Don't Waste Arizona, Inc

Don't Waste Arizona, Inc.

A non-profit environmental organization created for the protection, conservation, and preservation of the human and natural environment in and around Phoenix, and the state of Arizona.

Chemical Spill

Nukes won't halt Climate Change

DWAZ Comments Re Alliance Metals Aluminum Manufacturing

Hazardous aluminum dross characterization and recycling strategies: A critical review
Hydrolysis of aluminum dross material to achieve zero hazardous waste
Hazardous aluminum dross characterization and recycling strategies: A critical review

Aluminum related reactions can also release large amounts of potentially toxic and/or flammable gases and noxious odors. The additional oxygen can lead to adverse reactions including combustion. These are a few reasons why aluminum dross is considered a hazardous material.

Aluminum dross as a hazardous solid waste in aluminum production industries has caused serious environmental and public health challenges.

Question: What will be done to assure that the aluminum dross has been treated so it won't cause an explosion? If it hasn't been treated, it is a hazardous waste due to its explosive and reactive properties, and before this facility can legally accept and utilize the dross, it must first get a hazardous waste facility permit. Either way, before accepting aluminum dross at the facility, the dross must be tested for ignitability and reactivity, and if it tests as such, it would be hazardous waste and the facility would not be allowed to accept it or utilize it. There are no hazardous waste facilities licensed in Arizona to dispose of hazardous wastes. Also, the owner/operator of a facility that has to get a hazardous waste permit must be investigated to assure that there is no criminal background.

BLDS must be required for the baghouse.
Electronic Code of Federal Regulations

§261.3 Definition of hazardous waste.

(a) A solid waste, as defined in §261.2, is a hazardous waste if:

(1) It is not excluded from regulation as a hazardous waste under §261.4(b); and

(2) It meets any of the following criteria:

(i) It exhibits any of the characteristics of hazardous waste identified in subpart C of this part. However, any mixture of a waste from the extraction, beneficiation, and processing of ores and minerals excluded under §261.4(b)(7) and any other solid waste exhibiting a characteristic of hazardous waste under subpart C is a hazardous waste only if it exhibits a characteristic that would not have been exhibited by the excluded waste alone if such mixture had not occurred, or if it continues to exhibit any of the characteristics exhibited by the non-excluded wastes prior to mixture. Further, for the purposes of applying the Toxicity Characteristic to such mixtures, the mixture is also a hazardous waste if it exceeds the maximum concentration for any contaminant listed in table 1 to §261.24 that would not have been exceeded by the excluded waste alone if the mixture had not occurred or if it continues to exceed the maximum concentration for any contaminant exceeded by the nonexempt waste prior to mixture.

(ii) It is listed in subpart D of this part and has not been excluded from the lists in subpart D of this part under §§260.20 and 260.22 of this chapter.

Subpart C--Characteristics of Hazardous Waste
§261.20 General.
§261.21 Characteristic of ignitability.
§261.22 Characteristic of corrosivity.
§261.23 Characteristic of reactivity.
§261.24 Toxicity characteristic.

Odor rule applies
Pressure drop monitoring and leak detection are necessary and should require constant monitoring and consistent calibration schedules. MACT standard.

Opacity limits? 5%?
Bag detection system alarm needs to be 'on" at all times (page 91 alliance metals) MACT
OM&M plan been developed and submitted?
Page 92 -- (ii) "dross -only furnace"
Page 93 -- bottom admits major source
Page 95 -- leak detect 7 continuous opacity monitoring crossed out. At bottom records of annual afterburner inspections crossed out.
Page 96 -- Processing "only clean charge" crossed out, is appropriate as the is no clean fuel stock.
Furnace runs 24/7; HCL emissions 1.75 tons/yr - fugitive? page 105

Prevailing wind? SW?
Aluminum dross hazardous waste?
Where is MACT rule for D/F (42 U.S.C. 7401)? Not listed as requirement

Don't Waste Arizona, Inc
1991 - 2020

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