rolling and drawing facilities
  • Primary aluminum production facilities
  • Aluminum die casting facilities
  • Aluminum foundry facilities

22
(No Transcript)
23
Regulated HAPs
  • Particulate matter emissions (PM) (surrogate for
    HAP metals)
  • Total hydrocarbon (THC) emissions - surrogate for
    HAP organics)

24
  • Hydrogen chloride (HCl) emissions - a HAP and a
    surrogate for inorganic HAPs including hydrogen
    fluoride (HF) and chlorine (Cl2)

25
  • Dioxin and furan emissions at secondary aluminum
    production facilities that are major or area
    sources

26
(No Transcript)
27
Projected Environmental Benefits
  • Reduce HAP emissions by about 12,420 tons/year, a
    70 reduction from current levels
  • Reduce HCl emissions by 12,370 tons/year, a 73
    reduction

28
Projected Environmental Benefits (Continued)
  • Reduce metal emissions by 40 tons/year, a 60
    reduction
  • Reduce dioxin/furan emissions by 0.88
    pounds/year, a 79 reduction

29
Projected Environmental Benefits (Continued)
  • Reduce polycyclic organic matter emissions by 10
    tons/year, a 25 reduction
  • Reduce PM emissions by 3,185 tons/year, a 30
    reduction

30
(No Transcript)
31
Rule Requirements
  • Emission standards and operating requirements
  • Monitoring and compliance provisions
  • Notifications, reports, and records

32
(No Transcript)
33
Applicability and Description of Affected
Units63.1500
34
Applicability and Description of Affected Units
  • Secondary aluminum production
  • operations
  • Affected sources
  • Secondary Aluminum Website
  • http//www.epa.gov/ttn/uatw/alum2nd.html

35
(No Transcript)
36
Secondary Aluminum NESHAPS Applicability
Flowcharts
37
(No Transcript)
38
(No Transcript)
39
(No Transcript)
40
(No Transcript)
41
(No Transcript)
42
Secondary Aluminum Production Operations
  • Preprocessing of scrap aluminum (size
    reduction, removal of oils, coatings, and other
    contaminants)

43
  • Furnace operations (melting, in-furnace
    fluxing/refining, tapping)
  • Additional refining (in-line fluxing)
  • Cooling of dross

44
(No Transcript)
45
Processing of Scrap Aluminum
  • Crushing, shredding, and grinding
  • Drying
  • Heating in a dryer or kiln
  • Heating in a sweat furnace

46
Crushing, Shredding, and Grinding
  • To reduce the size of scrap aluminum
  • Emissions Particulate matter (PM)
  • and HAP metals generated as dust
  • from coatings other contaminants

47
Chip Dryers
  • To reduce the size of scrap aluminum
  • Emissions Particulate matter (PM)
  • HAP metals generated as dust from
  • coatings and other contaminants

48
Applicability and Description of Affected Units
  • Secondary aluminum production operations
  • Affected sources

49
(No Transcript)
50
Secondary Aluminum Production Operations
  • Preprocessing of scrap aluminum (size reduction,
    removal of oils, coatings, and other contaminants)

51
  • Furnace operations (melting, in-furnace
    fluxing/refining, tapping)
  • Additional refining (in-line fluxing)
  • Cooling of dross

52
Preprocessing of Scrap Aluminum
  • Crushing, shredding, and grinding
  • Drying
  • Heating in a dryer or kiln
  • Heating in a sweat furnace

53
Crushing, Shredding, and Grinding
  • To reduce the size of scrap aluminum
  • Emissions Particulate matter (PM) and HAP
    metals generated as dust from coatings and other
    contaminants

54
Chip Dryers
  • Evaporates oil and moisture from uncoated
    aluminum chips borings
  • Generally operate at temperatures ranging between
    300oF to 750oF
  • Emissions Organic HAPs including dioxins and
    furans

55
Scrap Dryers/Delacquering Kilns/Decoating Kilns
  • Remove coatings and other contaminants that may
    be present in scrap prior to melting (e.g., oil,
    grease, lubricants, lacquers, rubber, and plastic
    laminates)

56
  • Heat scrap to exit temperature of 1000 F
  • Emissions Inorganic HAPs including
    particulate metal HAPs and hydrogen chloride and
    organic HAPs including dioxins and furans

57
Charging End of Delacquering Kilns
58
Discharge End of Delacquering Kilns
59
Sweat Furnaces
  • Reclaim aluminum from scrap with high levels of
    iron
  • Operate in batch mode at a temperature high
    enough to melt the aluminum but not the iron

60
  • Molten aluminum can be cast into sows, ingots, or
    T-bars used as feedstock for melting and refining
    furnaces
  • Emissions Dioxins and furans

61
Sweat Furnace Charging
62
Sweat Furnace
63
Uncontrolled Sweat Furnace 1
64
Uncontrolled Sweat Furnace 2
65
Furnace Operations
  • Melting
  • Fluxing/refining
  • Tapping

66
Melting
  • Begins with charging of scrap into furnace
  • Chemistry of molten bath adjusted by adding
    selected scrap or alloying agents (e.g., silicon)

67
Charging Sidewell Furnace
68
Fluxing
  • Done to refine molten aluminum to improve product
    quality, achieve product specifications, or
    reduce material loss

69
  • Fluxes may be added to remove impurities and
    reduce aluminum oxidation
  • May be performed in the furnace or outside the
    furnace by an in-line fluxer

70
Fluxing Processes
  • Addition of salts (cover flux)
  • Addition of solvents
  • Injection of gasses (demagging and degassing)

71
Process Furnaces
  • Refractory-lined metal vessels heated by oil,
    gas, or electricity that are used to melt scrap

72
  • Types include melting, holding, and refining
    furnaces
  • Charging of scrap can be done from the side,
    front, or top of the furnace

73
Examples of Process Furnaces
  • Top charging and front charging furnaces

74
  • Sidewell melting furnace a furnace with an open
    well adjacent to the hearth used for charging
    scrap solid flux or salt to the furnace,
    injecting fluxing agents, skimming dross

75
Transferring Molten Aluminum to Holding Furnace
76
Sidewell Furnace
77
Examples of Process Furnaces - Continued
  • Induction furnaces heating mechanism is
    electric energy
  • Reverberatory furnaces typically gas

78
Process Furnace Emissions
  • HAP emissions from scrap and fluxing agents
    include
  • Particulate metal HAPs
  • Hydrogen chloride
  • Dioxins and furans

79
Dross-only Furnaces
  • Typically rotary barrel-designed furnaces
    dedicated to reclamation of aluminum from dross
    formed during melting, holding, alloying, or
    fluxing operations carried out in other process
    units

80
Dross-only Furnaces Contd.
  • Dross and salt flux are sole feedstocks
  • Emissions Particulate matter including metal
    HAPs

81
In-line Fluxing
  • Fluxing performed in a device exterior to
    furnace, located in a transfer line from furnace
  • Involves injection of chlorine, argon, nitrogen,
    or other gases to achieve desired metal purity

82
In-line Fluxing - Continued
  • Found primarily at facilities that manufacture
    high quality aluminum or in facilities with no
    other means of degassing
  • Emissions Hydrogen chloride and particulate
    matter

83
Tapping
  • Transferring molten metal from melting furnace to
    molds or to a ladle

84
Cooling of Dross
  • Dross - slags and skimmings from melting and
    refining consisting of fluxing agents,
    impurities, and/or oxidized and non-oxidized
    aluminum

85
Cooling of Dross - Continued
  • Accomplished in rotating, water-cooled drums
  • Sole feedstock to dross-only furnaces
  • Emissions Particulate matter including metal
    HAPs

86
Rotary Dross Cooler
87
(No Transcript)
88
Affected Sources at Major Sources of HAPs -
63.1500
  • Each new and existing
  • Aluminum scrap shredder
  • Thermal chip dryer
  • Scrap dryer/delacquering kiln/decoating kiln

89
  • Each new and existing group 2 furnace
  • Melts, holds, or processes only clean charge, and
  • Performs no fluxing, or
  • Performs fluxing using only non-reactive,
    non-HAP-containing/non-HAP-generating gases or
    agents

90
  • Each new and existing
  • Sweat furnace
  • Dross-only furnace
  • Rotary dross cooler

91
  • Each new and existing secondary aluminum
    processing unit (SAPU)
  • Group 1 furnace processes non-clean charge or
    processes clean charge with reactive fluxing

92
  • Combination of all group 1 furnaces and all
    in-line fluxers within a secondary aluminum
    production facility

93
(No Transcript)
94
Secondary Aluminum Processing Units (SAPU)
  • Existing SAPU all existing group 1 furnaces and
    all existing in-line fluxers

95
  • New SAPU any combination of new group 1
    furnaces and new in-line fluxers constructed
    after 2/11/99
  • Group 1 furnaces and in-line fluxers are emission
    units within an existing or new SAPU

96
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97
Affected Sources at Area Sources of HAPs
  • Emission limits for dioxins and furans and
    associated operating, monitoring, reporting, and
    recordkeeping requirements apply to affected
    sources located at area sources

98
Affected Sources at Area Sources of HAPs Contd.
  • Each new and existing
  • Thermal chip dryer
  • Scrap dryer/delacquering kiln/decoating kiln

99
Affected Sources at Area Sources of HAPs Contd.
  • Sweat furnace
  • SAPU with one or more group 1 furnace emission
    units processing other than clean charge

100
(No Transcript)
101
Affected Sources
  • Does not include aluminum die casters, foundries,
    or extruders that
  • Melt only clean charge and materials generated
    within the facility or returned clean materials
    originally from facility, and

102
Affected Sources Contd.
  • Do not operate a thermal chip dryer, sweat
    furnace, or scrap dryer/delacquering
    kiln/decoating kiln

103
(No Transcript)
104
Clean Charge
  • Molten aluminum
  • T-bar, sow, ingot, billet, pig
  • Alloying elements
  • Uncoated/unpainted thermally dried chips

105
Clean Charge - continued
  • Scrap dried at 650 F
  • Scrap delacquered/decoated at 900 F
  • oil-, lubricant-free unpainted/uncoated gates and
    risers

106
Clean Charge - continued
  • Oil- lubricant-free unpainted/uncoated scrap,
    shapes, or products that have not been processed
    in such a way that causes contamination

107
Clean Charge - continued
  • Runaround scrap
  • Customer returns (clean material which contain no
    paint or other solid coatings)

108
(No Transcript)
109
Runaround Scrap
  • Scrap generated on-site or returned that does not
    contain paint or solid coating
  • Machining chips that have not been dried 650 F,
    or by equivalent non-thermal drying method, are
    not runaround

110
(No Transcript)
111
Emission Standards and Operating Requirements
63.1505 and 63.1506
112
Emission Standards and Operating Requirements
  • Emission Standards
  • 63.1505
  • Secondary Aluminum Website
  • www.epa.gov/ttn/uatw/alum2nd/require/
  • requirement_tables.html

113
Pollutants Regulated
  • PM surrogate for particulate metal HAPs
  • THC surrogate for gaseous organic HAPs
  • D/F limits apply to a major or area source
  • HCl HAP surrogate for chlorine HF
  • Opacity

114
(No Transcript)
115
Format of Emission Standard
  • Emission limits
  • Mass per unit (lb/ton) of feed/charge (or
    production)
  • Concentration (gr/dscf)
  • Percentage reduction

116
Format of Emission Standard - Continued
  • Emission limits
  • D/F in units of TEQ
  • International method of expressing toxicity
    equivalents for D/F

117
Format of Emission Standard - Continued
  • Except for D/F, apply to major sources only
  • Apply to all new and existing affected sources
    and emission units

118
(No Transcript)
119
Opacity Limit
  • Sources with a PM add-on air pollution control
    device -- monitored with a continuous opacity
    monitor (COM)

120
Opacity Limit Contd.
  • Aluminum scrap shredders monitored with a COM, or
    monitored by visible emissions
  • Opacity limit 10 percent

121
(No Transcript)
122
Aluminum Scrap Shredders
  • 0.010 grain (gr) of PM per dry standard cubic
    foot (dscf)

123
(No Transcript)
124
Thermal Chip Dryers
  • 0.80 lb of total hydrocarbon emissions (THC) per
    ton of feed
  • 2.50 micrograms of dioxins and furans (D/F)
    toxicity equivalents (TEQ) per megagram (Mg) of
    feed

125
Thermal Chip Dryers Contd.
  • D/F limit for units at major or area sources

126
(No Transcript)
127
Scrap Dryers/Delacquering Kilns/Decoating Kilns
  • 0.08 lb PM per ton of feed
  • 0.80 lb HCl per ton of feed
  • 0.06 lb THC per ton of feed
  • 0.25 micrograms of D/F TEQ per Mg of feed

128
Scrap Dryers/Delacquering Kilns/Decoating Kilns
Alternate Limit
  • Applies if afterburner has a design residence
    time 1 second, and operates at a temperature
    1400oF
  • 0.30 lb PM per ton of feed

129
Scrap Dryers/Delacquering Kilns/Decoating Kilns
Alternate Limit Contd.
  • 1.50 lb HCl per ton of feed
  • 0.20 lb THC per ton of feed
  • 5.0 micrograms D/F TEQ per Mg of feed

130
(No Transcript)
131
Sweat Furnaces
  • 0.80 nanograms D/F TEQ per dry standard cubic
    meter (dscm) at 11 percent oxygen
  • No test required if sweat furnace has afterburner
    with design residence time
  • 2 seconds and operates at 1600oF

132
(No Transcript)
133
Dross-only Furnaces
  • 0.30 lb PM per ton of feed

134
(No Transcript)
135
In-line Fluxers
  • Limits are used to calculate the standard
    applicable to secondary aluminum processing units
    (SAPU)
  • 0.04 lb HCl per ton of feed
  • 0.01 lb PM per ton of feed

136
In-line Fluxers With No Reactive Fluxing
  • No HCl and PM limits apply
  • Work practice no reactive fluxing

137
(No Transcript)
138
Rotary Dross Coolers
  • 0.04 gr of PM per dscf

139
(No Transcript)
140
Clean Furnaces (Group 2)
  • No emission limits
  • Work practices clean charge only and no
    reactive fluxing or else

141
(No Transcript)
142
Group 1 Melting/Holding Furnaces (Clean Charge
Only)
  • Limits are used to calculate the standard
    applicable to secondary aluminum processing units
    (SAPU)
  • 0.80 lb PM per ton of feed

143
Group 1 Melting/Holding Furnaces (Clean Charge
Only) Contd.
  • 0.40 lb HCl per ton of feed, or 10 percent of the
    HCl upstream of an add-on control device
  • No D/F limit for clean charge furnaces and only
    clean charge can be used

144
Group 1 Furnaces
  • Limits are used to calculate the standard
    applicable to secondary aluminum processing units
    (SAPU)
  • 0.40 lb PM per ton of feed

145
Group 1 Furnaces Contd.
  • 0.40 lb HCl per ton of feed, or 10 percent of the
    HCl upstream of an add-on control device
  • 15.0 micrograms of D/F TEQ per Mg of feed

146
(No Transcript)
147
Group 1 Furnaces (Clean Charge Only)
  • Limits are used to calculate the standard
    applicable to secondary aluminum processing units
    (SAPU)
  • 0.40 lb PM per ton of feed

148
  • 0.40 lb HCl per ton of feed, or 10 percent of the
    HCl upstream of an add-on control device
  • No limit on D/F clean charge only

149
(No Transcript)
150
Sidewell Group 1 Furnace
  • If reactive fluxing (except cover flux) is done
  • - In the hearth, or
  • - In the sidewell when metal level falls below
    top of passage between sidewell and hearth, then

151
Sidewell Group 1 Furnace Contd.
  • Then, limits for sidewell apply for combined
    hearth sidewell emissions

152
(No Transcript)
153
Secondary Aluminum Processing Units (SAPU)
  • No 3-day, 24-hour rolling average emissions of
    PM, HCl, or D/F in excess of the
    production-weighted emission limit for all units
    in the SAPU

154
Secondary Aluminum Processing Units (SAPU) Contd.
  • SAPU may comply by demonstrating compliance of
    each emission unit with its applicable emission
    limit

155
(No Transcript)
156
Emission Standards and Operating Requirements -
Continued
  • Operating Requirements
  • 63.1506

157
Capture/Collection Systems
  • All sources and emission units with an add-on air
    pollution control device (APCD)

158
  • Design and install a capture and collection
    system in accordance with American Conference of
    Governmental Industrial Hygienists (ACGIH)
    guidelines

159
  • Industrial Ventilation A Manual of Recommended
    Practice
  • - Chapter 3 Local Exhaust Hoods
  • - Chapter 5 Exhaust System
  • Design Procedure

160
  • Vent captured emissions through a closed system
    (except dilution air fabric filter temperature
    control)
  • Operate in accordance with operation,
    maintenance, and monitoring (OMM) plan

161
(No Transcript)
162
Feed/Charge Weight Measurement
  • All sources and emission units subject to
    production-based (lb/ton of feed) emission
    limits
  • - Operate a device that records
  • the weight each charge, or
  • production weight

163
  • Operate in accordance with OMM plan
  • May use production basis instead of feed if
  • Production is measured for all
  • emission units within a SAPU

164
  • All emission limit compliance calculations for
    SAPUs are based on production

165
(No Transcript)
166
Labeling
  • Post visible labels at each
  • - group 1 furnace
  • - group 2 furnace
  • - in-line fluxer
  • - scrap dryer/delacquering kiln/decoating
    kiln

167
  • Labels identify emission limits and means of
    compliance, including
  • - Type of source or emission unit
  • - Applicable operational standards
  • and control methods
  • - Afterburner operating temperature
  • and residence time

168
(No Transcript)
169
Affected Sources and Emission Units with Fabric
Filters
  • Scrap shredders
  • Scrap dryer/delacquering kiln/decoating kiln
  • Dross-only furnace
  • Rotary dross cooler
  • In-line fluxer

170
  • Group 1 furnace
  • Must operate a bag leak detection system or
    continuous opacity monitor
  • Except scrap shredders may alternatively choose
    to monitor VE

171
(No Transcript)
172
Fabric Filter with Bag Leak Detector
  • Initiate corrective action within 1 hour of alarm
  • Follow OMM plan
  • Operate so that alarm does not sound more than 5
    of operating time in 6-month period

173
(No Transcript)
174
Fabric Filter with COM
  • Initiate corrective action within 1 hour of a
    6-minute average opacity ? 5
  • Complete corrective actions in accordance with
    OMM plan

175
Aluminum Scrap Shredder with Fabric Filter VE
Alternative
  • Initiate corrective action within 1 hr of any
    observed VE
  • Complete corrective action in accordance with
    OMM plan

176
Thermal Chip Dryer with Afterburner
  • Maintain average operating temperature for each
    3-hr period ? average operating temperature
    during performance test

177
  • Operate afterburner in accordance with OMM plan
  • Operate dryer using only unpainted aluminum chips

178
(No Transcript)
179
Scrap Dryer/Delacquering Kiln/Decoating Kiln -
Afterburner and Lime-injected Fabric Filter
180
  • Maintain afterburner average operating
    temperature for each 3-hr period ? than average
    operating temperature from performance test

181
  • Operate afterburner in accordance with OMM plan
  • Maintain average fabric filter inlet temperature
    for each 3-hr period ? average temperature during
    performance test ( 25oF)

182
  • For continuous lime injection systems
  • Maintain free-flowing lime in the hopper or silo
    at all times
  • Maintain lime feeder at setting established
    during performance test

183
(No Transcript)
184
Sweat Furnace with Afterburner
  • If performance tested, maintain each 3-hr.
    average temperature ? operating temperature of
    performance test

185
  • If not tested, afterburner design residence time
    must be ? 2 seconds and operate at ? 1600oF
  • Existing sweat furnaces must meet operating
    requirements by the compliance date

186
  • New sweat furnaces must meet operating
    requirements by March 23, 2000 or upon startup,
    whichever is later
  • Operate in accordance with OMM plan

187
(No Transcript)
188
Dross-only Furnace with Fabric Filter
  • Must have bag leak detector or COM
  • Operate using only dross as feed material

189
(No Transcript)
190
In-line Fluxer with Lime-injected Fabric Filter
  • For continuous lime injection systems
  • - Maintain free-flowing lime in the
  • hopper or silo at all times for
  • continuous injection systems

191
  • - Maintain lime feeder at setting
  • established during performance
  • test
  • Maintain reactive flux injection rate ?
    performance test rate for each operating cycle or
    time period used in performance test

192
(No Transcript)
193
In-line Fluxer Using No Reactive Flux Material
  • Use no reactive flux

194
(No Transcript)
195
Group 1 Furnace with Lime-injected Fabric Filter
  • Maintain average fabric filter inlet temperature
    for each 3-hr period ? average temperature during
    performance test ( 25oF)

196
  • Maintain reactive flux injection rate at or below
    performance test rate for each furnace cycle

197
  • For continuous injection systems
  • Maintain free-flowing lime in the
  • hopper or silo at all times
  • Maintain lime feeder at setting established
    during performance test

198
  • For sidewell furnaces
  • - Operate so level of molten aluminum
  • is above the top of passage between
  • sidewell and hearth during reactive
  • flux injection, unless hearth is also
  • controlled

199
  • For sidewell furnaces Contd.
  • Add reactive flux only to sidewell of the furnace
    unless the hearth is also controlled

200
(No Transcript)
201
Group 1 Furnace Without Add-on Controls
  • Maintain reactive flux injection rate ?
    performance test rate for each operating cycle or
    time period used in performance test

202
  • Operate furnace within range of charge materials,
    contaminant levels, and parameter values
    established in site-specific monitoring plan
  • Use only clean charge (melting/holding furnace)

203
(No Transcript)
204
Site-specific Monitoring Plan
  • For group 1 furnaces without control devices -
    OMM plan must include a section that documents
    work practices and pollution prevention measures,
    including procedures for scrap inspection

205
  • Site-specific monitoring plan and testing to
    demonstrate adequacy of the monitoring plan must
    be developed in coordination with, and approved
    by, the permitting authority

206
(No Transcript)
207
Clean (Group 2) Furnace
  • Use only clean charge
  • Use no reactive flux
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