Association Weighs In on EPA's Secondary MACT Rule

The Aluminum Association has submitted comments to the Environmental Protection Agency on its proposed National Emissions Standards for Hazardous Air Pollutants (NESHAP) Secondary Aluminum Production Rule.

In a 60-page letter, the Association took issue with a number of areas of the rule, including:

• The requirement that regulatory changes take effect 90 days after promulgation;
• The American Conference of Industrial Hygienists' hooding requirement for testing uncontrolled furnaces;
• Requirements for furnace classification changes;
• Startup and shutdown (SS) emissions limits; and
• EPA's failures to justify, explain, or seek public comment for a change to the performance test language in the rule's preamble.

For a copy of the Association's comments, please contact Chuck Johnson, Vice President of Environment, Health & Safety, at cjohnson@aluminum.org.