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MONITORING PROGRAM <br /> <br />The existing CUP monitoring program lists the following test <br />parameters: <br /> <br /> A. Criteria Pollutants <br /> ( NOx, SOx, CO, particulates ) <br /> <br />B. Heavy Metals <br /> ( As, Be, Cd, Cr, Hg, Pb and Zn ) <br /> <br />C. Acid Gases <br /> <br />D. Dioxins/Furans <br /> <br />Criteria Pollutants <br /> <br /> We recommend that only the particulates and opacity be tested for <br />once every five years. The only fuel burned at the Permit Holders' <br />facility is propane which is not considered a sulfur bearing fuel and <br />therefore will not generate SOx~ The burners operate with an excess of <br />oxygen and therefore the carbon monoxide will be converted to carbon <br />dioxide. <br /> <br /> An MPCA permit is for a 5 year period and would usually require <br />only one test for this period if it is classified as a minor source <br />(greater than 25 TPY but less than 100 TPY). Therefore, we recommend <br />the above test period of'once every five years for particulates and <br />opacity. <br /> <br />Heavy Metals <br /> <br /> A secondary aluminum' producer is not a source for heavy metals. <br />The particulate metal emission will be aluminum. Therefore, a heavy <br />metal stack test should not be required. <br /> <br />Acid Gases <br /> <br /> The acid gases consist of HC1, HF and H~r. These gases will not <br />be generated in a secondary aluminum melt furnace as operated by the <br />Permit Holder. Therefore, an acid gas test should not be required. <br /> <br />Dioxins/Furans <br /> <br /> Dioxins and Furans will not be formed in a secondary aluminum <br />melt furnace. These compounds require a chlorine and organic precurser <br />to form in a temperature range of from 850 to 430 F. These criteria <br />are not found in the operations of a secondary melt furnace. <br />consequently, a dioxin/furan test should not be required. <br /> <br /> <br />