1 The EPA can establish both work practice requirements and an emission standard under the Act, and nothing about either the language or the structure of the Act obviously precludes such an approach. Section 112( h), by its own terms, limits only EPA's authority to utilize work practice requirements " in lieu" of emission standards [ CAA § 112( h)( 1 )]. Indeed, the statute contemplates emission reductions " through application of measures, processes, methods, systems, or techniques" that specifically include process changes; materials substitution; enclosures; capture and treatment; design, equipment, work practice or operational changes; or a combination of these approaches. See CAA § 112( d)( 2). MEMORANDUM Date: August 28, 2003 To: Docket ID Nos. OAR 2002 0034 and A 2000 56 ( Iron and Steel Foundries)

From: Kevin Cavender, EPA/ OAQPS Subject: MACT Floor for Scrap Inspection Programs An important component of the technology for control of emissions of HAP metals, especially lead and mercury, from melting furnaces and other foundry processes is a scrap selection and inspection program. We have established emission limits to ensure control of less volatile metal HAP that cannot be reduced by a scrap selection and inspection program. The combination of a work practice standard for scrap inspection and an emission limit is the most effective means to control metal HAP emissions. 1 Information on current industry practices was compiled from the 1998 survey of approximately 600 iron and steel foundries. The vast majority of foundries ( well over the median of the top 12 percent that determines the MACT floor) have implemented a pollution prevention program that includes scrap selection and specifications. Tables 1, 2, and 3 list the survey responses for foundries with the three types of melting furnaces. The survey responses also indicate that the procedures are different from plant to plant. Representatives from several companies with these programs were interviewed to gain additional details. Results are summarized in Attachment A. One of the common elements among foundries is a visual inspection of scrap. Most foundries also use specifications for their suppliers to limit contamination.

The information we collected indicates that a scrap selection and inspection program is part of the MACT floor for metal HAP emissions from iron and steel foundries. We could not confirm that preventing mercury switches and lead components in the scrap was indisputably part of the MACT floor, although many foundries reported some type of effort to prevent unwanted contamination. However, the low cost of the scrap inspection program and the potential reductions in mercury emissions alone make the work practice requirements in the final rule an appropriate above the floor control. These work practice requirements are at least as stringent as the practices used by the average of the top 12 percent of foundries. 2 TABLE 1. SCRAP PROGRAMS   ELECTRIC ARC FURNACES Iron Foundries ID Company City St Survey Response IL 05 Caterpiller Inc., Mapleton IL Melt specifications limit % lead and certain other metals in incoming scrap. MI 09 Hayes Albion Corporation Albion MI The purchasing department specifies a limit on the amount of cutting fluids deemed acceptable on scrap metal. IA 17 John Deere Foundry Waterloo Waterloo IA Scrap supplied must meet specification that limits contaminants. No drying of the scrap is required. Scrap engine blocks must be stripped of internal components such as freeze caps, bearing plugs, etc. NE 05 Paxton Mitchell Company Omaha NE We purchase scrap such as railroad rail & stammings. All scrap is kept under roof of melt area. MI 24 Process Prototype Romulus MI We use only clean scrap, dry washed scrap WA 10 Spokane Steel Spokane WA Scrap selection. No oil or paint allowed. WI 02 Tomahawk Rice Lake WI Use all new and clean scrap Steel Foundries ID Company City St Survey Response IN 02 ABC Rail Anderson IN Use top grade scrap for remelt  no paint or oil allowed. Every load of scrap is visually checked before accepting the load. AL 26 ABC Rail Calera AL Scrap selection IL 04 American Steel Foundries Granite City IL Scrap selection has provided a 36.7% reduction in the generation of electric arc furnace dust from 1996 to 1997. KS 07 Atchinson Casting Corp. Atchinson KS Only premium grade scrap or clean returns are used for melting stock. No oily, greasy, painted, or otherwise contaminated scrap stock are utilized. WA 13 Atlas Foundry Tacoma WA Clean non oily scrap MI 12 Bay Cast Inc Bay City MI Scrap selection and drying of scrap. PA 25 CMI Quaker Alloy, Inc. Myerstown PA We purchase clean scrap ( low phosphorus and low sulfur). All revert material is mechanically cleaned before remelting. OR 09 Columbia Steel Portland OR Only select clean scrap is charged. No backcharging. PA 09 Empire Steel Castings, Inc. Reading PA We purchase and use low phosphorous/ low sulphur plate scrap. All revert material is mechanically cleaned before melting. OR 04 ESCO  Plant 3 Portland OR ESCO accepts clean scrap only. OR 01 ESCO Corp. Portland OR ESCO accepts clean scrap only. MS 03 ESCO Corporation Newton MS Low alloy returns are wheel treated to remove residual molding sand VA 07 Newport News Shipbuilding Newport News VA Scrap selection  no oily or galvanized scrap is used MO 01 Gold Foundry & Machine Works Independence MO We buy & use only clean carbon steel scrap CA 10 Grass Valley Steelcast Grass Valley CA Use of clean dry scrap TX 33 Henderson Manufacturing Co., Inc. Pittsburg TX Scrap is carefully selected to be free of oil, grease or paint to keep the amount of smoke and emissions to a minimum.

TX 19 Hensley Industries, Inc. Dallas, Dallas County TX All scrap is # 1 heavy, clean, steel scrap. Foundry returns are melted also. NH 01 Joy Technologies Claremont NH Only clean scrap is used for charging. MO 04 Mans Steel Mansfield MO All scrap is furnished by our fabrication divisions and is considered ID Company City St Survey Response 3 Foundary clean scrap. WI 29 Maynard Steel Casting Co. Milwaukee WI Scrap is to be essentially free from oil and grease and free from rust. PA 38 McConway & Torley Pittsburgh PA Oil free scrap is utilized as a raw material PA 29 McConway & Torley Kutztown PA All scrap is cleaned by the scrap dealers  use non volatile additives. AZ 04 ME West Castings Tempe AZ No. 1 heavy melt is used to minimize the need for backcharging. No autoshed is charged. MO 02 Milton B. Gold Foundry Independence MO We buy & use only clean carbon steel scrap AL 28 Mobile Pulley & Machine Works Mobile AL Scrap selection: clean steel " drops" from nearby shipyards IL 07 National Castings Inc. Melrose Park IL National Castings attempts to purchase the cleanest scrap available IL 06 National Castings Inc. Chicago IL National Castings attempts to purchase the cleanest scrap available.

WI 45 Northern Steel Castings, Inc. Wisconsin Rapids WI Scrap is structural steel; no paint PA 24 Pennsylvania Steel Foundry & Machine Hamburg PA Purchase low phosphorous/ low sulphur scrap which is also clean of oil. All revert material is mechanicaally cleaned before melting.

WA 12 Quali Cast Foundry, Chehalis WA Clean scrap selection.

WI 12 Racine Steel Castings Racine WI Purchase clean scrap IA 07 Sivyer Steel Corporation Bettendorf IA Purchase clean scrap, keep dry, keep roofs sealed with sand.

TX 32 Smith Steel. Marshall TX Use clean scrap TX 28 Southwest Steel Longview TX Clean dry scrap selected MO 12 Standard Electric Steel Corp. Springfield MO Clean scrap, returns & virgin alloys utilized WI 25 The Falk Corp Milwaukee WI Scrap selection PA 39 The Frog, Switch & Mnf Co Carlisle PA Use of clean, nonoily scrap WA 01 Vancouver Foundry Vancouver WA Use clean scrap & blast portion of returns.

WI 52 Waukesha Foundry Inc. Waukesha WI Clean scrap used, separate by type and wheelabrate WI 41 Waunakee Alloy . Waunakee WI All scrap is kept inside the building. WA 03 Western Steel Casting Seattle WA Scrap selection  only clean low carbon plate scrap used.

PA 11 WHEMCO Midland Foundry Midland PA Limit backcharging, do not use oily scrap, do not use bundled or fragmented scrap. 4 TABLE 2. SCRAP PROGRAMS   ELECTRIC INDUCTION FURNACES Iron Foundries ID Company City St Survey Response IN 03 Weil McLain Michigan City IN Facility uses clean scrap from internal operations and pig iron TX 14 Texas Foundries Lufikin TX Non oily, clean scrap only. TX 18 Lufkin Industries Lufkin TX Scrap selection MI 09 Hayes Albion Albion MI Purchase clean scrap. PA 07 Grinnell Columbia PA See attached scrap specification Doc. No. 111 008. Scrap is dried during preheating. MI 34 GM Saginaw MI Sort & scrap; follow a scrap selection specification MI 14 East Jordan Iron Works, . East Jordan MI Purchase clean scrap, radiation device screens scrap IL 05 Caterpiller Inc., Mapleton Foundry Mapleton IL Melt specifications limit % lead and certain other metals in incoming scrap. WI 28 Brillion Iron Works Brillion WI Facility purchases # 1 steel scrap with minimal painted or plated parts. Scrap is dried in preheater. IN 13 Auburn Foundry Plant # 2 Auburn IN We have strict QA/ QC procedures for the type of scrap we melt ( no oils, paints, etc.) IN 12 Auburn Foundry Plant # 1 Auburn IN Strict QA/ QC specifications are followed for all scrap purchased for cupola melting ( I. e. no paints, oils, lead, etc.) OH 40 Xenia Foundry Xenia OH Scrap selection PA 36 Wrightsville Foundry  Building # 8 Belleville PA Use of clean oil fee scrap, gas fired scrap drying process.

WI 10 Willman Industries, Inc. Cedar Grove WI Purchase of clean scrap iron. GA 01 Wheland Foundry Warrenton GA A strict clean scrap acceptance policy is practiced. TX 11 Western Iron Works, Inc. San Angelo TX Scrap screening CO 03 Western Foundries Longmont CO # 1 plate and structural clean, no oil, paint or coating GA 02 West Point Foundry & Machine Company West Point GA Scrap metals ( steel) is selected to be free of oils, greases, paint, and field dirt and to be dry. OH 25 Webster Manufacturing Tiffin OH Scrap drying ( for moisture) when needed. PA 15 Weatherly Casting & Machine Company Weatherly PA Metal charge consists of clean materials only, including pig iron, cropped steel rail, ferro alloys and recycled gates & overs. PA 33 Washington Mould Co Washington PA Clean dry scrap stored inside. VA 03 Walker Machine & Foundry Corporation Roanoke VA Gaylord scrap iron preheater, scrap selection procedure; no pipe, conventers, no paint  testing for chemistries PA 37 W. O. Hickok Mfg. Co. Harrisburg PA Clean scrap, no oil contaminated scrap used. PA 21 Victaulic Company of America Easton PA Scrap deliveries are scrutinized for excessive oils and coolants PA 22 Victaulic Company of America Alburtis PA Scrap deliveries are scrutinized for accumulations of oil and coolant. TN 17 Vestal Manufacturing Co. Sweetwater TN Use # 1 bushling  clean, dry, oil free VT 01 Vermont Castings  Foundry Division Randolph VT Purchased scrap specifications require vendors keep all nonferrous and tramp materials out of the supply. OR 06 Varicast, Inc. Portland OR Use clean scrap & blast portion of returns PA 20 Urick Foundry Erie PA Purchase only clean dry scrap  kept under roof until used. MN 11 United Machine & Foundry Winona MN dry scrap PA 14 United Foundry Co Johnstown PA Scrap selection OH 18 United Foundries  Canton OH Only clean & dry scrap are used. ID Company City St Survey Response 5 PA 06 Tyler Pipe Penn Division of Ransom Industries Inc. Macungie PA Scrap is run over a grizzly scrap cleaner conveyor. System is ducted to a griffin baghouse.

OH 10 Tri Cast, Inc. Akron OH Using pig iron and clean steel rail only. WI 22 Torrance Casting, Inc. La Crosse WI Scrap and pig is stored inside; scrap contains no oils/ greases. Pig iron is screened prior to charging to reduce rust and dust. OK 10 Tonkawa Foundry, Inc. Tonkawa OK Pure alloys and returns utilized AL 33 Tommie Corporation Thorsby AL Ductile iron returns cleaned by shot blasting. Use of dry, clean, steel scrap free of tramp elements that are detrimental to making quality ductile iron  such as manganese, chrome, lead. PA 08 Tom Ondrejko Co. Washington PA We choose selected clean melt stock and use perlite as metal cover during superheat & ladling of metal. MI 10 Thunder Bay Manufacturing Corporation Alpena MI Selective use of stamping plant scrap and structural steel scrap: all scrap is inspected to insure that there is no lead in incoming materials. CT 03 The Taylor and Fenn CoWindsor CT Only clean dry scrap is charged. OH 33 The Quality Castings Co. Orrville OH Specify 1005/ 1020 Scrap, No residuals OH 16 The Pioneer City Casting Belpre OH Use cleaned returns and purchase only clean slitter steel OH 62 The Knapp Foundry Co Akron OH Scrap selection IL 18 The Francis & Nygren Foundry Company Chicago IL 10 10 and 10 08 steel punchings kept inhouse under roof, very clean dry material AL 27 The Foundry of the Shoals, Inc. Florence AL We melt only clean structural scrap steel & pig iron to reduce lead in fumes to comply with OSHA statndard. MN 15 The Dotson Company, Inc. Mankato MN In 1995  an existing shakeout system was replaced with a Didion MD 80 rotary drum system. Gates and risers are cleaned in the didion before being returned for remelting. Before the didion installation all gates and risers were wheelabrated ( shot blast) IA 19 The Dexter Company Fairfield IA Ductile scrap is dried by a natural gas burner before loaded into the induction furnaces. TX 03 Texaloy Foundry Floresville TX Scrap selection is done by hand, which limits emissions and so is furnace charging. IN 05 Tate Model & Eng Kokomo IN Facility purchases clean dry pig only ( no scrap) AL 04 Talladega Foundry & Machine Company, Inc. Talladega AL Melt stack is approximately 45% clean foundry returns and 55% clean, unoxidized slitter steel scrap. PA 05 T. B. Wood's Sons Company Chambersburg PA Charge consists of returns, pig iron, and unpainted steel. All chemistry controlled. OH 07 T & B Foundry Company Cleveland OH Only clean oil free scrap is purchased ( rail & pig iron); all scrap is put through a dryer/ pre heater SC 06 Synehi Castings Greenwood SC Utilize only ' clean, dry' scrap CO 01 Svedala Industries, Inc. Pumps & Process Colorado SpringsCO Only prepared clean scrap is used, scrap is kept indoors at all times. NC 03 Stovall Foundry, Inc. Gastonia NC Select clean scrap AL 22 Stockham Valves & Fittings, Inc. Birmingham AL Selection of clean ( no grease, oil, lead, paint) scrap IN 32 Sterling Casting Corp Buffton IN Scrap selection OH 35 St. Marys Foundry, Inc. St. Marys OH Scrap is inspected and preheated prior to melt. All raw materials meet certification prior to melt. AL 02 Southern Ductile Bessemer AL Drying using a preheater ID Company City St Survey Response 6 Casting AR 01 Southern Cast Products Jonesboro AR We use clean, dry scrap CA 28 Soundcast Co. Costa Mesa CA Use only prime western scrap metal, clean and dry PA 16 Somerset Foundry Somerset PA Only clean dry scrap is charged. NE 01 Sioux City Foundry Company South Sioux CityNE Use internally generated cast iron returns. Buy only clean mild steel, no engine blocks or externally generated cast iron. PA 31 Saxonburg Foundry Co. Saxonburg PA All scrap is stored inside, to keep clean and dry, before use. No painted metal is used, only slight oxidation on scrap surface. IA 18 Russelloy Foundry, Inc. Durant IA Clean scrap Al 13 Robinson Foundry Inc. Alexander City AL Purchased scrap is specified to be free of excessive dirt, oil and grease. Automotive cast scrap is not accepted. in 25 RMG Foundry Mishawaka IN Purchase of clean, dry charge material; preheating of all charges CA 14 Richmond Micro MetalsRichmond CA Scrap is shot blasted IN 10 Richmond Casting Company Richmond IN Care taken to assure clean dry scrap purchased & charged gas torches used to dry wet scrap IA 12 Quinn Foundry Inc. Boone IA No automotive parts or painted steel is used. OH 34 Quincy Castings, Inc. Quincy OH Specify clean scrap  no oil; use pig iron; scrap is dried before charge NY 07 Pohlman Foundry Co., Inc. Buffalo NY Scrap which is used is good quality and clean and is processed via a preheater to remove moisture. IN 28 Plymouth Foundry, Inc. Plymouth IN We purchase dry oil free scrap steel OH 17 Plant # 3 & # 4  FoundryBlanchester OH Impurities are minimized by using selective feed stock. SC 04 Pinebrook Foundry Great Falls SC All returns are cleaned, we use no scrap, all pig iron and our on returns. NE 06 Phoenix Casting & Machining Juniata NE We use only pig iron and clean steel, which are drops from local fabricator and of known composition. All material stored inside and dry at use. AL 31 Phenix Foundry Phenix City AL We change by hand  80% pig iron. We use very little purchased scrap metal. TX 20 Penatek Industries, Inc. Odessa TX Most remelt scraps are shot blasted by the vendors. LA 06 Pearce Foundry, Inc. Prairieville LA Only clean dry scrap is used NE 05 Paxton Mitchell Company Omaha NE We are selective on scrap purchased. We also keep it dry and under roof  applies to all scrap. TX 09 Oil City Iron Works, Inc. Corsicana TX Only clean scrap without paint/ coating or oil. This preheater removes moistures. MI 06 Northland Castings Corp. Hart MI Cleaned ( washed) iron scrap, clean steel stampings, closed reaction chamber. IN 27 North Manchester Foundry Inc. North Manchester IN Scrap selection NH 04 Nashua Foundries, Inc. Nashua NH We use pig iron and steel ( OTM, rail and punchings) as our melt stock. WA 06N. E. W. Castings Inc. Spokane WA Only paint and oil free steel waste from fabricators and certified pig iron is used in our process. We do not use purchased scrap iron. This prevents contamination of lead etc. TN 09 Mueller Company Chattanooga TN Scrap preheater ( gas fired) 1100 deg. F; furnace charging practices; purchased scrap selection AL 05 Mueller Co. Albertville AL Indoor storage and handling of scrap PA 35 Mt. Joy Foundry Mt. Joy PA Purchase of clean, oil free scrap. OH 20 Minster Machine Company Minster OH Cyclone included prior to cartridge system to enhance life of the collector and increase collection efficiency ID Company City St Survey Response 7 WI 30 Milwaukee Malleable & Grey Iron Works Division Milwaukee WI Some melting stock is shot blasted, clean steel scrap is used.

MI 18 Midwest Metallurgical Laboratory, Inc. Marshall MI Use of clean scrap, use of flotret process for magnesium innoculation MI 03 Midland Iron Works, Inc. Midland MI Scrap selection OH 32 Miami Cast Inc. Miamisburg OH All input materials are clean, dry and free of oils, solvents, etc. KS 05 Metlcast Products, Inc. Salina KS We purchase clean scrap steel to reduce air and solid waste emissions. TX 31 Martin Foundry Division of Martin Sprocket & Gear Dallas TX Only clean A grade machine scrap used; no automotive parts are accepted. All scrap is thourghly inspected for pockets of oil or other liquids. TX 13 Mabry Foundry Inc. Beaumont TX Scrap dryer  Buy clean low phos plate & structural CA 11 Lodi Iron Works, Inc. Lodi CA Scrap is dried TN 04 Lodge Manufacturing Co. South Pittsburg TN Scrap selection: Bushling steel, returns, and pig iron. No automotive or mixed scrap is used. Scrap is allowed to dry prior to use. WI 44 Liberty Foundry Wauwatosa WI We purchase premium, clean, oil free scrap when available IL 10 Lemfco Inc. Galena IL Clean scrap is purchased, scrap is preheated. AL 21 Lawler Machine & Foundry Co. Birmingham AL Lawler Foundry uses pig iron to comprise approximately 44% of total charge. MS 02 Laurel Foundry Sandersville MS Selection of non contaminated scrap charges OH 58 Kenton Iron Products Kenton OH Use clean dry forge crops, pig iron & returns. WV 01Kelly Foundry & Machine Elkins WV Shot blast all scrap MD 01 Kaydon Ring & Seal Co. Baltimore MD Rail shot blasted prior to use. CA 09 K. P. Iron Foundry Fresno CA Dirty scrap is tumbled to remove oil and dirt  All scrap is preheated to burn off residue IA 11 Iron Foundry Cedar Falls IA Scrap selection, pre heating AL 12 Imperial Casting Co. Florence AL We buy only clean scrap ( no oil), we use 1/ 3 charge of pig iron, & preheat our scrap w/ pig iron. PA 18 Hazleton Pumps, Inc. Hazelton PA All scrap is shot blasted if dirty. MA 03 Harmony Pattern & Casting Co., Inc. Swansea MA Using clean steel stampings & pig iron only in charge makeup OH 27 Hamilton Foundry Harrison OH Scrap selection NC 02 Hallman Foundry, Inc. Sanford NC Scrap size specifications, magnetic separators, and drying PA 53 Hale Pump Conshohocken PA Use oil free scrap. Will dry scrap if necessary. CA 29 Gregg Industries El Monte CA Only clean & dry scrap is used TX 10 Greens Bayou Foundry Houston TX Use only clean oil free scrap & pig. MN 07 Grede Foundry St. Cloud MN We purchase and use only clean black clip when available. KS 03 Grede Foundries, Inc. Wichita Wichita KS Only clean ( oil free) low alloy carbon steel and foundry returns ( home scrap) are used in the charge. VA 06 Graham White Manufacturing Company Salem VA Use graded/ dry scrap  charge is dry stored and does not require additional drying. TX 15 Goulds Pumps  Turbine Division Foundry Slaton TX Only clean dry steel plate, stuctural steel, scrapped castings and casting returns are melted. GA 04 Goldens' Foundry & Machine Co., Inc. Columbus GA Cleaning & drying in preheater CA 34 Globe Iron Foundry, Inc. Commerce CA Using as dry and clean scrap as possible. AL 06 Glidewell Specialties Foundry Company Calera AL Facility purchases very clean scrap with no rust and very little machine oil ( punchings and stampings) ID Company City St Survey Response 8 MI 04 Giddings & Lewis Casting Technology Menominee MI Our scrap is very clean  no oil, dirt, paint, etc. Scrap is preheated before use ( permit condition). NJ 01 General Foundry Flagtown NJ Clean select steel scrap is purchased, returns are shot blasted NY 04 Frazer & Jones Co. Solvay NY Purchase # 1 steel busheling free of any residues ( oil, etc.). Prior to melting, steel is dried in a Venetta preheater to approximately 1000 deg. F. CO 02 Fountain Foundry, Inc. Pueblo CO Torch dry scrap NC 04 Foundry Service Co Biscoe NC All scrap passes through a preheater prior to charging. OK 07 Flanagan Iron Works Tulsa OK Use only # 1 clean plate steel, pre alloyed ingot, and low phosphorus low manganese pig iron to produce all alloys. KS 06 Ferroloy Foundry, Inc. Wichita KS Reasonably clean and dry scrap. No painter grease. Gas fired pre heater KS 01 Farrar Corporation Norwich KS Charge material is limited to pig, returns, and clean structural steel. Charge is dried prior to putting in furnace. RI 03 Fairmount Foundry Inc. Woonsocket RI Purchase of cleanest and dry materials. ME 2 Etheridge Foundry Portland ME Scrap is hand picked 2 times to ensure no contaminants ME 01 Enterprise Foundry, Inc. Lewiston ME Selected # 1 steel scrap, all iron returns cleaned prior to charging PA 46 EMI Company Erie PA High grade scrap is purchased. Preference of purchase is given to oil free scrap. Incoming scrap is dried before melted. IA 16 Eagle Iron Works Des Moines IA Selected scrap supplier and A 36 mild steel from our fabrication shop. Also operation of wet scrubber ( EIW emissions pt # 2). Restricted to 5000 hours/ year per conditions of polk county operating permit # 00215. OR 05 Eagle Foundry CompanyEagle Creek OR Purchasing requires non oily, no paint clean scrap from scrap suppliers WA 07Dyko Foundry Spokane WA All scrap is clean. OR 03 Durametal Corporation Tualatin OR All scrap steel being used is dried with a gas dryer MI 05 Dock Foundry CompanyThree Rivers MI Structural scrap  preheating ( dry & clean) MS 01 Dews Foundry Hattiesburg MS Good scrap selection, no mixed scrap is used, scrap is dried. WA 05D & L Foundry, Inc. Moses Lake WA We manually sort the scrap to discriminate against materials other than iron, i. e., aluminum, brass, bronze, lead, rubber MI 37 CWC Castings Division of Textron Inc. Muskegon MI Melting selected clean scrap & returns plus virgin materials only. RI 02 Cumberland Foundry Cumberland RI All scrap whellabrated and or cleaned before melting CA 25 Covert Iron Works Huntington ParkCA Use only clean scrap. No oil, paint, grease, trash FL 03 Consolidated Castings, Inc. Jacksonsville FL Use only selected clean scrap and returns. Selected scrap is 100% glass mold high grade iron purchased from one source. CA 19 Commercial Castings Fontana CA We purchase only clean degreased iron broken cast and brake drums OH 60 Commercial Casting Co. New PhiladelphiaOH Scrap is clean and hand loaded. IN 15 Columbia City Engineering, Inc. Columbia City IN Use clean scrap  use gray iron scrap for base charge ( less inoculation & carbon additions  slag). Natural gas torch burn off in closed lid. TN 06 Clinch River Casting, Inc. Caryville TN Only new, reject cast iron scrap and new reject steel scrap is melted TN 12 Cleveland Foundry & Mfg. Co, Inc. Cleveland TN Purchase clean scrap iron, steel & pig iron, hoe scrao cleaned in shotblast to prepare for charging, charge done by hand TN 16 Clarksville Foundry, Inc. Clarksville TN All scrap is dry, or allowed to air dry, before charging. Scrap with no contaminants is preferred AL 19 Citation Foam Casting Columbiana AL Scrap is dried, preheated, prior to charging MA 06 Charlette Bros Foundry Blackstone MA Clean scrap  no greasy parts. ID Company City St Survey Response 9 wv 02 Centre Foundry Wheeling WV Scrap is dried and furnace lid is tightly sealed. OK 09 Central Machine & ToolEnid OK All scrap is # 1 clean hand sorted and shot blasted material PA 12 Centec Roll CorporationBethlehem PA Scrap selection is limited by: low moisture, free of oils, and free of coatings ( also aerosol cans are not selected for melting) IL 17 Castwell Products, Inc. Skokie IL All charges are preheated ( dried) OH 14 Cast Fab Technologies, Inc. Cincinnati OH Clean slitter scrap return are used, as well as all scrap is dried before being dumped into furnaces TN 05 Camden Casting Center Camden TN Scrap selection, preheating MI 35 Burgess Norton Mfg. Co. Plant 3 Muskegon MI Scrap is purchased as a # 1 clean stamping waste. No oils, grease or rust. VT 02 Brown Foundry Swanton VT Charge consists of pig iron, clean steel, and foundry returns. MI 28 Briggs & Stratton Corp Revenna MI Only high grade structural scrap steel used. AL 38 Brewton Iron Works, Inc. Brewton AL All scrap is dried before charging. Only scrap steel & returns are cured. No CI scrap is ever used. Dried consists of 1 small gas torch. IN 14 Bremen Castings, Inc. Bremen IN Scrap metal is clean by shot blasting process prior to melting. NJ 02 Bierman Everett FoundrIrvington NJ Clean purchased scrap and pig iron; kept dry. MI 29 Bernier Cast Metals, Inc. Saginaw MI Use of washed & degreased scrap AR 03 Bentonville Castings Co. Bentonville AR Scrap is delivered to an inside storage area. We do not melt automotive engine parts. Melting scrap is very selective. pa 13 Benton Foundry, Inc Benton PA Only clean scrap, selected to close parameters, is purchased, then dried before melting. CA 05 Bell Foundry Company South Gate CA Scrap loads are inspected 100%. Galvanized and oily materials are rejected. No debris is accepted in the scrap loads. WI 08 Belgium Foundry Belgium WI Purchase clean scrap only WI 20 Bay Engineered CastingsDePere WI We pay a premium for extremely clean scrap. AL 07 Barry Pattern & FoundryBirmingham AL Small, broken, clean cast iron delivered for melting AL 29 Bama Foundry, Inc. Montgomery AL Purchase of clean, sorted scrap. WI 14 Baker Manufacturing Co. Evansville WI We have a scrap inspection/ certification program designed to ensure that all scrap is clean, dry and oil free. WI 06 Austin Gray Iron Foundry Corporation Sheboygan WI Scrap selection, cleaning prior to melting, preheat drying to clean scrap IL 11 Aurora Industries, Inc. Montgomery IL Purchase only clean scrap visual inspection vendors must meet specifications AL 30 American Safety Tread Pelham AL Dry clean new pig iron or remelt is loaded. TX 07 Alamo Iron Works Foundry San Antonio TX Limited to melting clean structural steel or our own re melt only, convenant of air control permit. AL 03 Alabama Ductile Casting Co. Brewton AL Scrap selections: Preheater to heat scrap and remove excess oil. MT 01 AFFCO, Inc. Anaconda MT Furnaces are 1000 lb. & 2000 lb. capacity so have to hand charge. Use only clean scrap. Don't preheat scrap. MN 04 AEGoetze  Lake City Lake City MN Screen scrap steel, shot blast gates & runners, dry chips TN 08 Acheson Foundry & Machine Works, Inc. Chattanooga TN Only purchase clean bushling scrap, pig iron, rail crops, & shot blast rusty scrap TX 25 A A Foundries, Inc. San Antonio TX Clean, dry scrap returns Steel Foundries ID Company City St Pollution Prevention CA 13 Wyman Gordon Company San Leandro CA Furnaces are charged with only ultra clean ingots or gates and risers CT 02 Wyman Gordon Investment Castings, Groton CT Only new alloy is melted. Melt only what's needed ID Company City St Survey Response 10 Inc. CA 03 Westelectric Castings Commerce CA Clean scrap, free of contamination from oil, grease or similar smoke producing material. A slag cover is maintained over molten productin metal during melting and pouring operations. WI 52 Waukesha Foundry Inc. Waukesha WI Clean scrap is used, separate by type and wheelabrate MN 14Waltek Inc. Anoka MN Majority of metal melted is bar stock. TX 17 Victoria Precision Alloys, Inc. Victoria TX We only melt clean scrap or ingots, nothing containing oils, paints, etc. AL 08 Vermont American, Auburn Division Auburn AL All scrap material used is clean & dry. All returns have been through shot blast. UT 03 Torry Metals Corp. Spanish Fork UT We use only clean, dry, and returns scrap. MO 03 Carondelet Corporation Pevely MO Most scrap is cleaned in a blast machine before melting OH 65 The Bimac Corporation Dayton OH We buy certified ingot and clean scrap only. TX 08 Texcast, Inc Houston TX We melt virgin metal only, no scrap. All material is shotblasted before melting TX 26 Texas Precision Metalcraft, Inc. Sugar Land TX We use only certified ingot and bar stock for melting MI 36 Temperform Corporation Novi MI Only clean dry oil free scrap is purchased.

CA 01 Techni Cast Corp. South Gate CA Use only clean scrap. All turnings & borings from Machine shop are washed/ dried before using. TX 22 Sure Cast, Inc. Burnet TX Use of segregated scrap, use of dry metal. WV 03 Sturm Inc. Barboursville WV Sturm buys only certified AOD ingot to use as melt stock ( cleaned and shotblast before delivery). CA 35 Strategic Materials Corp. South Gate CA Scrap is cleaned off premise MI 31 Steeltech Ltd. Grand Rapids MI Most charges are made from pure metals and any scrap used is clean and dry. ( emissions from our small induction furnaces fall below the lower permissable limits). WI 32 Stainless Foundry & Engineering, Inc. Milwaukee WI Purchased scrap must be free from all oil.

MO 10 St. Louis Precision Casting Company St. Louis MO Only clean, dry material is used MS 04 Southern Cast Products Meridian MS Natural gas afterburner to combust fume during meltdown. AL 10 Southern Alloy Corporation Sylacauga AL Scrap selected for cleanliness. All scrap is dry at charging. Dirty scrap is shot blasted before charging TX 32 Smith Steel Casting Co. Marshall TX Use clean scrap IA 07 Sivyer Steel CorporationBettendorf IA Use only clean and dry scrap. WI 04 Shelmet Precision Casting Company Wild Rose WI Facility buys certified ingot AOD Refined. Leave metal molten for the shortest time possible. MI 01 Shellcast, Inc. Montague MI All material must be clean & dry to melt. WA 14 SeaCast/ Eagle, Inc. Marysville WA We purchase ingot and scrap in the cleaned condition, ready to use. Internal revert is shot blast cleaned if necessary before remelting. IA 01 Seabee Corporation Steel Hampton IA Facility buys high grade clean scrap to keep contaminates low IL 21 Sarcol, Inc Chicago IL Clean re melt material by sandblasting MI 22 RLM Industries, Inc. Oxford MI Scrap is purchased blasted, washed and dried MO 07 Ralston Purina Comp. Pet Products Support St. Louis MO Remelt is cleaned prior to use. Burn off stage is also used to burn wax from shell for a clean burnout. WI 12 Racine Steel Castings Racine WI Purchase clean scrap WA 12Quali Cast Foundry, Inc. Chehalis WA Clean scrap selection. ID Company City St Survey Response 11 WI 46 Precision Metalsmiths, Inc. Markesan WI No scrap metal is used. Only prime ingot or remelted prime ingot is used. OH 42 Precision Metalsmiths, Inc. Euclid OH No scrap metal is used. Only prime ingot or remelted prime ingot is used WI 46 Precision Metalsmiths, Inc. Markesan WI Internal scrap castings and sprue is remelted into reusable ingots. Metal is without impurities. CA 06 Precision Cast Products Oakland CA All scrap is shot blasted or cleaned by other means. CT 04 Philbrick Booth & Spencer, Inc. Hartford CT Argon blanket, scrap selection PA 24 Pennsylvania Steel Foundry & Machine Company Hamburg PA Purchase low phosphorous/ low sulphur scrap which is also clean of oil. All revert material is mechanicaally cleaned before melting. PA 43 Penncast Corporation Marietta PA Only clean dry scrap is used IL 12 Penberthy, Inc Prophetstown IL Only clean scrap is used OR 02 PED Manufacturing, Ltd. Oregon City OR No scrap is used. All charge material consists of virgin ingot or gates & risers which are cleaned by grit/ shot blasting. WI 31 OMC Milwaukee Milwaukee WI Charge materials purchased free of oil, gas, grease and scale, revert is cleaned and dried. OH 37 Ohio Foundry, Inc. Tallmadge OH Buy " premium" SAE 1008 clean scrap from a stamping operation. All iron is made from merchant pig. PA 52 Nova Precision Casting Auburn PA Only drummed process scrap is primary melt source. WA 04Northwest Castings Seattle WA We use all prepared scrap at our facility. WI 34 Northern Stainless SteelPewaukee WI Only very clean charge materials are used. WI 07 Northern Precision Casting Co., Inc. Lake Geneva WI Only melt clean ingots, bar stock or revert.

TX 02 National Foundry & Mfg. Crane TX Clean scrap plate only  500 pounds per hour PA 28 Muncy Foundry Muncy PA A liquid argon blanket is used when melting steel alloys. Plate scrap is purchased to a maximum .5% oil and/ or dirt content. All scrap is processed through a scrap dryer. OH 04 MorCast Precision, Inc. Columbus OH All stock is purchased clean, dry and certified and appropriately stored ( covered) for use. MO 06Monett Steel Castings Monett MO Use of clean scrap, temparature control procedures to avoid oxidation, shot blasting of scrap, use of coagulant during slagging MN 06Minncast Inc. Fridley MN We purchase heavy section, clean and size material for faster melting and reduced oxidation. WA 09Meltec Division of Young Corporation Seattle WA Clean scrap IN 31 MedCast Warsaw IN Only clean scrap is used in the coreless induction furnace. TX 01 Manufactured Alloys, Inc. Luling TX No scrap used WA 02Mackenzie Specialty Arlington WA We purchase clean scrap and have a dry storage UT 02 Maca Supply Company Springville UT A high quality scrap is selected and kept clean. CA 12 Lodi Iron Works, Inc. Galt CA Koawool cover for furnace; ultra clean starting materials. NH 01 Joy Technologies Inc. Claremont NH Only clean, contaminant free scrap is used. OK 11 Jencast, A Division of Jensen International South CoffeyvilleOK Melting of non painted scrap steel and not melting automotive engine parts. WI 21 Investment Casting Plant Fond du Lac WI All returns are blast cleaned prior to loading into furnace. All new material is clean prior to loading into furnace. MI 23 Huron Casting, Inc. Pigeon MI Scrap selection is a # 1 busheling with minimum oil content NH 03 Hitchiner Mfg. Co., Inc. Milford NH Only ultra clean metal used ( no oil, no grease) dry metal use ID Company City St Survey Response 12  Milford Facility only. PA 54 Harcast Co., Inc. Chester PA Charge material is shot blast cleaned within 24 hours of use. UT 05 GSC Foundries, Inc., Steel Division Ogden UT melting prime ingot under argon cover WI 26 Grede Foundries, Inc  Milwaukee Steel Division Milwaukee WI Scrap stored indoors, purchase only premium punchings scrap PA 04 Goulds Pumps, Inc. Ashland PA Majority of purchased scrap is purchased clean. CO 04 Goltra Castings Co., Inc. Golden CO Clean scrap is utilized. VA 07 Newport News Shipbuilding and Dry Newport News VA Scrap selection  no oily, galvanized or wet scrap is used OH 09 Foundry Division Dayton OH Purchased scrap must be oil free & clean. Purchased clean and oil free basic elements ( chrome, nickel, copper, iron, etc.). OH 38 Fisher Cast Steel Prod. Inc. West Jefferson OH Fisher buys all degreased scrap and shot blast most of the returns. OR 04 ESCO  Plant 3 Portland OR ESCO accepts clean scrap only PA 09 Empire Steel Castings, Inc. Reading PA We purchase and use low phosphorous/ low sulphur plate scrap. All revert material is mechanically cleaned before melting. OH 24 Elano Corporation, Casting Division Xenia OH No scrap metal  certified refined ingot free of impurities with clean surfaces MI Eagle Alloy, Inc. Muskegon MI Clean scrap is used PA 30 Duraloy Technologies, Inc. Scottdale PA All scrap and virgin material to be melted at this facility is required to be clean and oil/ solvent free. AZ 05 Dolphin, Incorporated Phoenix AZ 1) Ingot and clean scrap. 2) Surface protection: air liquide ( SPAL) process is a patented process for producing an inert argon environment above the molten metal surface thus reducing oxidation and the resultant emissions. PA 19 Delvest, Inc West Chester PA All metals are cleaned and dried before charging furnace. TX 16 Delta Centrifugal Corporation Temple TX Due to low carbon specification on produced alloys, only clean scrap material is purchased for melting. CA 33 Dameron Alloy Foundries Compton CA Clean raw material  use liquid argon blanket PA 27 Damascus Steel Casting Co. New Brighton PA Scrap is dried prior to charging; internal scrap is shot blasted; charging, melting and tapping conducted within a building. WI 56 Craft Cast Jackson WI All charge materials are purchased clean and dry. TX 05 Consolidated Castings Corporation Hutchins TX Scrap is blast cleaned before use. No oily scrap used.

OH 26 Concorde Castings, Inc. Eastlake OH Metal is high purity master metal usually melting in 20 to 100 lb. charge SC 01 Conbraco Industries, Inc. Conway SC All scrap is wheelabrated OR 09 Columbia Steel Casting Company, Inc. Portland OR Only select clean scrap is charged.

CA 16 Coastcast Corporation Rancho Dominguez CA The casting trees are quenched immediately after the metal has been poured PA 48 CMI Tech Cast, Inc. Myerstown PA Raw materials are stored outside  causing materials to rust. Canopy is scheduled for construction and to be completed by April 98. All furnaces can't be run at same time. PA 25 CMI Quaker Alloy, Inc. Myerstown PA We purchase clean scrap material ( low phosphorus and low sulfur). All internal revert is mechanically cleaned before melting. ID Company City St Survey Response 13 TX 23 Centrifugal Castings, Inc. Temple TX All scrap vendors are required to supply scrap that has been cleaned by a method approved to remove trash and dirt. IL 08 Cast Rite Steel Castings Corp. Chicago IL Scrap selection is very clean, no rust IN 21 Casteel Service, Inc. Kingsbury IN Casteel's practice  is to consistantly purchase only good quality oxide free scrap. WI 03 Cast Tools, Inc. Racine WI All of melt stock comes in as plate scrap from rolling mills. It is selected, weighed and shot blasted in preparation for melting. It is completely dry. Our furnaces are highly density charged, small additions are made and no fumes off melting cylce CA 17 California Electric SteelAngels Camp CA We specify that all scrap, returns and alloys be free of contaminants and foreign material. PA 01 Brighton Electric Steel Casting Company Beaver Falls PA Only clean, dry scrap used in melting operations OK 01 Big Four Alloy CastingsTulsa OK Clean scrap MI 12 Bay Cast Incorporated Bay City MI Scrap selection, drying WA 13Atlas Foundry & Machine Company Tacoma WA We use clean dry blast scrap or returns only.

MI 08 Astech, Inc. Vassar MI Buy washed and dried low alloy steel punchings for melting TX 06 American Spincast, Inc. Belton TX Drying borings, processed scrap. CT 05 American Industrail FerroCast Pawcatuck CT Wheelabrated, dry or virgin stock AL 20 American Alloy Products, Inc. Cullman AL Our primary source of melting stock is clean plate with our secondary being AOD ingot. We also remelt all gates, heads, rivers and runners. AZ 01 American Aerospace Technical Castings Inc. Phoenix AZ All scrap is cleaned prior to melting CA 07 Amcast Precision Products Rancho Cucamonga CA Only prime ingot is used.

IA 10 Alloys Foundry Cedar Falls IA Scrap selection and drying IN 22 Aero Metals, Inc. LaPorte IN All scrap is clean and dry CA 02 Acme Castings, Inc. Huntington ParkCA Cleaning in shot blasting machine and drying when wet. TN 07 Accu Cast Chattanooga TN Purchase AOD refined melt stock and wheelabrated certified plate material. 14 TABLE 3. SCRAP PROGRAMS   CUPOLA MELTING ID Company City St Survey Response TN 01 Wheland Foundry Chattanooga TN Coke breeze screening; aggresive scrap control procedures. MD 02 ABC Rail Corp., Baltimore Baltimore MD Scrap selection: avoid lead containing sewer pipe seals, non ferrous metals. No scrap washing is done. KS 02 ACME Foundry Coffeyville KS Reduce emissions by buying clean, oil free scrap metal. CA 08 Alhambra Foundry Alhambra CA We purchase clean dry scrap CA 26 American Brass & Iron Foundry Oakland CA Acceptance inspection on incoming shipments. Incentive programs for removing non ferrous metals. IN 12 Auburn Foundry Plant # 1 Auburn IN Strict QA/ QC specifications are followed for all scrap purchased for cupola melting ( i. e. no paints, oils, lead, etc.) MN 09 Badger Foundry Winona MN Scrap selection and inspection AL 39 Bells Novelty Casting Co. Anniston AL We hand select our cupola scrap as to keep foreign materials such as brass, lead, alum., out because this not only is a source for pollution, but contaminates our iron alloy. IN 14 Bremen Castings Bremen IN Purchase of quality scrap for cupola SC 02 Cast Products Co. Westminster SC All scrap is free of dirt or grime IL 03 Chicago Heights Gray Iron Foundry, Chicago Heights IL Use clean dry scrap iron  clean pig iron  new steel  no greasy scrap used IN 01 Chrysler Indianapolis IN Sort scrap to reduce lead and electrical components IN 16 Decatur Casting Decatur IN Scrap selection NE 04 Deeter Foundry Lincoln NE Purchase of clean # 1 machinery cast without belts, hoses, bearings, etc. PA 34 Donsco, Inc. Wrightsville PA oil free, clean, shreaded plate, no galvanized scrap, primarily using steel rail crop. PA 10 EAFCO, Inc. Boyertown PA Only clean dry scrap is charged. MI 14 East Jordan Iron East Jordan MI Purchase clean scrap, radiation device cleans scrap TX 29 Gainesville Foundry, Inc. Gainesville TX clean scrap purchased MI 33 GM Saginaw MI Sort and Scrap, follow a scrap specification MN 10 Gorman Company Winona MN Scrap is stored inside. MI 17 Great Lakes Casting Corp. Ludington MI Melt personnel inspects scrap for lead pipe, wheel weights, etc. during unloading. Purchase order restrictions. MI 27 Grede Vassar, Inc. Vassar MI We attempt to purchase only paint free, oil free, and alloy free scrap VA 08 Intermet Corp Lynchburg VA Scrap selection MA 09 Jahn Foundry Corp. Springfield MA Written cleanliness specifications applied to all purchase orders for furnace charge materials MI 30 Kurdziel Industries Rothbury MI Purchase specifications for incoming scrap metal. Melt personnel review scrap for presence of materials not meeting specifications OH 44 Kurdziel Iron of Wauseon Wauseon OH Specifications on purchased scrap. Melt personnel inspect scrap for unwanted materials MA 05 LeBaron Foundry Brockton MA Use no oily scrap IA 08 Max Cast Kalona IA Dry clean scrap NY 01 Oneida Foundries Oneida NY Buy only clean scrap, no oil AL 37 Opelika Foundry Opelika AL OFCO limits the size of scrap charged to the cupola to prevent hangups which would cause OFCD to bypass the baghouse. IA 13 Progessive Foundr Perry IA Low phos  12; no bronze, brass, aluminum, soil pipes. IA 02 Quality Foundry Co. Stockton IA A very clean charge is used  consists of 30% pig iron, 20% rail steel, 50% clean machining cast or foundry return RI 01 Seaboard Foundry Inc. Johnston RI Melt mostly pig iron & structural steel trails. No automotive scrap is used which may contain oil and lead. ID Company City St Survey Response 15 PA 16 Somerset Foundry Somerset PA Only clean dry scrap is charged. NE 02 Spitz Foundry, Inc. Hastings NE Do not melt any greasy iron; all hand picked IN 32 Sterling Casting Buffton IN Scrap selection AL 22 Stockham Valves Birmingham AL Selection of clean ( no grease, oil, lead, paint) scrap TX 12 Taylor Foundry Company Wichita FallsTX Scrap specification state no lead bearing materials or other nonferrous parts and all cast must be reasonably free of grease and dirt. Nonferrous attachments are removed prior to charging. OH 11 The Blanchester Foundry Company, Blanchester OH Purchase cleaned scrap for cupola charge.

OH 05 Wagnerware Corp Sidney OH Scrap selection  pig iron  inhouse scrap PA 20 Urick Foundry Erie PA Purchase only clean dry scrap, keep under roof until used. AL 01 US Pipe & Foundry Birmingham AL Dust suppression by spraying scrap iron with water prior to charging. MA 02 Ware Foundry, Inc. Ware MA All washed motor cast WI 01 Waupaca Foundry, Inc.  Plant 1 Waupaca WI QA program with scrap suppliers to prevent lead, excess zinc and other unwanted metals from entering process. NY 06 Wormuth Brothers Foundry, Inc. Athens NY Only clean dry scrap is charged into cupola PA 17 Wyano Foundry Wyano PA Only clean dry scrap is charged. PA 03 Zurn Cast Metals Operations Erie PA Scrap is carefully visually inspected to ensure absense of grease, oil, dirt, etc. 2 TCLP = toxicity characteristic leaching procedure, used to determine the quantity of specific compounds that may leach from a waste material.

3 Examples of scrap available for sale or purchase: Sheet Iron Scrap, White Goods, Mixed Steel Can Scrap, Bundled Steel Can Scrap, E. C. Briquettes, Mixed Scrap Iron & Steel, No. 1 Steel, Special Plate Punchings, No. 2 Steel, No. 3 Steel ( Unprepared Bushling), No. 4 Steel ( Silicon Bushling), No. 4 Shredded Steel, Mixed Cast Iron, Sorted Machine Cast, Sorted Automotive Cast, Unclean Motor Block, Clean Motor Block, Whole Prepared Car Bodies, Flattened Car Bodies, Green Car Bodies, Mixed Turnings & Borings, Short Shoveling Borings, Mill Scale, Iron Oxides, Manganese Steel. ATTACHMENT A. SUMMARY OF INFORMATION ON SCRAP SPECIFICATIONS 1. What are the purposes of scrap inspections and specifications?

! The primary purpose given by most foundries is to maintain product quality   to keep the chemistry of the molten iron within specifications. Most foundries perform extensive metallurgical analyses of the molten iron.

[ If the iron is out of specification and the scrap quality is the suspect, most plants can trace back to the type of scrap used and its source. The supplier may be notified or placed on a " quality hold."]

! Environmental concerns are also one of the purposes. Limiting lead content was most often mentioned, as was cadmium.

[ Lead and cadmium compounds are relatively volatile and end up in the pollution control dust or sludge, scrubber water, or as air emissions. Plants do not want their dust classified as hazardous ( such as exceeding certain TCLP2 limits). Consequently, a measure of success is dust or sludge that does not fail the TCLP for toxic metals.]

2. What are typical scrap specifications?

! Plants usually specify scrap by type. 3 Standard specifications are provided by the Iron Casting Research Institute ( ICRI) and the Institute of Scrap Recycling Industries ( ISRI). They also define " cleanness" and " alloy free" for ferrous scrap:

a. Cleanness. All grades shall be free of dirt, nonferrous metals, or foreign material of any kind, and excessive rust and corrosion. However, the terms " free of dirt, nonferrous metals, or foreign material of any kind" are not intended to preclude the accidental inclusion of negligible amounts where it can be shown that this amount is unavoidable in the customary preparation and handling of the particular grade involved.

c. Residual alloys. Wherever the term " free of alloys" is used in the classifications given herein, it shall mean that any alloys contained in the steel are residual and have not been added for the purpose of making an alloy steel. Steel scraps shall be considered free of alloys when the residual alloying elements do not exceed the following percentages: 17 percent Nickel 0.45 Chromium 0.20 Molybdenum 0.10 Manganese 1.65 The combined residuals other than manganese shall not exceed a total of 0.60 percent.

! Some specify " no paint" or no more than 5% painted, no PCBs, no dripping liquids, free of excessive fines and rust, no aluminum, no oil. Some exclude specific types of scrap, such as no transmissions, no shock absorbers.

3. How is scrap inspected?

! Very few plants actually sample and analyze scrap. Periodic visual inspections is a common technique. However, that only detects something obvious, such as paint or liquid contamination.

! Sampling scrap is difficult. The load may come in with thousands of different pieces. Some scrap is bundled and compressed, which makes it difficult to know what is in the center. Several plants said they depended on the supplier to inspect and maintain quality.

4. Do scrap specifications depend on type of furnace or whether gray or ductile iron?

! No. 18 SUMMARY OF A SAMPLING OF SCRAP INSPECTION PROGRAMS Company Furnace Iron type Summary 1 electric arc; induction gray visual inspection ( e. g., dripping liquids); spot check metal content; lead is a concern 2 cupola; induction gray visual check; rely on supplier certification 3 induction gray visual check; rely on supplier certification 4 induction gray & ductile visual check for liquids; rely on supplier certification ( dealer may wash or dry scrap)

5 induction gray visual check car scrap; dry scrap onsite; periodic sampling; specifications for suppliers 6 cupola No lead in scrap; rely on dealer for pre processing and pre grading; visual inspection for no paint or contaminants 7 cupola; electric are;

induction gray Specify to dealer it must be " lead, PCB, paint free"; spot visual inspections; cannot see inside bundles, not reasonable to sample 8 cupola gray & ductile Specify no lead, cadmium, or paint; no gear boxes or transmissions 9 induction ductile Specify free of fines, dirt, no more than 5% paint; steel must be free of alloys 10 cupola gray & ductile Specify scrap chemistry; free of oil and grease 11 cupola gray No lead, chromium, cadmium 12 cupola ductile & gray Specify no lead, aluminum, transmissions, shock absorbers, shredded cars 12 cupola visual inspection; pre graded & pre processed scrap 14 cupola gray specify size & shape 15 induction iron for boilers clean scrap that meets ASTM specs.; spot check for metal content; concern about lead


[Federal Register: May 16, 2007 (Volume 72, Number 94)]
[Notices]
[Page 27548]
[DOCID:fr16my07-52]

-----------------------------------------------------------------------

DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. TS07-4-000]

Central Vermont Public Service Corporation; Notice of Filing

May 8, 2007.
    Take notice that on April 25, 2007, Central Vermont Public Service
Corporation filed an application for partial exemption from the
standards of conduct pursuant to Order No. 2004, 105 FERC 61,248
(2003), and sections 358.1(d), 358.2(a), 358.4(a) and (c) and 358.5(a)
and (b) of the Federal Energy Regulatory Commission's Regulations.
    Any person desiring to intervene or to protest this filing must
file in accordance with Rules 211 and 214 of the Commission's Rules of
Practice and Procedure (18 CFR 385.211, 385.214). Protests will be
considered by the Commission in determining the appropriate action to
be taken, but will not serve to make protestants parties to the
proceeding. Any person wishing to become a party must file a notice of
intervention or motion to intervene, as appropriate. Such notices,
motions, or protests must be filed on or before the comment date. On or
before the comment date, it is not necessary to serve motions to
intervene or protests on persons other than the Applicant.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper using the ``eFiling'' link at http://www.ferc.gov.
 Persons unable to file electronically should submit an

original and 14 copies of the protest or intervention to the Federal
Energy Regulatory Commission, 888 First Street, NE., Washington, DC
20426.
    This filing is accessible on-line at http://www.ferc.gov, using the

``eLibrary'' link and is available for review in the Commission's
Public Reference Room in Washington, DC. There is an ``eSubscription''
link on the Web site that enables subscribers to receive e-mail
notification when a document is added to a subscribed docket(s). For
assistance with any FERC Online service, please e-mail
<EMAIL_ADDRESS>or call<PHONE_NUMBER> (toll free). For

TTY, call<PHONE_NUMBER>.
    Comment Date: 5 p.m. Eastern Time on May 25, 2007.

Kimberly D. Bose,
Secretary.
 [FR Doc. E7-9316 Filed 5-15-07; 8:45 am]

BILLING CODE 6717-01-P


[Federal Register: January 3, 2006 (Volume 71, Number 1)]
[Notices]
[Page 103]
[DOCID:fr03ja06-60]

-----------------------------------------------------------------------

DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

[Docket No. RP06-151-000]

Kern River Gas Transmission Company; Notice of Filing of
Revisions to Annual Fuel Reports

December 27, 2005.
    Take notice that on December 21, 2005, Kern River Gas Transmission
Company (Kern River) filed schedules showing prior-period adjustments
to the gas compressor fuel and lost and unaccounted-for (L&U) gas
balances reflected in the annual fuel reports submitted by Kern River
for calendar years 2000 through 2004.
    Kern River states that it has served a copy of this filing upon its
customers and interested state regulatory commissions.
    Any person desiring to intervene or to protest this filing must
file in accordance with Rules 211 and 214 of the Commission's Rules of
Practice and Procedure (18 CFR 385.211 and 385.214). Protests will be
considered by the Commission in determining the appropriate action to
be taken, but will not serve to make protestants parties to the
proceeding. Any person wishing to become a party must file a notice of
intervention or motion to intervene, as appropriate. Such notices,
motions, or protests must be filed in accordance with the provisions of
Sec.  154.210 of the Commission's regulations (18 CFR 154.210). Anyone
filing an intervention or protest must serve a copy of that document on
the Applicant. Anyone filing an intervention or protest on or before
the intervention or protest date need not serve motions to intervene or
protests on persons other than the Applicant.
    The Commission encourages electronic submission of protests and
interventions in lieu of paper using the ``eFiling'' link at http://www.ferc.gov.
 Persons unable to file electronically should submit an

original and 14 copies of the protest or intervention to the Federal
Energy Regulatory Commission, 888 First Street, NE., Washington, DC
20426.
    This filing is accessible on-line at http://www.ferc.gov, using the

``eLibrary'' link and is available for review in the Commission's
Public Reference Room in Washington, DC. There is an ``eSubscription''
link on the Web site that enables subscribers to receive e-mail
notification when a document is added to a subscribed docket(s). For
assistance with any FERC Online service, please e-mail
<EMAIL_ADDRESS>or call<PHONE_NUMBER> (toll free). For

TTY, call<PHONE_NUMBER>.

Magalie R. Salas,
Secretary.
 [FR Doc. E5-8183 Filed 12-30-05; 8:45 am]

BILLING CODE 6717-01-P


National Water Quality Assessment Program ( NAWQA) Analysis of Nutrients March 3, 2003 The first synthesis of NAWQA data ( and the only one currently available) is for Nutrients and Pesticides. It is contained in " The Quality of Our Nation's Waters   Nutrients and Pesticides". The following summarizes the information available for nutrients.

Purpose: The purpose of the NAWQA program is to develop long term, consistent and comparable information on streams, ground water, and aquatic ecosystems to support sound management and policy decisions. The NAWQA program tries to answer the following questions relating to nutrients: 1. Which nutrients are found in streams and ground water across the nation? At what concentrations? 2. Are elevated concentrations more prevalent in certain geographic regions and environmental settings? 3. How do differences in land use, chemical use, land management practices, and natural processes help explain differences in vulnerability to contamination of streams and ground water? 4. Are nutrient concentrations elevated only at certain times of the year? Are concentrations changing over time? 5. What are the implications to human health and the environment? 6. How is this information useful for guiding future research, monitoring, and watermanagement and protection strategies related to nutrients?

Chemicals: The program includes 500 chemical constituents.

Sample Locations: The NAWQA program focuses on water quality in more than 50 major river basins and aquifer systems, referred to as " Study Units". Together, these include water resources available to more than 60 percent of the population in watersheds that cover about one half of the land area of the conterminous U. S. The report on nutrients uses the information from the first 20 study units. Attachment I shows the location of these study units.

Sample Design: Streams and shallow ground water in agricultural, urban, and some undeveloped ( mostly forested) settings were studies in the first 20 study units. The agricultural areas are diverse in climate and geography, and they span coastal, desert, and temperate environmental settings. They include areas of corn and soybean production in the Midwest; areas of production of wheat and other grains in the Great Plains; areas of mixed row crop and poultry production in the East;; rangeland grazing and cattle feeding operations in the arid Southwest; and areas of intensive production of grain, fruits and nuts, vegetables, and specialty crops in California and the Pacific Northwest. Sampling of streams and shallow ground water in urban areas represented primarily residential land use, typically with low to medium population density. In general, the urban assessments focused on non point sources of contaminants, although some sampling or rivers was done downstream from major metropolitan areas which have point discharges from municipal wastewater treatment plants. Nutrients also were assessed in major rivers and in aquifers commonly used for drinking water. These samples represent integrated water quality effects from multiple land uses and environmental settings that occur within relatively large contributing areas. The following table summarizes the sites sampled in the study.

SUMMARY OF SAMPLE SITES Type of Sample Number of Samples Relatively Undeveloped Forest or Rangeland Streams 28 Shallow ground water studies 4 Agricultural Land Streams 75 Shallow ground water studies 36 Urban Land Streams 22 Shallow ground water studies 13 Mixed Land Use Streams 87 Major aquifers 33 Study Duration: NAWQA began investigations in 20 study units in1991 and phased in work in more than 30 additional basins by 1997. The report on nutrients uses the information from the first 20 study units.

Evaluation Method: Nutrient levels are summarized on U. S. maps to facilitate analysis and comparison of regional and national patterns. Concentrations or detection frequencies are ranked according to three categories: lowest for the lowest 25%; medium for the middle 50%;;; and highest for the highest 25% of concentrations or detection frequencies among all stream sites or ground water studies. For nutrients in streams, flow weighted total nitrogen and total phosphorus concentrations were determined for each stream site for 1994 and 1995 and were averaged. For shallow ground water, median nitrate concentration was determined for each ground water study.

The maps of national results also show patterns of non point inputs of nitrogen and phosphorus. Based on county agriculture statistics for 1987 and 1992, average annual nitrogen and phosphorus inputs to agricultural and urban land were estimated from commercial fertilizer sales ( 1991 94) and manure from animals ( 1992). Average annual input of nitrogen from the atmosphere was estimated from 1991 94 data.

Results are reported as total nitrogen ( nitrate, nitrite, ammonia, and organic nitrogen) and total phosphorus ( phosphates and particulate organic phosphorus are the main components).

Results: Human activities   including agricultural and urban uses of fertilizer, agricultural use of manure, and combustion of fossil fuels   have caused widespread increases of nitrate in shallow ground water and total nitrogen and total phosphorus in streams across the Nation.

Nitrate did not pose a national health risk for residents whose drinking water came from streams or from major aquifers buried relatively deep beneath the land surface. Some concerns were evident in 4 of the 33 major aquifers sampled, where nitrate concentrations in more than 15% of each aquifer exceeded the EPA drinking water standard ( MCL= 10 mg/ L). The most prevalent nitrate contamination of ground water, however, was found in relatively shallow ground water in rural areas where the water commonly is used for domestic supply.

In more than one half of sampled streams, concentrations of total nitrogen and total phosphorus were above national background concentrations. Elevated phosphorus levels, in particular, can lead to excessive plant growth in freshwater environments; in more than one half of sampled streams and in three fourths of agricultural and urban streams, average annual concentrations of total phosphorus exceeded the EPA desired goal for prevention of nuisance plant growth ( 0.1 mg/ L). The highest total nitrogen and total phosphorus concentrations were found in small streams draining watersheds with large proportions of agricultural or urban land. Long term monitoring of streams indicates that programs to control point source discharges of phosphorus and ammonia have been effective, despite population increases in most metropolitan areas. Phosphorus concentrations have decreased as a result of reductions in the use of phosphate detergents and in the amount of phosphorus discharged from upgraded wastewater treatment plants. Improved waste water treatment, which converts ammonia to nitrate, generally has resulted in a decrease in ammonia concentrations and an increase in nitrate concentrations in streams. Thus, concentrations of total nitrogen downstream from metropolitan areas have changed little during the past 20 years, although toxicity to fish has decreased with decreasing ammonia levels.

Results from NAWQA studies have shown regional and seasonal differences in nutrient concentrations that can be explained largely by the amounts and timing of fertilizer and manure applications and by the variety of soils, geology, climate, and land and water management practices across the Nation. Recognition of thee differences is important for efficient protection of ground water needed for drinking and for curbing eutrophication of surface water.

Contact: http:// water. usgs. gov/ lookup/ get? nawqa Short term Followup: None Long term Followup: In more information on nutrients is needed, the report contains detailed information that may be useful.


TO:	Bob Lucas, EPA/SPPD

FROM:	Jeff Coburn

DATE:	April 30, 2007

SUBJECT:	Documentation of NOx Control Cost Estimates

I.	Purpose

This memorandum documents the methodology used to estimate costs to
control nitrogen oxides (NOx) for the fluid catalytic cracking unit
(FCCU), the fluid coking unit, and process heaters.

II.	NOx Controls

The following NOx control techniques were considered:

Flue Gas Recirculation.  Flue gas recirculation (FGR) uses flue gas as
an inert material to reduce flame temperatures.  In a typical flue gas
recirculation system, flue gas is collected from the heater or stack and
returned to the burner via a duct and blower.  The addition of flue gas
with the combustion air reduces the oxygen content of the inlet air
stream to the burner.  The lower oxygen level in the combustion zone
reduces flame temperatures, which in turn reduces NOx emissions.  The
normal NOx control efficiency range for FGR is 30 percent to 50 percent.
 When coupled with low-NOx burners (LNB) the control efficiency
increases to 50-72 percent.

Low-NOx Burners.  Low-NOx burner (LNB) technology utilizes advanced
burner design to reduce NOx formation through the restriction of oxygen,
flame temperature, and/or residence time.  The two general types of low
NOx burners are staged fuel and staged air burners.  Staged fuel LNBs
are particularly well-suited for boilers and process heaters burning
process and natural gas, which generate higher thermal NOx.  The
estimated NOx control efficiency for LNBs where applied to petroleum
refining fuel burning equipment is generally around 40 percent.

Ultra-low NOx Burners.  Ultra-low NOx burners (ULNBs) may incorporate a
variety of techniques including induced flue gas recirculation (IFGR),
steam injection, or a combination of techniques.  These burners combine
the benefits of flue gas recirculation and low-NOx burner control
technologies.  Rather than a system of fans and blowers (like FGR), the
burner is designed to recirculate hot, oxygen-depleted flue gas from the
flame or firebox back into the combustion zone.  This leads to a
reduction in the average oxygen concentration in the flame without
reducing the flame temperature below temperatures necessary for optimal
combustion efficiency.  The estimated NOx control efficiency for ULNBs
in high temperature applications is 50 percent.  Newer designs have
yielded efficiencies of between 75 and 85 percent.  When coupled with
selective catalytic reduction, efficiencies in the range of 85 to 97
percent can be obtained.

Controlling Excess Oxygen in Complete Combustion FCCU Catalyst
Regenerators.  Most of the previous control options are specific to
process heaters and carbon monoxide (CO) boilers.  However, controlling
the oxygen concentration in the FCCU regenerator exhaust at
approximately 0.5 percent has been seen to reduce NOx concentrations by
20 to 40 percent as compared to NOx concentrations when the regenerator
exhaust oxygen concentration is between 1 and 2 percent.  As such,
complete combustion FCCU regenerators with active excess oxygen controls
are expected to have similar performance as partial combustion FCCUs
followed by CO boilers that use low-NOx burners or flue gas
recirculation.

Selective Non-Catalytic Reduction.  In the selective non-catalytic
reduction (SNCR) process, urea or ammonia-based chemicals are injected
into the flue gas stream to convert nitric oxide (NO) to nitrogen gas
(N2) and water.  Without the participation of a catalyst, the reaction
requires a high temperature range to obtain activation energy.  The
optimum operating temperature for SNCR is 1,600 °F to 2,100 °F.  At
temperatures above 2,000 °F, NOx control efficiency decreases rapidly.
The normal NOx control efficiency range for SNCR is 50 percent to 70
percent.  SNCR systems are usually lower in capital cost than SCR
systems for the same application.  One advantage of this technology is
the fact that no liquid or solid waste is generated.  SNCR technology
has been applied to CO boilers, process heaters and boilers in the
petroleum refining sector where control efficiencies are consistent with
the range mentioned above.

LoTOxTM Technology.  The LoTOxTM process (i.e., low-temperature
oxidation) is a patented technology that uses ozone to oxidize NOx to
nitric pentoxide and other higher order nitrogen oxides, all of which
are water soluble and easily removed from exhaust gas in a wet scrubber.
 The system operates optimally at temperatures below 300°F.  Thus,
ozone is injected after scrubber inlet quench nozzles and before the
first level of scrubbing nozzles.  Outlet NOx emission levels have been
reduced to less than 20 parts per million by volume (ppmv), and often as
low as 10 ppmv, when inlet NOx concentrations ranged from 50 to 200 ppmv
(an 80 to 90 percent reduction efficiency).

Selective Catalytic Reduction.  Selective catalytic reduction (SCR) is a
post-combustion NOx control technology in which ammonia (NH3) is
injected into the post-combustion gas stream in the presence of a
catalyst.  A catalyst bed containing metals in the platinum family is
used to lower the activation energy required for NOx decomposition.  The
reaction of NH3 and NOx is favored by the presence of excess oxygen.
The NH3 oxidation to NOx increases with increasing temperature.  The
normal NOx control efficiency range for SCR is 70 to 90 percent.  There
are at least three SCRs currently in-use at refineries to control FCCU
NOx emissions.

Combination System.  Combination systems have used combustion controls
followed by SCR or SNCR technology in order to reduce costs of NOx
removal from a flue gas.  For example, LNB has been combined with SNCR
technology to minimize the capital and operating cost for NOx removal as
well as improve the control efficiency.

Catalyst Additives.  An additional NOx emission control option specific
for the FCCU is the use of catalyst additive, such as X-NOX and DENOX
(from Grace-Davison; Bruhin, et al. 2003).  Non-platinum combustion
promoter additives appear to achieve a 30 to 50 percent emission
reduction.  Additional catalyst additives have had limited success at
further reducing the NOx emissions from the FCCU, and the results of
these other additives have been quite varied.

Not all of these control technologies are applicable to all units.  For
example, use of catalyst additives is applicable only to FCCUs, while
the use of low-NOx burners are not applicable to complete combustion
FCCU catalyst regenerators.  For each source type, costs for four
control scenarios were developed in 2005 dollars; the control scenarios
ranged between 35 percent and 95% NOx emission reduction efficiencies.
As the baseline emissions of different FCCUs can span a fairly
significant range of outlet NOx concentrations, representative baseline
concentrations were assigned a weighting factor to simulate the
distribution of baseline NOx emissions.  For each representative
baseline NOx concentration, the control scenario needed to achieve a
given emission limit was assigned to the fraction of FCCUs represented
by that concentration.  The overall costs for a given scenario were then
calculated based on the weighting attributed to that uncontrolled NOx
concentration range.  Although this basic approach was used for each NOx
emission source type, the specific costing methodologies for each of the
three types of sources are presented in separate sections to clearly
identify the differences in the costs developed for the different
sources.

III.	Cost Estimates of FCCU NOx Control Systems

Control costs were developed for a model 50,000 barrel per day (bbl/d)
capacity FCCU with an estimated flow rate of 140,000 standard cubic feet
per minute (scfm).  Four control scenarios were evaluated:

Scenario 1:  a 35 percent reduction based on simply controlling the
amount of excess oxygen used in either the FCCU catalyst regenerator of
the CO boiler.

Scenario 2:  a 50 percent reduction based on:

Limiting excess oxygen and using non-platinum oxidation promoters in
complete combustion FCCU regenerators

Limiting excess oxygen and using low-NOx or ultra low-NOx burners in
FCCU equipped with CO boilers

Scenario 3:  a 90 percent reduction based on application of LoTOxTM or
SCR control system.

Scenario 4:  a 95 percent reduction based on application of high
efficiency SCR control system

Scenario 1.  For the most part, Scenario 1 is not expected to require
additional equipment and may have little to no actual impact on the
operational costs.  From information collected during site visits to
refineries and from consent decree evaluation reports submitted to EPA,
a 35 percent NOx reduction is achievable by controlling combustion
conditions, primarily the excess oxygen content.  Although all new FCCUs
are expected to have fully automated control, a capital cost of $20,000
and an annual operating cost of $4,000 per year were used to estimate
the costs of upgrading the computerized combustion control system.
These costs were annualized over 5 years, so the annualized cost for
Scenario 1 was estimated to be $8,900 per year.

Scenario 2.  Two control options were evaluated for this scenario.
Based on data reviewed from consent decree evaluation reports, complete
combustion FCCUs are expected to be able to reduce NOx emissions by 50
percent by controlling excess oxygen levels and replacing the platinum
combustion promoter with a non-platinum combustion promoter designed to
reduce NOx formation.  These costs include the costs of Scenario 1, plus
the additional cost of the non-platinum combustion promoter as compared
to the traditional platinum combustion promoter.  For the model FCCU,
the added combustion promoter cost was estimated to be $295,000 per
year.  Combined with enhanced combustion controls, the total annualized
cost of this option was $305,000 per year.

Capital costs for low-NOx burners were reported by MACTEC (2005) for gas
boilers as ranging from $430,000 to $5.5 million, while the capital
costs for low-NOx burners were reported to be $2.1 million.  From these
estimates, a capital cost of $2.1 million was selected for this option.
The operating costs reported by MACTEC (2005) were $90,000 per year
based on operating and maintenance labor; the ultra low-NOx burners also
have compressed air costs.  While the labor costs may be associated with
the boiler operation, it seems unlikely that these costs would be
additional to the costs of operating the boiler without the low-NOx
burners.  However, given that the low NOx burners operate at lower
temperatures, it does seem reasonable that there may be an impact on
combustion efficiency or steam production when using the low NOx
burners.  As such, this $90,000 per year operating cost was used.
Combined with enhanced combustion controls, the total annualized cost of
this option was just under $300,000 per year.

Since the MACTEC report dealt primarily with retrofit technologies, it
is likely that the capital costs reported are specific to retrofits and
that the incremental capital cost for new construction would be
substantially less as indicated by the costs reported by ERG (2001) for
new process heaters.  On the other hand, refineries that use complete
combustion FCCU regenerators do not have the option of installing
low-NOx burners.  Therefore, even though the annualized costs of
applying low NOx burners is likely overstated, the annualized costs
determined for these options were very similar, and an average of the
two option costs was used as the costs for Scenario 2.

Scenario 3.  As with Scenario 2, two control options were evaluated for
this scenario.  Costs for a 90 percent efficient LoTOxTM system were
based on preliminary costs provided by Belco Technologies Corporation
(Hutter and Confuorto, 2006).  The additional capital cost for the
LoTOxTM system when added to a new wet scrubber control system was
estimated to be $6 million, with an annual operating cost of
approximately $1.6 million.  Costs for an SCR system were estimated
based on the costs developed by MACTEC (2005) for gas boilers.  Reported
capital costs ranged from $2 million to $17 million; a mid-range value
of $10 million was selected.  The operating costs are dominated by
electricity and catalyst replacement costs.  The annual operating costs
were adjusted based on the selected capital cost (insurance and taxes)
and on a 5-year catalyst replacement frequency to develop an annual
operating cost of approximately $1.4 million.  The electricity costs
were not altered even though the model boiler exhaust flow rate for
which MACTEC developed costs was larger than the model FCCU exhaust flow
rate.  As such, the annual operating costs are still expected to be
conservative, or at least reasonable, even if catalyst life of less than
5 years is realized.  For these two options, the total annualized costs
were estimated to be $2.1 to $2.3 million.  As the annualized costs for
these options were so similar, these costs were averaged to develop the
control costs for Scenario 3.

Scenario 4.  Costs for Scenario 4 were assumed to be 30 percent higher
than the costs for Scenario 3.

Additional Costs Associated with Existing Unit Retrofits due to
Modification or Reconstruction.  No additional retrofit costs were
attributed to Scenario 1.  A capital cost retrofit factor of 1.35 was
applied to escalate the capital costs of Scenarios 2 through 4 to
account for additional costs associated with applying the controls to an
existing unit.  For example, adding a LoTOxTM system to a unit with an
existing wet scrubber requires some modification of the existing
scrubber system, which adds cost to the control system retrofit.  The
application of this retrofit factor may be dubious for Scenario 2, as
these costs are arguably already applicable to retrofits, but it was
applied to insure the retrofit costs were not understated.

Monitoring, Recordkeeping, and Reporting Costs.  In addition to the
control system cost, an initial performance evaluation and continuous
NOx monitoring is required.  The monitor must be maintained and
calibrated, and the data must be recorded and emission exceedances
periodically reported.  To account for these costs, an initial cost of
$130,000 and annual operating costs of $21,000 per year were added to
the control costs outlined above.

Summary of FCCU NOx Control Scenario Costs.  Table 1 summarizes the
fully burdened NOx control costs for new, modified, and reconstructed
FCCUs.  For completion, Scenario 0 was defined for FCCUs capable of
meeting a given regulatory alternative with no change in operation.  The
costs for this scenario are solely the costs associated with monitoring,
recordkeeping, and reporting.

Table 1.  Summary of Scenario Costs for FCCU NOx Controls

Scenario	New  Construction	Modified or Reconstructed

	Capital Cost

($1,000)	Annual Operating Cost ($1,000/yr)	Total Annualized Cost
($1,000/yr)	Capital Cost

($1,000)	Annual Operating Cost ($1,000/yr)	Total Annualized Cost
($1,000/yr)

0	 $ 130 	 $ 21 	 $ 40 	 $ 130 	 $ 21 	 $ 40

1	 $ 150 	 $ 25 	 $ 49 	 $ 203 	 $ 27 	 $ 76

2	 $ 1,210 	 $ 219 	 $ 333 	 $ 1,630	 $ 236 	 $ 390

3	 $ 8,130 	$ 1,500 	$ 2,270	$ 11,000 	 $ 1,610 	 $ 2,650

4	 $ 10,600	$ 1,650 	$ 2,650 	$ 14,300 	 $ 1,800 	 $ 3,140

Estimation of FCCU NOx Emissions and Emissions Reductions.

Currently, subpart J does not have any NOx emission limits for FCCUs.
Therefore, the baseline emissions for newly construcetd sources are
assumed to be uncontrolled NOx emissions.  Uncontrolled NOx emissions
are assumed to range between 50 ppmv and 300 ppmv, with a median value
of between 100 and 150 ppmv.  Numerous existing FCCUs are subject to
consent decrees that do impose NOx concentration limits on the FCCU
emissions.  Therefore, some of the existing FCCUs have installed NOx
controls, and the distribution of NOx concentrations at existing units
(those that will be modified or reconstructed) are skewed towards lower
concentrations than the newly constructed units.  Table 2 presents the
representative concentrations used in the baseline analysis and the
fraction of affected units that are represented by that concentration
for new construction and for modified and reconstructed units.

Table 2.  Summary of Representative Baseline NOx Emissions for New,
Modified, and Reconstructed FCCUs

Representative

Average NOx

Concentration

(ppmv)	Annual NOx Emissions  for Model FCCU at Average Concentration
(tons/yr)	Fraction of Newly Constructed Units Represented by Average NOx
Concentration	Fraction of Modified or Reconstructed Units Represented by
Average NOx Concentration

20	88	0	0.05

30	132	0	0.1

40	176	0	0.1

50	220	0.05	0.1

60	264	0.05	0.1

80	352	0.15	0.1

100	439	0.2	0.15

150	659	0.25	0.15

200	879	0.15	0.05

250	1,099	0.1	0.05

300	1,318	0.05	0.05

For the nationwide impact estimates, it was assumed that 15 new
refineries’ worth of processes would be new, modified, or
reconstructed over the next 5 years.  Based on the number of FCCUs
compared to the number of refineries in the U.S., there would be 12
affected FCCUs.  It was assumed that 40 percent of the affected units
would be new construction and 60 percent of the affected units would
become new due to modification or reconstruction.  Based on the assumed
number and distribution of these units, the nationwide impacts of
imposing different NOx concentration emission limits were estimated.
The results of these calculations are provided in Table 3.

Table 3.  Summary of Nationwide Impacts of Various NOx Regulatory
Alternatives for FCCUs

Regulatory Alternative NOx Emission Limit (ppmv)	Total Capital
Investment  (million $)	Annual Operating Costs  (million $/yr)	Total
Annualized Costs  (million $/yr)	NOx Emission Reduction from Baseline

(tons/yr)

Nationwide Costs for Newly Constructed Units

80	                   13.5 	                     2.5
  3.8 	                 1,870

60	                   22.8 	                     4.2
  6.4 	                 2,340

40	                   32.0 	                     5.7
  8.7 	                 2,630

20	                   42.5 	                     7.4
11.4 	                 2,830

Nationwide Costs for Modified or Reconstructed Units

80	                   14.4 	                     2.1
  3.5 	                 1,590

60	                   26.0 	                     3.8
  6.3 	                 2,030

40	                   48.4 	                     6.9
11.5 	                 2,520

20	                   78.7 	                   11.2
18.7 	                 2,940

Nationwide Costs for all New, Modified, and Reconstructed Units

80	                   27.8 	                     4.6
  7.3 	                 3,460

60	                   48.8 	                     8.0
12.7 	                 4,380

40	                   80.4 	                   12.6
20.2 	                 5,150

20	                 121.2 	                   18.6
30.1 	                 5,760

IV.	Cost Estimates of Fluid Coking Unit NOx Control Systems

NOx control costs were developed for a model 40,000 bbl/d capacity fluid
coking unit.  The unit is assumed to have a CO boiler and an estimated
exhaust flow rate of 200,000 scfm.  The same four control scenarios as
developed for the FCCU were used for the fluid coking unit except that
Scenario 2 was based solely on low-NOx burners in the CO boiler.  As
many of the FCCU NOx control costs were developed from gas boilers
slightly larger than the model fluid coking unit CO boiler, no other
changes in the FCCU cost estimates were made (MACTEC, 2005).

Most new coking units are expected to be delayed coking units.  Only one
affected fluid coking unit was projected in the first 5 years; this
fluid coking unit is assumed to become subject to the rule due to
modification or reconstruction.  As such, only the costs for retrofit
NOx controls apply.

Currently, subpart J does not have any NOx emission limits for fluid
coking units.  Therefore, the baseline emissions for fluid coking units
are assumed to be uncontrolled NOx emissions.  Similar to the FCCU
analysis, a range of representative baseline concentration were assumed.
 Table 4 presents the assumed distribution of baseline NOx emissions for
fluid coking units.

Table 4.  Summary of Representative Baseline NOx Emissions for Fluid
Coking Units

Representative

Average NOx

Concentration (ppmv)	Annual NOx Emissions  for Model Fluid Coking Unit
at Average Concentration (tons/yr)	Fraction of Fluid Coking Units
Represented by Average NOx Concentration

80	502	0.1

100	628	0.2

150	942	0.2

200	1,256	0.2

250	1,570	0.2

300	1,884	0.1

As with the FCCU analysis, different regulatory alternatives were
evaluated.  For each regulatory alternative, the control scenario needed
at each representative baseline concentration was determined.  Even
though only one fluid coking unit was expected to be impacted, a
distributional analysis of representative baseline NOx concentrations
was still used to develop the most representative average impacts for
fluid coking units.  Table 5 summarizes the nationwide impacts for the
NOx regulatory alternatives considered for fluid coking units.

Table 5.  Summary of Nationwide Impacts of Various NOx Regulatory
Alternatives for Fluid Coking Units

Regulatory Alternative NOx Emission Limit (ppmv)	Total Capital
Investment  (million $)	Annual Operating Costs  (million $/yr)	Total
Annualized Costs  (million $/yr)	NOx Emission Reduction from Baseline

(tons/yr)

80	            4.50 	            0.54 	            0.97
760

60	            6.66 	            0.86 	            1.49
884

40	            9.54 	            1.22 	            2.12
978

20	            12.6 	            1.70 	            2.90 	          1,043

V.	Cost Estimates of Process Heater NOx Control Systems

The NOx control scenarios considered for process heaters were similar to
those used for FCCUs with the following differences:

Scenario 2 was modified to be an 80 percent NOx emission reduction
using ultra low-NOx burners.  The effectiveness of ultra low-NOx burners
for process heaters is well-demonstrated, much more so than for FCCUs
and fluid coking unit CO boilers where the majority of the heating value
is in the exhaust gas rather than in the fuel fired to the boiler.
Therefore, the Scenario 2 was assigned 80 percent control efficiency,
and the control costs were revised for ultra low-NOx burners based on
the costs reported by MACTEC (2005) for gas-fired boilers.  As discussed
in the FCCU section, these costs do not appear to be incremental costs,
especially for newly constructed units, but these costs were used as a
worst-case scenario for the ultra low-NOx burner costs.

Costs for Scenario 3 and 4 were revised to be based solely on the use of
an SCR.

For process heaters, there are a greater number of affected sources
covering a much wider range of sizes than for the FCCU.  Therefore, the
cost estimates developed previously for the were not applicable without
some algorithm for adjusting the costs for size.  As a first step, the
size and number of process heaters at a model plant refinery with a
50,000 barrel per calendar day (bbl/cd) FCCU was assessed.  Process
heater capacities for the processes were estimated based on process
heater fuel gas use rates developed for the refinery emission model
(RTI, 2002).  Table 6 summarizes the process heater sizes in millions of
British thermal units per hour (MMBtu/hr) and the number of process
heaters of each size, assuming 15 refineries’ worth of processes
become subject to the rule over the next 5 years.

The costs developed for each scenario were broken into “fixed costs”
and costs that vary with the size of the process heater.  For example,
the cost of operating the NOx monitor was considered “fixed” because
it was independent of the size of the process heater.  The capital costs
that vary with process heater size were assumed to vary according to
Equation 1; the operating costs that vary with process heater size were
assumed to vary in direct proportion to the process heater size.

 	Equation 1

 Where,

	VCIPH,i = 	variable capital investment for the ith process heater, $

	VCIPH,i = 	variable capital investment for the model process heater for
which costs were developed, $

	QPH,i =	volumetric flow rate of the ith process heater, scfm

	QMP =	volumetric flow rate of the model process heater for which costs
were developed, scfm

Subpart J does not have any requirements for NOx control from process
heaters.  The assumed baseline distribution of NOx emission
concentrations for process heaters is presented in Table 7.  The actual
annual mass emissions are dependent on the size of the process heater
being assessed.

Various regulatory alternatives were evaluated by assigning the
appropriate control scenario to each representative baseline
concentration in the same manner as with the FCCUs.  As the
cost-effectiveness of applying controls to smaller process heaters was
not as good as for larger process heaters, a variety of size thresholds
were also considered.  The following four regulatory alternatives were
considered:

Option 1.  80 ppmv NOx concentration limit applied to all process
heaters with a capacity greater than 20 MMBtu/hr.

Option 2.  40 ppmv NOx concentration limit applied to all process
heaters with a capacity greater than 20 MMBtu/hr.

Option 3.  30 ppmv NOx concentration limit applied to all process
heaters with a capacity greater than 40 MMBtu/hr.

Option 4.  40 ppmv NOx concentration limit applied to process heaters
with a capacity greater than 20 MMBtu/hr but less than or equal to 100
MMBtu/hr and 20 ppmv NOx concentration limit applied to process heaters
with a capacity greater than 100 MMBtu/hr.

Table 6.  Summary of Model Refinery Values Used to Assess the Size and
Number of Affected Process Heaters

Process Unit	Model Plant Size

(bbl/cd)	Fuel Use Factor

(MMBtu/bbl)	Process Heater Size (MMBtu/hr)	Projected Flow Rate (scfm)
Number of New, Modified, or Reconstructed Processes

Crude Distillation	143,000	0.087	520 	104,000 	15

Vacuum Distillation	71,000 	0.084	250 	49,900 	13.5

Thermal Cracking (coking)	28,600 	0.094	110 	22,400	6

Catalytic Cracking	50,000 	0.051	105 	21,100	12

Catalytic Reforming	28,600 	0.467	560 	111,000 	15

Hydrocracking	14,300 	0.105	60 	12,500	4.5

Hydrotreating/Hydrorefining	100,000 	0.018	70 	14,900 	30

Alkylation (general)	14,300	0.217	130 	25,800 	9

Polymerization	 2,900

	- 	3

Aromatics 	14,300	0.100	60 	11,900 	4.5

Isomerization	 7,100	0.150	45 	 9,000 	7.5

Other Lube Oil Processes	14,300	0.368	220 	43,800	0

Full-Range Distillation	14,286 	0.087	50 	10,400 	45

Hydrogen Planta	30a 	15.0a	18 	 3,600 	9

Sulfur Plantb	210b 	3.077b	27 	 5,500 	19.5

Asphalt Plant	14,300 	0.190	110 	22,600 	6

a Production in millions of cubic feet per day (MMcu.ft/day); fuel use
factor in MMBtu per MMcu.ft.

b Production in long tons per day (LTD); fuel use factor in MMBtu per
LTD.

Table 7.  Summary of Representative Baseline NOx Concentrations for
Affected Process Heaters

Representative

Average NOx

Concentration (ppmv)	Fraction of Affected Process Heaters Represented by
Average NOx Concentration

80	0.1

100	0.25

150	0.5

200	0.15

The nationwide impacts for the regulatory alternatives considered for
process heaters NOx control are presented in Table 8.

Table 8.  Summary of Nationwide Impacts of Various NOx Regulatory
Alternatives for Process Heaters

Regulatory Alternative 	Total Capital Investment  (million $)	Annual
Operating Costs  (million $/yr)	Total Annualized Costs  (million $/yr)
NOx Emission Reduction from Baseline

(tons/yr)

Nationwide Costs for Newly Constructed Units

Option 1	 48 	  4.4 	  9.5 	6,820

Option 2	 68 	  5.8 	  12.7 	8,110

Option 3	 95 	  8.0 	  17.4 	8,180

Option 4	 158 	  14.2 	  29.6 	8,730

Nationwide Costs for Modified or Reconstructed Units

Option 1	 91 	  8.8 	  18.3 	10,230

Option 2	 132 	  12.1 	  25.3 	12,170

Option 3	 187 	  16.7 	  35.0 	12,270

Option 4	 314 	  27.9 	  58.3 	13,090

Nationwide Costs for all New, Modified, and Reconstructed Units

Option 1	 139 	  13.2 	  27.7 	17,050

Option 2	 199 	  17.9 	  38.0 	20,280

Option 3	 282 	  24.7 	  52.4 	20,450

Option 4	 471 	  42.1 	  87.9 	21,820

VI.	References

Bruhin, T., G. McElhiney, G. Bourdillon, and P.A. Diddams.  2003.
“Catalytic Solutions for FCC Unit Emissions.”  In the proceedings of
the World Petroleum Conference 2003.  pp. 144-147.  Available at:

  HYPERLINK
"http://www.world-petroleum.org/isc2004/File%20022/144_145_146_147.pdf"
http://www.world-petroleum.org/isc2004/File%20022/144_145_146_147.pdf

Eastern Research Group (ERG).  2001.  Petroleum Refinery Tier 2 BACT
Analysis Report – Final Report.  Prepared for U.S. Environmental
Protection Agency, Manufacturing Branch, Washington, DC.  January 16,
2001.

MACTEC.  2005. Midwest Regional Planning Organization (RPO) Petroleum
Refinery Best Available Retrofit Technology (BART) Engineering Analysis.
 Report prepared by MACTEC Federal Programs/MACTEC Engineering and
Consulting, Inc. for The Lake Michigan Air Directors Consortium (LADCO).
 March 30, 2005.

Hutter, E. and Confuorto, N.  2006.  Email correspondence between Jeff
Coburn, RTI International; Edward Hutter, Applications Manager, Belco
Technologies Corporation; and Nick Confuorto, Vice President,
Technology, Sales & Marketing, Belco Technologies Corporation re: Design
and costs of wet scrubbers and LoTOx systems.  Date of final
communication:  September 9, 2006.

RTI.  2002.  Petroleum Refinery Source Characterization and Emission
Model for Residual Risk Assessment.  Prepared for U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards,
Research Triangle Park, NC.  EPA Contract No. 68-D6-0014.  July 2,
2002.

Addressee:  Bob Lucas – Documentation of NOx Control Cost Estimates

April 30, 2007

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