EPA-453/R-92-001
   CONTROL OF VOC EMISSIONS FROM
NONFERROUS METAL ROLLING PROCESSES
     CONTROL TECHNOLOGY CENTER

             SPONSORED BY:

         Emission Standards Division
  Office of Air Quality Planning and Standards
     U.S. Environmental Protection Agency
 Research Triangle Park, North Carolina 27711

Air and Energy Engineering Research Laboratory
      Office of Research and Development
     U.S. Environmental Protection Agency
  Research Triangle Park, North Carolina 27711
                 June 1992

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                                             EPA-453/R-92-001
                                                     June 1992
    CONTROL OF VOC EMISSIONS FROM
NONFERROUS METAL ROLLING PROCESSES

                 Prepared by:

                W. Scott Snow
            Philindo J. Marsosudiro
       Alliance Technologies Corporation
          100 Europa Drive, Suite 150
       Chapel Hill, North  Carolina 27514
         EPA Contract No. 68-DO-0121
           Work Assignment No. 1-30
           (Alliance No. 1-638-030-1)
                Project Officer

                 Joseph Myers
          Emission Standards Division
      U.S. Environmental Protection Agency
  Research Triangle Park, North Carolina  27711
                 Prepared for:

           Control Technology Center
      U.S. Environmental Protection Agency
  Research Triangle Park, North Carolina  27711
                                  U.S. Environmental Protection Agency
                                  Region 5, Library 'PM?J)
                                  77 West Jackso- Oci! :.:-d, 12th Floor
                                  Chicago, IL  60504-5590

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                                   DISCLAIMER

      This final report was prepared for the Control Technology Center, U.S. Environmental
Protection Agency, by Alliance Technologies Corporation, 100 Europa Drive, Chapel Hill, NC
27514, in partial fulfillment  of Contract No. 68-DO-0121, Work Assignment No 1-30.  The
opinions, findings and conclusions expressed are those of the authors and not necessarily those
of the Environmental Protection Agency.
                                         m

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                                     PREFACE

       This report was prepared for and funded by the Control Technology Center (CTC) of the
U.S. Environmental Protection Agency. The CTC was established by EPA's Office of Research
and Development (ORD) and Office of Air Quality Planning and Standards (OAQPS) to provide
technical assistance to State and local air pollution control agencies. Several levels of assistance
are available  through the CTC:  a CTC HOTLINE provides telephone assistance on matters
relating to air pollution control technology; in-depth engineering assistance is provided when
needed by  EPA and its  contractors; and the CTC can provide technical guidance through
publication of technical guidance documents, development of personal computer software, and
presentation of workshops  on control technology matters.  The fourth  assistance program
sponsored by the CTC is the CTC Bulletin Board System  (BBS), a part of the EPA OAQPS
Technology Transfer Network. Users of the BBS can retrieve CTC information through one of
four major  area  menu   selections.   The four areas  included are  Utilities, Help  Center,
Documents/Software, and CTC Projects.
       Technical guidance projects,  such  as this one, focus on  topics  of national or regional
interest that are identified through contact  with State and local agencies. In this case, the CTC
received a number of calls on controlling volatile organic compound  (VOC) emissions from
nonferrous metal rolling processes. Controlling VOC emissions at various source types that have
not been addressed by Control Techniques Guidelines (CTG's) is of interest to many States and
local air pollution control agencies due to on-going ozone  nonattainment problems (VOC is a
precursor of ozone) and requirements in Tide I of the Clean Air Act Amendments of 1990. This
report  presents  the results of a study to identify and collect information on nonferrous metal
rolling processes and the  VOC emissions generated during these operations.
                                          IV

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                              TABLE OF CONTENTS

Section                                                                       Page

Disclaimer  	iii
Preface	iv
List of Figures	  vii
List of Tables	viii

1      INTRODUCTION	1-1

2      PROCESS DESCRIPTION AND VOC EMISSIONS SOURCES  	2-1
       2.1    Introduction  	2-1
       2.2    Nonferrous Rolling Industry Structure .	2-1
             2.2.1  Market Structure	2-2
             2.2.2  Raw Materials, Products, and Product End-uses  	2-2
             2.2.3  Profile of Aluminum and Copper Rolling Facilities	2-3
             2.2.4  Rolling Mill Types 	2-3
       2.3    Rolling Process Description  	2-4
             2.3.1  Cold Rolling Process Equipment	2-4
             2.3.2  Hot Rolling Process Equipment 	2-8
             2.3.3  Deformation Theory and Heat Generation 	2-8
       2.4    Rolling Mill VOC Emissions  	2-9
             2.4.1  Types of Lubricants  	2-9
             2.4.2  Lubricant Application Techniques	2-11
             2.4.3  Physical Properties of Various Rolling Lubricants	2-12
             2.4.4  Sources of Lubricant Loss and Make-up  	2-14
             2.4.5  Factors Affecting the Level of Emissions	2-17
             2.4.6  Degradation of Rolling Lubricant	2-19
             2.4.7  Current Emissions Controls in the  Rolling Industry	2-19
       2.5    References  	2-21

3      VOC EMISSION CONTROL TECHNIQUES	3-1
       3.1    Introduction	3-1
       3.2    Capture Systems for Nonferrous Rolling Mills  	3-1
       3.3    Control Devices for Nonferrous Rolling Mills	3-2
             3.3.1  Carbon Adsorption 	3-4
             3.3.2  Absorption (Scrubbing)  	3-6
             3.3.3  Incineration 	3-7
       3.4    Lubricant Substitution (Source Reduction)	3-9
             3.4.1  Emission Reduction Mechanisms of Lubricant Substitution  	3-10
             3.4.2  Applicability of Lubricant Substitution to Rolling Process	3-11
             3.4.3  Applicability of Lubricant Substitution as a Control Method  .... 3-13

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                       TABLE OF CONTENTS (Continued)

Section                                                                    Page

            3.4.4  Summary   of  Lubricant   Substitution   Advantages   and
                  Disadvantages	  3-14
      3.5    Process and Equipment Modifications	  3-14
            3.5.1  Process Modifications for Potential VOC Emission Reduction  ...  3-16
            3.5.2  Equipment Modifications for Potential VOC Emission Reduction .  3-17
      3.6    References	3-19

4     CONTROL COST ANALYSIS	4-1
      4.1    Introduction  	4-1
      4.2    VOC Add-On Control Devices	4-1
            4.2.1  Carbon Adsorption	  4-3
            4.2.2  Absorption (Scrubbing) 	4-3
            4.2.3  Thermal Incineration	4-3
            4.2.4  Catalytic Incineration	4-10
      4.3    Lubricant Substitution	4-10
      4.5    References	  4-16

APPENDIX A TRIP REPORTS  	A-l
                                       VI

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                               LIST OF FIGURES




Number                                                                      Page




2-1   Schematic Diagram of Metal Deformation Process on a Two-High Mill	2-5




2-2   Schematic Diagram of a Four-High, Single Stand Nonferrous Rolling Mill	2-6




2-3   Sources of Lubricant Loss and Input in a Nonferrous Rolling Mill 	2-16




3-1   Typical Rolling Mill Stand Capture System  	3-3
                                       VII

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                                LIST OF TABLES

Number                                                                      Page

2-1   Typical Lubricants for Nonferrous Metal Rolling	2-10

2-2   Important Lubricant Properties	2-13

3-1   Summary of Advantages and Disadvantages of Lubricant Substitution
      Experience in the Aluminum Foil Rolling Industry  	3-15

4-1   General Parameters and Cost Factors For Estimating Costs for Add-On
      Control Devices	4-2

4-2   Operating and Labor Requirements Used to Estimate Annual Costs for
      Fluidized-Bed Carbon Adsorption	4-4

4-3   Capital and Annual Costs for Fluidized-Bed Carbon Adsorption	4-5

4-4   Operating and Labor Requirements Used to Estimate Annual Costs for Oil
      Adsorption	4-6

4-5   Capital and Annual Costs for Oil Absorption  	 . . .	4-7

4-6   Operating and Labor Requirements Used to Estimate Annual Costs for
      Thermal and Catalytic Incinerators 	4-8

4-7   Capital and Annual Costs for Thermal Incineration	4-9

4-8   Capital and Annual Costs for Catalytic Incineration	4-11

4-9   General Assumptions and Cost Factors Used to  Derive Lubricant
      Substitution Cost Impact	4-12

4-10  Example Calculation  of Annual Cost for Lubricant Substitution 	4-14

4-11  Annual Costs for Lubricant Substitution at Various Lubricant Use
      Reductions	4-15
                                        Vlll

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                                     CHAPTER 1
                                   INTRODUCTION

       This report presents the results of a study to collect and report information on nonferrous
metal rolling processes, volatile organic compound (VOC) emissions generated during these
operations, emission control techniques and their effectiveness, and costs associated with process
changes and emission control options. State agencies and other government-sponsored programs,
as well as equipment manufacturers, professional and trade organizations, and nonferrous metal
rolling facilities were contacted to assess production methods,  current emission controls used in
the industry, and available control technologies for nonferrous rolling processes.
       Many nonferrous metal rolling operations exist in the United States  today, however,
aluminum  and copper are the  two largest industries.  There are  approximately 55  facilities
engaged in aluminum rolling operations and 23 facilities producing copper rolled products. Most
aluminum facilities are located in the South and Midwest while  copper facilities are found mainly
in the North and Midwest, It has been estimated that half of  these plants are located in ozone
nonattainment areas.
       This report is divided into four chapters and one appendix.  Chapter 2 characterizes the
nonferrous metal rolling industry's  market structure, raw materials, products, and mill types. It
provides a description of the rolling processes, process equipment, and lubricants used during the
rolling processes. Chapter 2 also provides a discussion of process VOC emission sources within
a nonferrous rolling mill and the current emissions controls being utilized in the industry.
       Chapter 3 discusses methods of reducing and controlling VOC emissions resulting from
nonferrous rolling mill operations.  Areas addressed include add-on control devices, process  and
equipment modifications, improved operating practices, and source reduction methods.  Chapter
4  estimates the  capital  and annual costs associated  with add-on control  devices  and source
reduction  methods.
       This report also includes an appendix that contains copies of the trip reports  for the two
nonferrous metal rolling facilities visited during the course of this work assignment.
                                           1-1

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                                    CHAPTER 2
            PROCESS DESCRIPTION AND VOC EMISSIONS SOURCES

2.1   INTRODUCTION

      This chapter gives an overview of the nonferrous metal rolling industry including market
structure, process descriptions, and volatile organic compound (VOC) emissions sources.  The
EPA defines a VOC as any organic compound that participates in atmospheric photochemical
reactions.  Compounds designated as having negligible photochemical reactivity are exempt from
regulation. VOC emissions from nonferrous rolling mills result from the use of lubricants
containing hydrocarbon compounds in the rolling process. While a variety of nonferrous metals
are included in the rolling industry,  the primary focus of this document is  on the two major
nonferrous metal rolling operations:  aluminum and copper.
       The nonferrous rolling industry can be broken down by type of nonferrous metal rolled
and type of rolling, hot or cold.  General process descriptions are given based on the type of
rolling mill employed (two-high, four-high, continuous, etc.).  Sources of VOC emissions are
identified, and available information on emissions levels from those sources are given.

2.2    NONFERROUS ROLLING INDUSTRY STRUCTURE

       In general, a "nonferrous metal roiling mill" is defined as a process machine for the gauge
reduction  or forming of nonferrous metals by exerting pressure between rotating rolls.1  The
nonferrous metal rolling industry consists of rolling facilities producing nonferrous plate, sheet,
strip,  and/or foil.  In related rolling industries nonferrous rod  and bar are  produced.  These
facilities are not addressed in this report because rod and bar are produced by hot rolling ingot2
using a water-based coolant that produces little or no VOC emissions. The  nonferrous metals
category includes aluminum,  copper, lead, zinc, refractory metals, magnesium,  nickel, tin,
titanium, and zirconium.  This section describes the nonferrous metal rolling industry in terms
of the market, raw materials, processes, rolling mill types, products, and product uses.
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2.2.1   Market Structure

       The U.S. Government Standard Industrial Classification (SIC) coding system has several
categories which include nonferrous metal rolling.  SIC codes 3351, 3353, and 3356 contain
nonferrous metal rolling among other types of metal manufacturing.  Copper  sheet, plate, and
strip production are included in SIC code 3351, along with copper drawing and extruding,3 which
are not within the scope of this report. Aluminum sheet, plate, and foil production fall under SIC
code 3353; however, SIC code 3353 also includes establishments producing aluminum welded
tube which are not relevant to this report.3 Other nonferrous metal rolling is included in SIC
code 3356; however, this is a broad category which includes all nonferrous metal rolling (except
aluminum and copper), drawing, and extruding operations.3   As stated before, drawing and
extruding processes are not relevant to this report. Industry sources indicate that the other main
types of nonferrous metal rolling, besides aluminum and copper, are lead and zinc.4  Another
minor category (SIC code 3497) includes nonferrous metal foil and leaf fabrication.7
       Bureau of the Census data indicate that a total of 55 establishments in the U.S. were
engaged in aluminum rolling operations  with a combined production rate of approximately 5.12
million tons (10.24 billion pounds) in 1987.  There were also 23 copper rolling facilities in the
U.S. producing approximately 0.59 million tons (1.18 billion pounds) of copper rolled products
in 1987.  The  only other nonferrous metal rolling data available were for lead with eight (8)
locations in  the  U.S.  producing approximately  31.6 million pounds of rolled  lead product.
Geographically, the aluminum rolling industry is concentrated in the South and Midwest, while
copper rolling facilities are found mainly in the North and Midwest. Other nonferrous rolling
operations are spread fairly evenly across the United States.5
consumer.

2.2.2   Raw Materials, Products, and Product End-uses

        Two main types of raw materials are employed in the nonferrous rolling process:  metal
or metal alloy and lubricant. Initially, metal in the form of ingots manufactured  by primary or
secondary producers undergoes hot rolling, using a water-based lubricant,6 which reduces these
ingots to plate and heavy-gauge sheet sizes.  These plates and sheets then undergo cold rolling,

                                           2-2

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which typically uses a petroleum-based lubricant for the production of light-gauge sheet and strip
or foil.
       Finished rolled products have a wide variety of uses. They may be further fabricated to
produce package foil, food wrap, lining material or containers.  In addition, sheet metal may
undergo  forming  and bending  operations  to produce decorative pieces,  tubes,  cones, etc.
Nonferrous sheet is also used in building and construction and in automobiles.2"7

2.2.3  Profile of Aluminum and Copper Rolling Facilities

       This report focuses on  the  two most prominent  types of nonferrous metal  rolling
operations in the U.S. today:  aluminum and copper.  Although industries are relatively similar,
there are some dissimilarities in plant functions and types of products rolled.
       The aluminum rolling industry is divided among plants that perform both hot and cold
rolling, those  that engage in foil (cold) rolling,8 and those that continuously cast.9  Hot/cold
rolling facilities directly reduce aluminum ingot to plate and sheet, while foil rolling mills reduce
sheet to foil thicknesses.  Aluminum plate is defined to be greater than 7.25 inches in thickness,
sheet is defined as between 0.006 and 0.245 inches in thickness and aluminum foil is defined as
less than 0.006 inches thick.10
       The copper rolling industry is similar in structure to aluminum given that certain facilities
perform both hot and cold rolling, while other facilities perform cold rolling only.  Hot rolling
reduces copper ingots to a sheet size of about 0.25 inches. Cold rolling reduces the gauge further
to strip thicknesses of usually not less than 0.004 inches.

2.2.4  Rolling Mill  Types

       Rolling mills include several different types: tandem mills, cluster mills, Sendzmir mills,
and continuous casters.  A tandem mill consists  of a number of stands spaced closely together
in one continuous line. In a cluster mill, each end of the two working rolls  is supported by two
or more backing rolls (six-high mill); this type of mill  is mainly used for rolling thin materials.
A Sendzmir mill  is  a relatively new design and features  several different roll arrangements
designed to roll very thin foils or strips.  Also fairly new is the continuous caster which has made

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it possible to directly convert molten metal into thin rolled products thereby eliminating the
various intermediate steps.9

2.3    ROLLING PROCESS DESCRIPTION

       Rolling operations are mechanically similar for both aluminum and copper.  The primary
purpose of a nonferrous metal rolling operation is to reduce the gauge (thickness) of the metal
work piece and form it into a useful shape.2 The two basic types of rolling processes are hot and
cold rolling which  are used in most nonferrous rolling industries.  As stated previously, hot
rolling reduces metal ingots to medium gauge where further reduction takes place via cold rolling
to strip,  foil, and light-gauge sheet  sizes.  This section discusses  both hot and cold rolling
processes and the equipment employed during those operations.

2.3.1  Cold Rolling Process Equipment

       The primary equipment used to cold roll nonferrous metal includes a two- or four-high
rolling stand, work rolls, back-up rolls (four-high  mill), drive motors, roll bending  and gap
adjustment hydraulic systems, and the coil/recoil and core handling systems. More modern mills
contain gauge and shape controls.9 One set of this equipment constitutes a mill stand.
       A schematic diagram of the  deformation process on a two-high mill is illustrated in
Figure 2-1.  Two-high  simply  means  that metal is deformed between two steel work  rolls.
Figure 2-2 illustrates a  four-high single stand (i.e., one set of rolls) mill along with auxiliary
equipment.2 The four-high rolling stand represents a  special kind of two-high  roller where
backup rolls are used to reinforce the  smaller working  rolls.  These four-high mills resist the
tendency of long working rolls to deflect and thus permit the rolling of wider sheets and very
small thicknesses.9
       The work rolls are arranged vertically while the nonferrous metal is fed horizontally into
the mill at speeds ranging from 180 to 2,400 meters per minute (600 to 8,000 ft/min).2'8  The roll
force is supplied by the work rolls (via drive motor) perpendicular to the surface  of the metal.
The frictional forces that develop between the rolls and  the work piece carry the rolled product
through the mill.2
                                           2-4

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Mill  Input
                          Nonferrous  Metal Plate, Sheet, Strip or Foil
Mill  Output
     Figure 2-1. Schematic diagram of metal deformation process on a two-high mill.2



                                            2-5

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2-6

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       Deformation occurs in two dimensions such that tilt work piece is flattened and elongated
but not widened during the rolling process.  The work rolls are typically 0.76 meters (30 inches)
to 1.27 meters (50 inches) wide regardless of the mill type. The diameter of the work rolls,
however, is variable. The diameter of the work rolls for a typical two-high mill is approximately
0.61 meters (24 inches) and for a four-high mill is between 0.25 meters (10 inches) and 0.36
meters (14 inches).  The diameter of the back-up rolls for a four-high mill is approximately 0.76
meters (30 inches).2
       Coil/recoil equipment is provided for each  rolling  mill to feed the work rolls  on the
entrance  side and recoil the rolled product on the exit side (see Figure 2-2).  Tension is applied
to the work piece  during the  rolling operation to reduce the mechanical load required for
deformation.  The temperature  of the metal during each of the cold rolling steps is maintained
below about 100C (212F) by the application of a hydrocarbon-based lubricant/coolant.  The
lubricant serves to keep the rolls cool and minimize friction between the rolls and work piece.
The lubricant is supplied in excess, and the  overflow is collected, cooled, and filtered before
being recycled.2
       There are  several stages to the rolling operation.  The nonferrous metal ingot is first sent
to a breakdown mill where it is hot rolled, which is designed  to achieve maximum thickness
reduction per mill  pass (50 to  65 percent).21"   When the metal  has  been  reduced  to the
intermediate-gauge coiled sheet via further hot or cold rolling, it is sent to finishing mills where
it is cold rolled to final product Finishing mills improve the surface quality and accomplish the
final thickness reduction of the nonferrous  metal.  Finished rolls are machined  and polished to
a narrow dimensional tolerance and bright finish. In the production of very thin foil (aluminum
foil, for example), two layers of metal are often rolled simultaneously on the last pass through
the finishing mill (pair rolling).2
       After the rolling process is complete, the cold rolled metal is  sent to an  annealing oven.
The purpose of annealing is to relieve the strain hardening induced by the cold rolling process
and to vaporize  or burn off any  residual lubricant  present on the  coiled roll.  This is
accomplished by  heating the nonferrous metal above its recrystallization temperature allowing
new grain growth in the metal's microstructure.2  Typically, copper is annealed at temperatures
over 600C (1100F) while aluminum is annealed at temperatures in excess of 400C (750F).6
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       Lubricants are usually chosen so that their 90 percent distillation endpoint is exceeded
during annealing, allowing :nost of the residual oil to vaporize from the metal surface.  The net
result of the annealing process is an oil-free product with improved ductility properties.  This
annealed product is then either cut to size and packaged or shipped elsewhere for further
fabrication.2

2.3.2  Hot Rolling Process Equipment

       The process equipment used to hot roll nonferrous metal is generally the same as that
used in cold rolling. There are,  however, two major differences between hot and cold rolling.
The first is that hot rolling is performed above the recrystallization temperature of the alloy being
processed.  This provides a more ductile material allowing for greater thickness  reduction of
metal ingots.  The second difference involves the lubricant used in the rolling process. Either
no  lubricant (dry rolling) or, more typically, an oil in water emulsion (normally one to five
percent)6 functions as the lubricant rather than a mineral oil.

2.33  Deformation Theory and Heat Generation

       The use of rolling lubricant/coolant is required for most nonferrous metals due to the
amount of friction and heat generated at the roll nip or roll bite. Friction is generated  between
the metal and the work rolls during the rolling process.  A small amount of friction is  required
to keep the metal moving through the mill; however, excessive friction can cause the  metal to
adhere to the work rolls.  Lubricants are designed to eliminate excessive friction and provide an
adequate amount to keep the roll moving.  Heat is generated at the roll bite via mechanical
deformation stresses that occur in the metal from the rolling process.  The lubricant is designed
to remove this excess heat.
       Cold rolling lubricants are designed to maintain  the roll bite  temperature below 100C
(212F). Generally, hot rolling does not generate excessive heat because internal stresses created
during rolling are relieved at the high initial temperatures of the metal.  Excessive friction,
however, may induce the need for lubrication in such oxidation prone  nonferrous metals as
aluminum.  In this case, an  oil in  water emulsion is required to prevent sticking.  For some

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metals such as copper, dry hot rolling is viable.  In most cases, however, oil in water emulsions
are used to protect the steel work rolls  from excessive temperatures.6

2.4    ROLLING MILL VOC EMISSIONS

       Several sources of VOC emissions may exist in a rolling mill as a result of lubrication.
These include emissions associated with lubricative metal rolls during rolling operations, fugitive
losses associated with storage and transfer of rolling lubricants, and equipment lubricant losses
in gearboxes, bearings, etc.  The lubricants used can be categorized as either high or low viscous
oils. High viscosity oils are typically employed to control wear in gearboxes, back-up and work
rolls and other bearings, and drive spindles. The lower viscosity oils are used mainly for rolling
operations to prevent contact between the surface of the work rolls and metal, and to take away
the heat generated by friction and metal deformation. The rolling lubricant or oil is the main
potential source of VOC emissions resulting from rolling operations.9  This section  contains a
description of various rolling lubricants, their physical properties and characteristics, application
techniques, and the sources and factors effecting lubricant losses.

2.4.1  Types of Lubricants

       As stated previously, most rolling processes require some type of lubricant/coolant The
function of the lubricant varies by metal but most often it is used to dissipate heat and prevent
sticking of the metal to the steel work rolls.  Hot rolling processes generally use oil in water
emulsions, steam, or no lubricant at all (dry rolling).6'11  Cold rolling lubricants, however, can
vary significantly from metal to metal and from individual mill to individual mill.8'11 A summary
of the typical base lubricants used in rolling mills by nonferrous metal type is given in Table 2-1.
       Lubricants employed in the nonferrous metal rolling industry can be classified as either
a water-based emulsion or a mineral oil. Another viable option for some nonferrous metal rolling
operations, especially hot rolling, is the use of no  lubricant (dry rolling).15  This section also
discusses  lubricant additives which may be used in both lubricant categories.
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  TABLE 2-1. TYPICAL LUBRICANTS FOR NONFERROUS METAL ROLLING15'16
  Metal and Its Alloys
Cold
Hot
  Aluminum
  Copper
  Magnesium
  Refractory Metals


  Titanium
MO (4-20) with 1-5%
fatty acid, alcohol, ester

Foil:  as above but MO
(1.5-6)
Emulsion, 2-10%
concentration of MO
(80-400) with fat

MO (8-50) with fat
same  as Aluminum
MO with boundary and
EP agents

Oxidized surface, with
  esters of soap,
  castor oil (fatty oil) and
  compounded MO (4-10)
Emulsion, 2-15%
concentration of MO
(20-100) with <20% fatty
acid, alcohol, ester

Emulsion, 2-8%
concentration of MO
(80-400) with fat

Dry
same as Aluminum
MO with EP additives
Dry

Dry

Fat and water
 MO - mineral oil; viscosity in cSt at 40C in parentheses.
 EP - extreme pressure additives.
2.4.1.1  Water-based Emulsions


       Oil in water (O/W) emulsions contain oil in the dispersed (internal) phase with water as

the continuous (external) phase. Emulsions are regarded as having three principal components:

the oily phase, the emulsifier, and water. The oily phase contains the mineral oil and, depending

on the application, required additives such as animal or vegetable fats, fatty oils, and soap.15

Emulsifiers are surface-active substances  (surfactants) that reduce  interfacial tension between

water and oil allowing them to become emulsified.16  Water  must be appropriately treated and

cleaned to avoid adverse affects on emulsion stability.15 These oil in water emulsions are, for

the most part, restricted to hot rolling operations, but are being improved for possible use in cold

rolling applications.
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2.4.1.2  Mineral Oils

       As previously discussed, mineral oils may be used in the oily phase of an oil in water
emulsion; however, they may also be used as the primary constituent especially in cold rolling
applications.   Mineral  oils are mixtures of hydrocarbons obtained mostly from crude oil by
distillation.  Their properties depend on chain length, structure, and degree of refining. As the
number of carbon atoms per molecule (chain length) increases so do viscosity, flash point, fire
point, boiling point and volatility.  Mineral oils can be refined to  remove impurities such as
waxes, aromatic compounds, and sulfur compounds.  Super-refined mineral oils are closer to
synthetic oils in purity, but there is no best mineral oil for all nonferrous metal rolling.15

2.4.1.3  Lubricant Additives

       Few of the water-based or mineral oil lubricants fulfill all the requirements of a metal
rolling lubricant.  Almost all lubricants require additives to impart other properties of a non-
lubrication nature such as oxidation resistance, and corrosion protection. Selecting the correct
additives for the job is the function of the industrial oil chemist.  Boundary, extreme-pressure
(EP), solid and other general additives each serve a different purpose in improving the quality
of the rolling lubricant.  It should be  noted,  however, that some additives could be detrimental
to the metal being rolled.15
       Boundary additives include fatty acids, fatty esters, fatty oils, and soap detergents. Fatty
acids and the like, in quantities  as small as 0.1 percent, have been shown to reduce friction in
the working  of aluminum.  EP additives provide viscosity protection  of the lubricant in its
working temperature range.  General additives include oxidation inhibitors, corrosion inhibitors,
detergents, and defoaming agents.15

2.4.2  Lubricant Application Techniques

       Several types of lubricant application techniques are used in  the nonferrous rolling
industry, including spraying, dripping, and flooding. The application method chosen by a specific
mill depends on the type of metal being rolled, the type of mill used, and the mill rolling speed.2
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Air jets are typically used to distribute the lubricant (whether oil or water base) to appropriate
areas to perform both cooling and lubrication.15  Mill operators commonly adjust the lubricant
flow rate to achieve particular degrees of product quality.2
       In general, high-speed mills require larger amounts of lubricant due to the increased heat
and friction generated.2 Flooding techniques under high-pressure application are good for this
requirement.  Slower rolling speeds do not require as much lubricant and therefore may use low-
pressure spray or  drip application.   Proponents of  high-pressure application claim  that
impingement on the roll and strip surfaces helps to  break up a stagnant layer of lubricant or
steam and thus increases heat transfer. Adherents of low-pressure application regard quantity of
lubricant and wetting  as more important, with the additional benefit of less misting; this is
currently the  preferred method of the nonferrous rolling industry.15 The application system must
ensure that lubricant is supplied in sufficient quantities, uniformly over the entire  strip surface.
A sufficient quantity of lubricant must be available to carry away a minimum of 15 percent of
all heat generated.  Rolling oils are typically applied to the roll  at rates  from 1,500 to 3,000
liters/min per meter of width of rolled strip at pressures ranging from 150 to  1,000 kPa.15
       After being applied to the rolls, spent lubricant is drained into a rolling mill pit where it
is either disposed of or replenished and recycled.  Lubricant lifetimes can range anywhere from
three months to two years. After the lubricant's lifespan is reached, it can be burned in a plant
boiler, sold at reduced cost as a fuel oil, or sent offsite for treatment and disposal or recycling.2

2.4.3  Physical Properties of Various Rolling Lubricants

       Physical properties of the rolling lubricant are the major determining factor in choosing
a particular lubricant for a mill.  Important properties pertaining to the rolling process include
the boiling range, viscosity, and flash point.  Important properties pertaining to potential VOC
emissions  (also somewhat  important to the  rolling process)  include  specific  heat, heat of
vaporization, and vapor pressure.2  These properties for three average types of rolling mill
lubricants are given in Table 2-2.
       An important property to the rolling process is the boiling range of the lubricant  The
boiling range of a  lubricant must be lower than the  temperatures obtained during the rolling
process. Another important property to the rolling process is viscosity.  Gauge reduction will
                                          2-12

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               TABLE 2-2. IMPORTANT LUBRICANT PROPERTIES
Physical Property
Rolling Properties
Boiling Range - C (F)
Initial Boiling Point
Final Boiling Point
Viscosity - cst at 38C (100F)
Flash Point
C
CD
Emissions Level Properties
Specific Heat
J/kg-K
(BTU/lb-F)
Heat of Vaporization at 66C (150F)
J/g
(BTUAb)
Vapor Pressure at 38C (100F)
mrnHg

Kerosene

174 (346)
264 (508)
2.5

49-82
(120 - 180)

2,093
(0.50)
256
(HO)
1.2
Lubricant
Mineral Oil

254 (490)
321 (610)
4.5

127
(260)

2,031
(0.485)
221
(95)
0.02

CJ3 Linear
Paraffin

226(438)
242 (468)
1.93

93
(200)

2,303
(0.55)
323
(139)
0.7
typically increase, and surface finish will decrease with higher viscosity.  For this reason,
functionally different mills require different rolling lubricants. For breakdown mills, where gauge
reduction is more important  than surface finish, high viscosity lubricants may be used.  At
finishing mills, the surface finish is more important, and, therefore, low viscosity lubricants are
preferred.2  It should be noted that the physical properties of any base lubricant can be altered
with additives.
      Flammability characteristics of lubricants are measured by the lubricant flash point.2 The
flash point of an oil is the lowest temperature at which that oil will give off sufficient vapor to
ignite momentarily upon application of a flame.12 Therefore, a lower flash point constitutes more
of a fire hazard; additives, however, can be used to increase the  flash point of any lubricant.
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       The two major factors contributing to the level of VOC emissions are the heat removal
capability of the oil and the volatility of the oil. The properties  associated with heat removal
capacity are the specific heat and the heat of vaporization.2 A higher specific heat implies that
more energy must be  consumed to raise the temperature of a substance.   A high  heat of
vaporization also means that more energy is required to vaporize the material.  Therefore, a
rolling lubricant with high  values for each of these would be  preferred  from an emissions
reduction  standpoint.
       The volatility of a lubricant depends primarily on its vapor  pressure.  Vapor pressure
varies with both temperature and type of hydrocarbons present in the lubricant.2 A lower vapor
pressure implies a larger number of carbon atoms (higher molecular weight) in the oil entailing
a lower rate of evaporization. Thus, a higher molecular weight rolling oil would be preferred to
reduce the vaporization of the lubricant. The drawback to this is that higher molecular weight
implies higher viscosity12 reducing the practicality of the coolant at foil rolling mills where low
viscosity oils are preferred for better surface finish  and faster production speeds.
       Each property discussed above varies by lubricant type  and thus  will vary by metal
industry and within a metal  industry depending  upon its application. Differences in aluminum
and copper lubricants are a prime example of this.  Aluminum lubricants are typically lower in
viscosity than any other nonferrous rolling industry except magnesium.18 Lower viscosity implies
a shorter  chain length  resulting in a higher vapor  pressure and lower heat capacity.  Copper
lubricants are typically  two to three times as viscous as aluminum oils15'16 implying a lower vapor
pressure and greater heat capacity.  How these  properties affect emissions  is further discussed
in Section 2.4.5.

2.4.4  Sources of Lubricant Loss and Make-up

       VOC emissions from nonferrous metal rolling facilities result from several sources of roll
coolant loss and make-up.  Emissions are either in the form  of a  vapor  or an aerosol.  The
aerosol/vapor split is an important factor when considering applicability of various add-on control
devices.2   The  vapor/aerosol split tends to vary  with the test method  used to  obtain the
information.19 Data obtained by a major manufacturer indicate that between 5 and 50 percent of
the total aluminum rolling mill emissions may be in the aerosol form. However, other aluminum

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industry specialists believe that the majority of mill emissions are in the vapor phase.2 One test
conducted for brass and copper mills concluded that 80 percent of the hydrocarbon emissions
were aerosol with the remaining 20 percent in the vapor form.20
       Emissions to  the atmosphere are difficult to quantify because of the many factors that
affect lubricant inputs and losses at a  given mill.  Figure 2-3 shows the various routes  of
lubricant input losses inputs  in a typical rolling  mill.  Lubricant losses can be qualitatively
distributed between the following pathways:

              oil vaporized at the roll bite
              residual lubricant carried out  on metal, eventually vaporized or burned off during
              annealing
              lubricant spilled or splashed on floor
              lubricant vaporized from supply sump
              sump lubricant losses to overflow drain2

These losses are balanced by  three main input sources of lubricant:

              make-up lubricant supply to the sump
              equipment oil leaks to the sump
              residual lubricant on the incoming metal coil2

       Vaporization of lubricant at the roll  bite is the main source for VOC emissions at cold
rolling mills.  It has been estimated that  as much as 70 percent or as little as 20 percent of mill
emissions are captured  by existing hoods  and ductwork,  the remainder comprising fugitive
emissions.2  Also, little information exists on the magnitude of oil vaporization at the roll bite
where the largest fraction of heat  generated is dissipated.2
                                          2-15

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                                               Roof  or  Control System
                                            Capture  Hood
          Unwind
           Roll
          Pump
          Wind
           Roll
          Losses

     A   Out on Foil
     B -  Out Stack
     C -  Splash onto Floor
     D -  Evaporation  from Sump
     E   Loss to Sump Overflow Drain
   Inputs

F -  In  Foil
G   Makeup Oil to Sump
H   Equipment Leaks
Figure 2-3. Sources of lubricant loss and input in a nonferrous rolling mill.

                                 2-16

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2.4.5   Factors Affecting the Level of Emissions

       Several rolling mill operational factors can affect the level of VOC emissions from any
given mill.  Each factor can generally be classified as either a mill parameter or a lubricant
parameter.  Both of these types of factors are discussed in this section.
       Mill operating parameters determine the amount of coolant required to obtain the desired
rolled product.  These parameters include:

             mill production rate (mill speed)
             magnitude of gauge reduction per pass
             type of mill (breakdown, finishing, etc.)
             face velocity of the capture hood (if existent)

The first three mill parameters are interrelated.  Mill production rate, gauge reduction, and mill
type all determine the amount of heat and friction generated at  the roll bite.  In  turn, this
determines the  required operating temperature of the lubricant oil.   Additionally, these three
parameters determine the amount of lubricant required for adequate cooling.  Higher  heat
generation requires more lubricant and thus more potential for VOC emissions.2  Therefore, for
the same metal, high-speed rolling mills with large gauge reductions per pass would be expected
to have higher VOC emissions rates than lower speed mills with less gauge reduction.
       The affect of gas velocity at the capture  hood is also a consideration for VOC emissions.
High face velocities would be expected to increase the amount of oil droplet entrainment in the
exhaust gas stream reducing the chance  for lubricant recovery/recycling and  increasing the
relative amount of VOC emissions.2  Therefore, the gas velocity of the capture hood  should be
designed to minimize this excess oil entrainment, thus reducing the amount of VOC emissions.
       The following lubricant parameters determine to what extent the mill operating parameters
can be met:

             type of lubricant used  (see Table 2-1)
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             physical and chemical properties of the base oil and lubricant additives
             (see Table 2-2)
             method of oil application and application rate
             lubricant operating temperature

The type of lubricant used is a function of the metal being rolled and at what stage the metal is
in production. Thus, the metal being rolled determines many of the mill and lubricant parameters
that are responsible for emissions levels.  Lubricant type and lubricant properties are highly
influenced by product specifications. Lubricant properties most relevant to emissions levels are
vapor pressure, boiling point range,  specific  heat, and heat of vaporization (all  these were
discussed previously).  Lubricants with low volatility, high  specific heats,  and large heats of
vaporization are preferred for emissions reduction.2  It was noted in Section 2.4.3  that rolling
lubricant properties are  different for aluminum and copper.   The  differences include a higher
vapor pressure, lower boiling point range, and lower heat capacity for the aluminum rolling
lubricant. Each of these may contribute to the  observed higher ratio of VOC  vapor/mist for
aluminum versus copper rolling mills (see Section 2.4.4).
       The lubricant  application technique can  influence mill emissions by determining the
quantity and physical state of the lubricant.  Often, application technique is dictated by the type
of product and product quality.2 For example,  spraying the lubricant  through  a nozzle more
evenly distributes  the lubricant, but  increases the  potential  for VOC emissions  because the
lubricant is partially atomized in the spraying process.  Atomized lubricant is more  likely to be
lost as vaporized VOC emissions due to the greater surface area available for  evaporization. The
flooding technique, mainly used for high heat generating operations such as foil rolling, increases
the potential for splashing and sump overflow emissions.
       The operating temperature of the lubricant is  a very important factor  in determining
emissions because vapor pressure (hence, rate of lubricant evaporation) is strongly temperature
dependent. As discussed previously, mill parameters determine the required lubricant operating
temperature.  Lower oil operating temperatures are desirable  for emissions control because the
lubricant is less volatile at lower temperatures.2
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2.4.6   Degradation of Rolling Lubricant

       After many passes through a rolling mill, the lubricant begins to degrade causing a change
in its original properties. During the rolling process metal fines are generated which contaminate
the oil and must be removed before further use. A recirculation and filtration system is used for
this purpose. However, after several recycling and filtering steps, the bulk of the oil experiences
a change in physical properties. Additives that were used to  enhance base oil properties are
inadvertently filtered out and must be replenished. In order to recover original lubricant from
the dirty oil, a separate distillation process is required.  Since distillation is not conducted at most
nonferrous rolling mills, the dirty oil waste  is either burned in the plant or sold as a waste oil.
       Other degradation to the rolling lubricant takes  place over a period of time.   The
continuous high temperatures that rolling oils experience will, after a period of time, reduce the
viscosity (and, therefore, the usefulness) of the  oil.  Also, contamination occurs  from the
hydraulic oils used to lubricant machine parts.  These oils are usually heavier than the rolling oils
and over time will degrade the properties of the original rolling lubricant. Recovery of the base
rolling oil again requires the distillation step noted previously.

2.4.7   Current Emissions Controls in the Rolling Industry

       At present, very few U.S. rolling establishments employ  any type of control device to
reduce vaporized  VOC emissions.  Capture  devices are used in the aluminum industry to some
extent  Most aluminum foil operations utilize some type of capture system to remove lubricant
vapor from  the work area.  Aluminum sheet and plate operations are typically uncontrolled.8
Some copper rolling facilities use  capture  systems to collect and reclaim lubricant,  however,
industry-wide capture systems are not believed to  be prominent,18"21
       The  types of control equipment  used by  aluminum and copper  rolling  mills mainly
consists of impactors, centrifuges,  or mist  eliminators  designed  to control  VOC mist (mostly
considered to be  particulate matter greater  than 10 microns in diameter) as opposed to VOC
vapor.  Each of  these  devices is quite adept at  controlling particulate (most are 90 percent
efficient or better); however, none of these devices  are designed to control VOC vapor emissions.
                                          2-19

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       A number of U.S. mills, especially aluminum foil rolling mills, have, instead of add-on
control devices, implemented a change in rolling lubricant. Lubricants with different emissions
level properties, but with the same or better rolling properties (see discussion Section 3.4) have
been introduced and have proven their applicability and performance.  The new rolling oils
typically cost more than previous oils, but with the addition of distillation equipment have proven
themselves to possibly be the most cost-effective approach to lower VOC emissions.
                                          2-20

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2.5   REFERENCES
1.     Smimov, V.V. and A.I. Tselikov. Rolling Mills. Pergamon Press Ltd., Oxford, London.
      1965.

2.     U.S. Environmental Protection Agency.  Volatile Organic Compound Control at Specific
      Sources in Louisville, KY, and Nashville, TN. EPA-904/9-81-087.  Region 4, Atlanta,
      GA. December 1982.

3.     Executive Office of the President.  Standard Industrial Classification Manual. Office of
      Management and Budget, 1987.

4.     Teleconference between J. Manion of the Department of Commerce - Nonferrous Metals
      Division and S. Snow of Alliance Technologies Corporation. December 18, 1991.

5.     U.S. Department of Commerce.  1987  Census of Manufacturers, Industry  Series -
      Nonferrous Metal Mills and Miscellaneous  Primary Metal Products.  MC87-I-33D.
      Bureau of the Census.  Issued May 1990.

6.     Booser, E. Richard, Editor. Handbook of Lubrication - Theory and Practice ofTribology,
      Volume II. The American Society  of Lubrication Engineers.  CRC Press, Inc., Boca
      Raton, FL. 1983.

7.     Larke, Eustace C. The Rolling of Strip, Sheet, and Plate. Second Edition. Chapman and
      Hall, Ltd. 1963.

8.     Teleconference between  R.  Carwile of the Aluminum Association Incorporated and
      S. Snow of Alliance Technologies Corporation. January 2, 1992.

9.     Kumar, Surinder. Overview  of a Rolling  Mill from Proceedings of the Workshop on
      Characterization and Control of Aluminum Cold Rolling Mills.  Aluminum Association
      Incorporated.  November 1983.

10.   Teleconference between P. Mara of the Aluminum Association Incorporated and S. Snow
      of Alliance Technologies Corporation. December 18, 1991.

11.   Teleconference between C. Dralle of the Copper and Brass Development Association and
      S. Snow of Alliance Technologies Corporation. December 17, 1991.

12.   Avallone, Eugene A. and Theodore Baumeister HI, Editors.  Mark's Standard Handbook
      for Mechanical Engineers. Ninth Edition. McGraw-Hill Book Company, New York, NY.
      1986.
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13.    Shackelford, James F.  Introduction to Materials Science for Engineers.  Macmillan
      Publishing Company, New York, NY.  1985.

14.    Teleconference between M. Roark of Olin Brass Company in East Alton, IL and S. Snow
      of Alliance Technologies Corporation.  January 8, 1992.

15.    Shey, John A.  Tribology in Metalworking - Friction, Lubrication and Wear. American
      Society for Metals, Metals Park, Ohio. 1983.

16.    Kalpakjian, Serope and Elliot S. Nachtman. Lubricants and Lubrication in Metalworking
      Operations.  Marcel  Dekker, Inc., New York, NY.  1985.

17.    Sandberg, Elina and  Rolf Skold.  Water-based Aluminum Cold Rolling - Report from a
      Lubricant Development Program in Lubrication Engineering. Journal of the American
      Society of Lubrication Engineers.  Volume 41, Number 9. September 1985.

18.    Teleconference between V. Middleton of Olin Brass Company in East Alton, IL and S.
      Snow of Alliance  Technologies Corporation, with  March 16, 1992.

19.    Teleconference between M. Tanchuk of Reynolds Metals Company in Richmond, VA and
      S. Snow  of Alliance Technologies Corporation, with .  March 18,  1992.

20.    Barten, Axel E.   A  New System for Separation and Recycling of Mineral Oils  from
      Process  Fumes in Lubrication Engineering.  Journal  of  the American Society of
      Lubrication Engineers.  Volume 39, Number 12.  December  1982.

21.    Trip Report to Olin  Brass  Corporation, East  Alton, IL  by  Alliance Technologies
      Corporation. February 10, 1992. See Appendix  A.
                                        2-22

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                                    CHAPTER 3
                     VOC EMISSION CONTROL TECHNIQUES

3.1   INTRODUCTION

      This chapter contains descriptions of various VOC emission control techniques that may
be applicable to the nonferrous metal rolling industry.  Capture systems are briefly discussed in
Section 3.2 while control devices are discussed in Section 3.3.  Control devices discussed in this
chapter include fixed-bed and fluidized-bed adsorbers, thermal and catalytic incinerators, carbon
adsorbers, and  oil  absorbers.   Lubricant  substitution as well  as  process  and equipment
modifications are discussed in Section 3.4 and Section  3.5, respectively.  Estimated costs for
some of these control options are discussed in Chapter 4.

3.2   CAPTURE SYSTEMS FOR NONFERROUS ROLLING MILLS

      In the rolling plant, VOC vapors and droplets (mist) are generated from the rolling mill
stand via mechanisms described in Chapter 2.  Emissions left uncontrolled  can generate high
VOC concentrations in the work area compromising health, safety, and productivity. Control of
these VOC emissions can be achieved by ventilating the manufacturing area to well designed
control equipment.  Several capture devices  such  as enclosures, hoods, and other devices are
applicable to the rolling mill to remove vapor and liquid VOC from the manufacturing area and
transport them to appropriate control equipment.1
      Several factors are important in the design of a good capture system.  A primary capture
system criterion is that the system maximize VOC capture at the minimum cost.  Optimization
of cost is generally  achieved by increasing the degree of closure around  the emission area to
minimize  capture airflow, because  airflow  volume is  the primary factor influencing control
system cost.  However,  it is also necessary to  consider other issues in designing a practical
capture system.1
      Other considerations in addition to airflow  and cost include fire and explosion hazards,
visibility requirements, and maintenance access.  To prevent  the risk of fire or explosion, the
maximum VOC concentration  within capture and control systems should be kept below  25

                                         3-1

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percent of the VOC's lower  explosive limit  (LEL).  The LEL of a  vapor is  the  lowest
concentration (by volume) in air which will explode,  ignite, or burn when there is  an ignition
source. Because VOC concentrations are not uniform within the capture system and to ensure
that no large part of the capture system reaches concentrations greater than 25 percent of the
LEL, a good capture system should provide average VOC concentration around 10 percent of the
LEL.
       Worker visibility must be maintained so that operators can clearly observe the  rolling mill
operations. Also, maintenance  and repair of the rolling stand and the coil system requires ready
operator access to the mill by means of openings, movable hoods, or panels.1
       A typical rolling mill stand capture system is shown in Figure 3-1.  The rolling mill is
enclosed on four sides up to  the pass line.  Above the pass line,  canopy hoods or  slotted
perimeter hoods extend over  the rolling stand from the mill enclosure to each  coil.  This
arrangement can be augmented with flexible closures (such as rubber flaps) and air curtains that
further contain VOC emissions  while providing good visibility and ready access.  Little published
data exist to indicate how much of the cold rolling lubricant is removed from a typical exhaust
system. However, two industry sources revealed that  localized hooding can achieve 70 percent
capture while mill enclosures can attain 90 to 95 percent capture.213 _ Lubricant exhaust  system
air volumes for hot and cold rolling mills typically range  from 11.8 m3/s  (25,000 cfm) to 47.2
m'/s (100,000 cfm).4
       Proper design and maintenance of the control system can potentially reduce  lubricant
losses  and prevent lubricant entrainment into the exhaust gases.  Drains located in the ductwork
should be installed in proper  locations and regularly checked for possible obstructions.  The
ductwork should also be kept clean of metal scrap and other debris which could lodge itself in
the ductwork and become re-entrained or evaporated by the  exhaust gas stream.5

3.3    CONTROL DEVICES FOR NONFERROUS ROLLING MILLS

       After entering the capture system, the VOC-laden airstream is directed to a control device
which can either remove or destroy the volatilized lubricant from the airstream.   The  control
device exit airstream is then exhausted to the  atmosphere or recirculated to the plant.  Some
devices, such as the  carbon adsorber and  oil absorber, separate the VOC from the  airstream
                                          3-2

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                              Mill Housing
Plant Floor
                                                            Foursided
                                                            Enclosure
             Figure 3-1.  Typical rolling mill stand capture system.
                                      3-3

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without destroying it, allowing the VOC to be recovered or reused. In contrast, other control
devices, such as thermal or catalytic incinerators, destroy the VOC.  The following sections
describe devices which may be applicable for use in the rolling industry to remove VOC vapors
and mist from the air.   Specifically,  Section 3.3.1 discusses  carbon adsorption, Section 3.3.2
discusses absorption, and Section 3.3.3 discusses incineration.

3.3.1   Carbon Adsorption

       Adsorption is a non-chemical process that bonds gaseous molecules to other surfaces by
means of Van der Waals forces. In the carbon adsorption process, VOC emission streams pass
through a bed of activated carbon in which the VOC molecules  are captured on the porous carbon
surfaces. The adsorptive capacity of the  carbon bed tends to increase with the parameters such
as gas phase VOC concentration, molecular weight, diffusivity, polarity, and boiling point of the
VOC.6 After the working VOC capacity of the carbon is reached, the VOC can be desorbed from
the carbon  and  collected for reuse.
       Desorption of VOC from the used carbon bed is  typically achieved by passing low-
pressure steam through the bed.7 In this regeneration cycle, heat from steam forces the VOC to
desorb from the carbon and become entrained in the steam.   After the carbon bed has been
^sufficiently cleared of  VOC,  it is  cooled  and replaced  on line  with  the  emission  stream.
Meanwhile, the VOC-laden steam is condensed, and the VOC separated from the water by
decanting or, if necessary, by distillation. If the VOC is not recovered for reuse or reprocessing,
it may be incinerated.8   Some  systems use heating units and nitrogen gas rather than steam to
desorb the  VOC from the carbon bed.
       Two commonly used adsorption devices arc the fixed-bed adsorber and the fluidized-bed
adsorber.  Each of these is discussed separately in the following paragraphs.
       In a continually operating fixed-bed system, the VOC emission stream is passed  through
two or more non-mobile carbon beds. In a two-bed system, one bed is on-line with the emission
stream while the other bed is either being regenerated or on standby. When the first bed reaches
its working VOC  capacity, the emission stream is  redirected to the second bed, and the first bed
is regenerated.  While  two beds are common, three  or more  beds  can be used in a variety of
                                          3-4

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configurations, with more than one bed on-line at any given time.7  The carbon in a fixed-bed
system can typically be used for five years before replacement is necessary.6
       The fluidized-bed adsorber system contains one or more beds of loose, beaded activated
carbon.  The VOC emission  stream is directed  upward through the beds where the VOC is
adsorbed onto the carbon.  The flow of the emission stream stirs the carbon beads causing it to
"fluidize" and flow within the adsorber.  The VOC-cleaned air exiting the adsorber is passed
through a dust collector (to remove any remaining carbonaceous particles) then released into the
atmosphere.7  Regenerated carbon is continually metered into the bed while VOC-laden carbon
is removed for  regeneration.9  The beaded carbon may be used and regenerated many times
before replacement becomes  necessary.   Attrition for one brand  of adsorbent applicable to
aluminum rolling is reported to be less than 2 percent per year.10
       Fluidized-bed adsorbers can capture more VOC than a fixed-bed adsorber with a given
quantity  of carbon because the fluidized bed mixes newly regenerated carbon and VOC more
thoroughly, and because the system continually replaces used carbon with regenerated carbon.
This increased VOC-capacity  reduces costs for steam regeneration.
       Carbon adsorbers are commonly used for air pollution control and/or solvent recovery
from dilute Oess than 10,000 ppmy) streams of  VOC in air.  Adsorption provides a very low
outlet VOC concentration as well as the opportunity to recover and  reuse the VOC.  Collection
efficiencies can range from 95 to 99 percent for  well-operated systems. Packaged systems are
available with flow rate capacities beyond 170,000 m3/h (100,000 scfm).9
       The principal  advantage  of carbon  adsorption is that it is  very cost effective with
relatively low concentrations of VOC. In an adsorber, VOC recovery offsets operation costs, and
operation of  the adsorber is  relatively simple for both continuous  and intermittent use.  It is
essentially a dry process which provides an inherent safeguard against liquid carryover after the
vapor removal stage.
       Carbon adsorbers exhibit some disadvantages with certain types of VOCs such as those
which are difficult to strip  from carbon or  those which  are  miscible with water (such as
emulsions).   If  the collected VOC is miscible with water,  additional distillation measures are
necessary to recover the VOC. If steam-stripping is conducted with chlorinated hydrocarbons,
corrosion and wastewater treatment problems may occur.11  Also, carbon adsorption is relatively
sensitive to emission  stream humidity and temperature.  Dehumidification is  necessary if the

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emission stream has a high relative humidity  (greater than 50 percent) and cooling may be
required if the emission stream temperature exceeds 49 to 54C (120 to  130F).9
       Other disadvantages include frequent carbon changes (although less so for fluidized-bed
adsorption) and retrofit equipment installation.  Retrofit equipment includes hooding, ductwork,
and the control device itself as well as its support structure.12 Only one known U.S. facility has
installed a carbon adsorber on a new rolling mill. Other unknowns for rolling mill applicability
include FDA approval (aluminum industry only) for reuse of recovered oil12 and amount of
deterioration of the oil (i.e., loss of additives, contamination by desorbant) after desorption.

3.3.2  Absorption (Scrubbing)

       In the absorption process, VOC is removed from the emission stream  by absorption in a
liquid  solvent such as a high molecular weight oil.  Spray towers, venturi scrubbers, or other
methods are used to bring the absorbent into contact with the emission stream.   After the VOC
dissolves  into the solvent the cleaned gas is exhausted to the atmosphere and  fractional
distillation or some other method is used to recover the VOC from the absorbent.7'13
       Absorption is applicable to many industrial processes, including nonferrous metal rolling
mills.13'14  It is most efficient when the VOC is soluble in  the absorbent, and when the absorbent
boiling point is significantly higher than the VOC to be absorbed. Absorbers have been shown
to remove at least 86 percent and even greater than 99  percent of the waste stream VOC for
various species.8'11
       Oil absorbers can be used with a wide variety of organic compounds without many of the
problems associated with other VOC control devices such as the carbon adsorber or incinerator.
A closed-loop system  has  been developed that demonstrates na equipment  deterioration with
extended use and operates without generating steam, corrosion, or wastewater.11
       One source identified oil absorption as perhaps the most applicable  control device for
rolling mill emissions.2 Despite its advantages, however, most absorption systems are not cost
effective with very low inlet VOC concentrations.11 Typically, absorption systems are applicable
for VOC concentrations from 250 to 10,000 ppmv.9  A major disadvantage to the oil absorption
system is the deterioration in recovered lubricant  because absorption reduces the  amount of
lubricant  additives, therefore oil reformulation  must be  performed  adding another step to the

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process.  Another difficulty (for the aluminum rolling industry) could be gaining FDA approval
to reuse the  recycled oil.   Finally,  severe retrofit problems arise when considering an oil
absorption system for VOC control. Sufficient size and space areas must be located for hooding,
ductwork, control device and support structure.12  Some of these units may be taller (up to 60
feet) than the rolling plant they were  designed to control.15
       These restrictions make the oil absorber a less-frequently used option for VOC control
in the rolling industry.  In fact, no installations are known in the United States and only one is
used in Canada.12"15 For most industrial processes, the  waste stream VOC concentrations are
generally low,  making  absorption less desirable  than  adsorption or incineration  unless the
absorbent is easily regenerated or the solution  (lubricant) can be immediately returned to the
process stream.7

3.3.3   Incineration

       Incineration remove VOC from an emission stream by combustion, converting the VOC
into carbon dioxide, water vapor, and small quantities of other compounds.  The VOC-laden
emission stream enters the incinerator chamber where the VOC is ignited, sometimes with the
assistance of a  catalyst. Incinerator performance is a function of the waste gas heating value,
inert content, waste gas water content, and the amount of excess combustion air.7  Other design
variables include degree of mixing, residence time, and the type of auxiliary burning used.
       In contrast to adsorbers and absorbers, incinerators do not recover the  VOC for reuse;
however, valuable heat is generated during the combustion reaction which  may be recovered for
use elsewhere in the plant.  The  two types of incinerators in common industrial use are the
thermal incinerator and the catalytic incinerator.  Each of these are discussed in  the following
paragraphs.
       Thermal incinerators pass the emission stream through a combustion chamber where the
VOC are burned at temperatures  typically ranging from 700 to 1,300C (1,300 to  2,370F).7
Initially, burning is begun with the assistance of a natural gas flame or similar heat source.  If
the VOC in  the emission stream have  sufficient heating value and concentration, ignition
temperatures  can be sustained by the combustion of the VOC, and the auxiliary heat source can
be turned off.  If the ignition temperature cannot be maintained by combustion of the  waste

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stream alone, the auxiliary heat source must remain on. Auxiliary heat can be provided by fuels
such as natural gas, and from recovery of heat released during combustion.  Waste gases from
thermal incinerators are usually vented to the atmosphere.
       Catalytic incinerators are similar to thermal incinerators in that they eliminate VOC from
the waste stream  via combustion.  The  distinguishing feature of a catalytic incinerator is the
presence of a catalyst (such as platinum or copper oxide) that allows VOC combustion to take
place at a lower ignition temperature than normal.7'9 By allowing the combustion reaction to take
place at lower temperatures  than  required for a thermal  incinerator, less preheating of the
emission stream from auxiliary heat is necessary, and significant fuel savings can be achieved.
       In the  catalytic incinerator, the  emission stream is preheated to  approximately 320C
(600F) by recovered incinerator heat or by auxiliary burners.7  The preheated emission stream
is passed through the  catalyst  bed where combustion takes place on the  activated  catalytic
surface. The catalytic incinerators are operated from 320 to 650C (600 to 1,200F), significantly
lower than operating temperatures for thermal incinerators.  Higher temperatures can shorten the
life of the catalytic bed. Properly operated catalytic converters can be satisfactorily operated for
3 to 5 years before replacement of the catalyst is necessary.9
       Thermal and catalytic incineration are both widely used to control continuous, dilute VOC
emission streams.  Both types of incinerators can typically  achieve VOC control efficiencies of
approximately 98 percent7 For safety considerations, VOC  concentrations within the incinerator
are usually limited to 25 percent of the VOC's lower explosive limit. If the VOC concentration
is higher in the waste gas, dilution air  may be required.9   Packaged, single-unit thermal and
catalytic incinerators  are  available to control emission streams  with flow rates up  to  about
170,000 m3/h  (100,000 scfm).8'9
       Relatively  lower energy costs make the catalytic  incinerator an important option for
control of VOC from emission streams;  however, the catalytic incinerator cannot  be utilized in
as many applications as the thermal incinerator.  Catalytic materials can be quickly degraded by
many elements or compounds present in rolling mill emissions such as metal fines (particulates).
Many of these materials are burned without difficulty in thermal incinerators.
       Thermal and catalytic incinerators are often well-suited for control of VOC from rolling
mill emission  streams.   Heat  recovery is readily  attained with both  thermal  and catalytic
incinerators, enhancing the economics  of using  an  incinerator rather than other  VOC control

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devices.  Thermal incinerators remove particulates and other organics in addition to VOCs, thus
enhancing their utility.8
       However, there also exist some disadvantages  to using incinerators.  First, incinerators
destroy the VOC rather than recovering  them; in some cases (especially for petroleum based
lubricants), the energy benefit may not be as great as the lost value of the VOC.  One source
indicated that thermal or catalytic incinerators are technically but not economically feasible for
aluminum foil rolling emission control.16
       Incinerators may not be practical choices for VOC removal if certain types of VOCs or
other materials are burned. Incineration of VOC emission streams that contain halogens or sulfur
can produce acidic compounds such as HC1 or SO2; these streams are likely to require additional
equipment, such as a scrubber, for removal of the acid components, greatly adding to the cost
of the VOC control system.6 Catalytic incinerators are very sensitive to materials in the emission
stream that can reduce the effectiveness of the catalyst.  Phosphorous, lead, sulfur,  and halogens
can poison typical catalysts and severely affect  their performance.9  If it is necessary to use
catalytic  incineration to control waste streams containing these materials, special catalysts or
other measures must be employed. Liquid or solid particles that deposit on the catalyst and form
a coating also reduce the catalyst's usefulness by preventing contact between the catalyst and the
VOC.8'9
       For safety reasons, both thermal and catalytic incinerators may require large amounts of
dilution air to reduce the VOC concentration in the emission stream below 25 percent of the
LFX. Heating the dilution air to the ignition point of the VOC may be prohibitively expensive,
particularly if a waste gas contains entrained water droplets which must be vaporized and raised
to combustion chamber temperature. Finally, retrofit installation will require adequate space and
support strength to house the necessary equipment.

3.4    LUBRICANT SUBSTITUTION (SOURCE REDUCTION)

       Lubricant substitution is not considered a VOC control technique, but more of a pollution
prevention or source reduction technique.  Typically, new equipment or equipment modifications
are not required with a change of rolling lubricant, however, some process parameters, such as
mill speed, gauge reduction per pass, etc., will most likely be altered to accommodate the new

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lubricant's physical  properties.   This section  briefly discusses  the  physical  and chemical
properties associated with different types of lubricants  and relates those  to current industry
experience with the various lubricants.  The applicability of lubricant substitution to the rolling
process and as an emissions control technique is also explored.
       Note that most of the  information contained here pertains to the aluminum foil rolling
industry since it is within this industry that the latest developments in  lubricant  substitution to
reduce  VOC emissions  have occurred.  Also,  since water based emulsions  are  assumed to
represent a small amount of total VOC emissions from the  aluminum foil rolling industry, only
petroleum based lubricants are considered to be candidates for lubricant substitution.
       This section is organized  into four subsections that include a discussion of emission
reduction mechanisms for lubricant substitution (Section 3.4.1), a discussion of the applicability
of lubricant substitution to the rolling process (Section 3.4.2), a discussion of the applicability
of lubricant substitution as an emissions control method (Section 3.4.3), and a summary of the
advantages and disadvantages associated with lubricant substitution performed in the aluminum
foil rolling industry (Section 3.4.4).

3.4.1  Emission Reduction Mechanisms of Lubricant Substitution

       Differences in the physical properties of lubricants are the major reason that, theoretically,
a significant amount of  VOC emissions can be avoided  The major properties associated with
emission reduction are vapor pressure, specific heat, and heat of vaporization (see Section 2.4.3).
A lubricant with higher  vapor pressure implies a shorter chain length of hydrocarbons and thus
a lower molecular weight.  This allows higher lubricant  evaporation during the rolling process
when compared to a lubricant with lower vapor pressure (i.e., longer  chain length and higher
molecular weight).  For this discussion, the term heavy oil refers to those oils with a relatively
lower  vapor pressure (less than  1 mmHg) while thin oils refer to a relatively higher vapor
pressure (greater than 1 mmHg).  As discussed previously, heat removal capacity is important
in reducing emissions because a higher capacity implies that more  heat is necessary to vaporize
the lubricant. For this reason, for reducing emissions, a heavy oil with high specific heat and
heat of vaporization properties would be preferred to a thinner oil. These properties have resulted
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in reduced vapor generation  and lower material costs because more of the lubricant can be
captured and recycled.15
       The lubricant oil operating temperature is another very important mechanism affecting
emissions because the vapor pressure of the lubricant, and  therefore the rate  of lubricant
evaporation, is highly temperature dependent.17 Low operating temperatures are desirable from
the standpoint of emissions control due to the fact that the lubricant is less volatile at lower
temperatures. Many manufacturers of cold rolled aluminum have successfully experimented with
reducing oil operating temperatures to the  lowest possible temperature that  product quality
considerations will allow.12*17'18 Lubricant application temperature is typically the same for most
nonferrous rolling operations  averaging around 38  to 49C  (100  to 120F) although it may be
somewhat higher for aluminum operations.19
       New technologies are  emerging that use a water-based rolling oil for aluminum rolling
operations.  Several advantages could be realized with water-based lubricants  including better
heat removal, lower coolant  cost, lower emissions, better  mill safety, and FDA compliance.
However, there arc major disadvantages that render current water-based technology unfeasible
for aluminum rolling operations.   These  include sheet water  stain and  retrofit equipment
requirements for the new water-based systems.  These problems  are being addressed and there
are continuing efforts to find  a suitable substitute for the current  petroleum-based lubricants.20

3.4.2  Applicability of Lubricant Substitution to Rolling Process

       The aluminum foil rolling industry has traditionally used thinner oils than other nonferrous
rolling  industries because  of end-product  concerns.19  During  the  1980's, several facilities
experimented with lubricant changeover from the  traditional kerosene (a mixture of C10 - C16
hydrocarbons) lubricant to normal or  linear paraffin oils (Cn - CM).17  Linear paraffins are
components of the kerosene fraction of crude oils and are separated from kerosene in pure form
by molecular-sieve absorption.12"17 The paraffins were evaluated based  on physical properties and
other parameters pertinent to  the aluminum foil industry. These additional parameters include
surface finish quality, mill production rate, FDA approval, and flammability.12
       At least three separate studies indicate that the linear paraffin oil produced an equivalent
or better surface finish quality than the original kerosene lubricant.12"18*21 This was expected since

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the linear paraffin has a lower viscosity than kerosene  and surface  finish quality  generally
increases with lower viscosity.17 The linear paraffins also demonstrated better viscosity stability
than kerosene due to the relatively narrow boiling ranges of the paraffins.21 Long-term, full-scale
experiments indicated  that production rates were not adversely affected and actually  increased
with lubricant changeover to linear paraffins.18"21
       Linear paraffins  also comply with  FDA regulations that  are required  of aluminum
lubricants.12  Other nonferrous  metal rolling lubricants are not typically required to meet FDA
standards.19122 Flammability is  normally measured by  the lubricant flash point and, as data in
Table 2-2 indicate, linear paraffins exhibit a higher flash point than kerosene, ideally providing
an extra margin of safety against fire hazards in the  rolling plant12"17
       As  stated in Chapter 2, different mills require different lubricant properties  based on
several operating parameters. Also, different metals  require different lubricant properties based
on the reaction of the lubricant  to the metal which they are applied. Additionally, each stage in
the production of a particular metal-finished product may require inherently different lubricant
properties.  In some cases, these separate requirements can be met by the  addition of various
additive packages.  However, in the case of aluminum foil production, the initial stages where
rolling thicknesses  are high (aluminum sheet) require  a heavier oil relative to the  final stages
where rolling thicknesses are small  (aluminum foil).2  The reasons for this are surface finish,
production rates, metal reaction to oil, and^FDA approval.19
        Most other  types of  nonferrous metal rolling  operations typically use lubricants with
similar properties.  Copper and other nonferrous metal lubricants have nearly the  same vapor
pressure (less than 0.1  millimeters of mercury)22 and around the same viscosity. Differences may
occur  in the additive packages  used with each metal lubricant or the application method of the
lubricant.
        In  order for a facility to implement lubricant  substitution,  sufficient research and
development (R&D)  must occur to ensure  that the  new  lubricant  will  not interfere with
production. Bench-scale, pilot-scale, and full-scale tests are normally conducted to determine the
performance requirements of new oils.  For the aluminum foil industry, linear paraffins have
undergone extensive full-scale  tests and, on the basis of lubricant property assessment, there is
no apparent technical reason to believe that linear paraffins cannot be used as a lubricant for most
cold rolling of aluminum foil.12 If substitutes are to be found for other nonferrous metals, they

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must also undergo rigorous R&D to determine their applicability. A few other nonferrous metal
rolling operations are currently evaluating options not to change lubricants, but to recover and
reuse the oil they currently employ to roll.

3.4 J   Applicability of Lubricant Substitution as a Control Method

       No data exist to determine an exact level of VOC emissions reduction from lubricant
substitution in nonferrous rolling mills.  All plants and mills are different and many variables
must be considered in  order to determine emissions reduction.  However, a few case studies
exemplify the theoretical amount of rolling oil usage reduction possible  from aluminum foil
rolling mills  that switch from traditional kerosene to linear  paraffins.   Based on  a direct
comparison of lubricant physical properties, a potential emissions reduction of 10 to 30 percent
is  possible with changeover to linear paraffin oil.12"17  This potential, however, does not fully
account for the observed 63 percent reduction in oil usage (based on mass consumption) noted
at  one  aluminum rolling facility.17
       During  1980, Kaiser Aluminum and Chemical Corporation Permanente's Cupertino,
California plant underwent a full-scale experiment involving the substitution  of linear paraffin
for kerosene.  After six months of operation, total rolling oil usage had declined an average of
63 percent with the linear paraffin.  After this experiment, Exxon Corporation began,  in 1982,
marketing linear paraffins as aluminum rolling oils.  Since that time other mills report switching
to  the  new oil  and  have  experienced usage declines by as much as 50 percent.  Kaiser also
experienced other advantages from lubricant changeover including more stable oil viscosity, fewer
mill fires, higher quality aluminum foil, lower rolling oil odor, and a savings of major capital
expenditures  (for add-on  VOC control equipment).  There were disadvantages observed that
included a higher cost of the aluminum rolling oil, a slight change in annealing practices, and the
inconvenience of no local aluminum rolling oil supplier at that time (1980).21
       A separate study was performed at the ARCO Aluminum Louisville Rolling Plant in June
and July of 1982. ARCO experienced a lubricant use reduction of 58.5 percent and an organic
vapor reduction of 21 percent on one mill with a linear paraffin test oil.  It was noted that the
quality of rolled material was not  appreciably different than  that produced with the original
kerosene lubricant  A larger scale study was performed in early 1983 in which ten rolling mills

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in the plant were subjected to the new rolling oil.  Results were not as favorable with only a 30
percent reduction in lubricant use for the entire line during the  trial run.  Therefore, ARCO
determined that it was feasible to use the new rolling oil on only  about 60 percent of the mills
located at the Louisville facility.23  This indicates that, as stated previously, linear paraffin oil
may not be applicable to all aluminum foil rolling mills.
       Rolling mill VOC emissions are  difficult to measure with accuracy due  to the many
variables that can impact the results.  Observed emissions at one given time may vary greatly
between emissions observed at a separate time on the same mill.18 However, each  of these case
studies show that lubricant substitution can affect not only the lubricant emissions but the amount
of usage as well.  The reason is that the inherent lower volatility of linear paraffins reduces the
evaporative losses from rolling operations.

3.4.4  Summary of Lubricant Substitution Advantages and Disadvantages

       As  noted from the  case  studies presented here, there  are several  advantages  and
disadvantages that have been recognized with the implementation of lubricant substitution in the
aluminum rolling industry. No such case studies or literature were available for other nonferrous
metal rolling operations. Note that these advantages and disadvantages are general  in nature and
may not apply to a specific mill which implements lubricant substitution.
       Advantages and disadvantages observed from lubricant substitution in aluminum foil
rolling mills are listed given in Table 3-1.  References for each item are given in the table.  Note
that an exact relationship between lubricant usage and emissions  reductions has not been
developed, therefore the amount of VOC emissions reduction potential is unknown.  Also, the
level of R&D required will  vary  from mill to mill and cannot be estimated to any accuracy.
Table 3-1 indicates that there are more advantages than disadvantages realized from substitution
of linear paraffin for kerosene in the aluminum foil rolling industry.

3.5    PROCESS AND EQUIPMENT MODIFICATIONS

       Other pollution prevention techniques  besides lubricant substitution include various
process and equipment modifications.  These techniques should be applicable  to the entire
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TABLE 3-1.  SUMMARY   OF   ADVANTAGES   AND   DISADVANTAGES   OF
             LUBRICANT SUBSTITUTION EXPERIENCE IN THE ALUMINUM FOIL
             ROLLING INDUSTRY
 Advantages
Disadvantages
 Reduction in rolling oil usage (up to 63
 percent observed)12"21

 Presumably a reduction in VOC vapor
 emissions21

 No major process changes required21
 Capital cost savings (no add-on control
 devices required)12"21

 Lower rolling oil odor21
 Lubricant viscosity remained more stable
 than kerosene18"21

 Equal or better quality foil product (less
 staining, brighter surface finish)12"18"21
 Lower level of additives required18"21


 Higher mill speeds achieved12"18"21

 Simpler annealing process21

 Increased gauge reduction per pass21

 Cleaner working area21

 Greater  ease of lubricant filtering18

 Fewer mill fires observed21

 FDA approval12"15
 Higher cost of the linear paraffin18"21


 A broken matte surface observed under some
 conditions18

 Greater dragout than kerosene/mineral seal
 oil18

 Potential skin irritation (good personal
 hygiene practices required)18'23

 R&D required to determine applicability of
 new rolling lubricant12

 Linear paraffin cannot be re-sold as a waste
 fuel oil like kerosene12"15

 Additional recirculation and recycling
 equipment may be needed to offset higher
 cost of new rolling oils15

 No published data for reduction of VOC
sapors (unknown control effectiveness)
                                      3-15

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nonferrous rolling industry although most information sources were for the aluminum rolling
industry.  Process modifications relate to mill and lubricant operating parameters (discussed in
Section 2.4.6). Equipment modifications include the addition of better capture devices, filtration
equipment, and recirculation/recycling equipment. Each type of modification can affect the level
of emissions, however, no currently published data  cite the magnitude of the overall effect on
VOC emissions.

3.5.1  Process Modifications for Potential VOC Emission Reduction

       Many operating parameters can impact the amount of VOC emitted from any given rolling
mill.  They  include mill  speed, gauge reduction per pass,  hood face velocity, control system
design and  maintenance, lubricant application technique,  rate of lubricant application, and
lubricant operating temperature.  Each of these parameters can be modified with the potential for
reducing rolling mill emissions. This section discusses each of these parameters.
       The  first two parameters listed, mill speed and gauge  reduction per pass,  affect the
quantity  of heat generated at the work rolls. Higher mill speeds  and larger gauge reductions
generate larger amounts  of heat which require larger volumes  of oil  to provide adequate
lubrication and cooling.   Larger volumes  of  oil  provide the  potential for higher lubricant
emissions.17   Modification  to  these  operating parameters, however, may result in reduced
production.  It is unclear as to the level of decreased production due to changes in mill speed or
gauge reduction, and whether it would prove economically feasible to reduce VOC emissions by
this route.
       Another potential affect on VOC emissions is the  face velocity  of the capture hood.
Higher gas  velocities at the hood would  be expected to improve convective  mass  transfer
conditions at the oil surface and to increase the degree of oil droplet entrainment in the exhaust
gas stream.17  Both of these phenomena would tend to increase the apparent amount of VOC
emissions.  Thus capture hood face  velocities should be  adjusted to minimize  each of these
phenomena  while at the same time ensuring the  sufficient removal of mist  and vapor
concentrations in the workplace.17
       The method and rate of lubricant application  impact the quantity and physical state of the
oil which, in turn, affect the level of emissions. Spraying the lubricant through a nozzle increases

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the potential for VOC vapor because the oil is partially atomized in the process. Atomized oil
has better potential to become vaporized and emitted because of the increased surface area
available for evaporation.17  Flood and drip techniques may reduce the potential for VOC vapor
emissions, however, they cannot be as uniformly applied to the metal and work rolls as spraying.
Any modification of application technique is dictated by the required product quality, mill speed,
gauge reduction, and technical feasibility.  The lubricant application rate should be reduced to
that required to provide sufficient heat removal and lubrication with as little excess as possible.
Higher application rates are generally needed at higher mill production  rates (mill speed and
gauge reduction) because more heat is generated and must be removed.17
       The impact of operating temperature on the level of emissions was previously discussed
in Section 3.4.1 of this report and therefore will not be further discussed here.
       As stated in Section 3.4.2, some amount of R&D effort will be required to implement
many of the changes to the rolling process in order to reduce emissions.  Sufficient bench- and
full-scale testing will have to be performed to determine which process changes are feasible and
in what combination to implement them.

3.5.2   Equipment Modifications for Potential VOC Emission Reduction

       Figure 2-2, presented in Chapter 2, illustrates the basic elements of a lubricant recycling
system. The lubricant flow is cooled after application by plate or tube heat exchangers, and then
filtered through wire mesh filters and/or active earth filters before being recycled. The purpose
of filtration is to remove metal fines from the oil that may produce a rough product finish.  The
extent to which the lubricant can be recycled depends on the  mill temperature, the chemical
composition of base oil and additives, the effectiveness of the filtration system, and the type of
metal rolling taking place.12
       An efficient recirculation system will recover lubricant from the sump, clean out metal
fines and other impurities, and return the lubricant to the mill for reuse.22  Some rolling facilities
have installed an intricate lubricant reclamation system, the benefits of which are believed to far
exceed the costs. The benefits include nearly unlimited reuse of lubricant, reduced waste oil
generation, and lower waste oil disposal  costs.15  The required equipment  includes  efficient
filtration systems to filter,  cool, and recirculate the oil back to the mills.  A distillation unit

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provides long life for the lubricant by recovering usable oil from the waste oil generated in the
filtering system.  This oil recovery somewhat offsets the additional cost of the paraffin and the
lost income from the sale of used kerosene.  The linear paraffin cannot be re-sold as a waste fuel
oil, thus  oil recovery is  an economically feasible solution.  In addition, the distillation system
reduces off-site disposal costs associated with waste oil. The entire circulation system requires
the addition of collectors, filters, cooling units, oil tanks, and a distillation unit as well as the
auxiliary  equipment  associated with each.   Other considerations must be made for retrofit
construction equipment (i.e., supports and structure).15
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3.6   REFERENCES
1.     Roos, R.A., G.P.  Fenton, and R.W.  Ferryman.  "Containment of Fumes and Vapors
      Generated in the Aluminum Rolling Process" in Lubrication Engineering, Volume 40.,
      No. 10. pp.  621-626.  American Society of Lubrication Engineers. October 1984.

2.     Teleconference between M. Tanchuk of Reynolds Metals Company in Richmond, VA and
      S. Snow of Alliance Technologies Corporation. March 18, 1992.

3.     Teleconference between R. Carwile of the Aluminum Association, Inc., Washington, D.C.
      and S. Snow of Alliance  Technologies Corporation.  January 2, 1992.

4.     Roos, R. A.  "Control of Emissions Generated by Hot and Cold Rolling Operations in the
      Aluminum Industry" in  Lubrication Engineering, Volume 38, No. 5.,  pp. 288-294.
      American Society of Lubrication Engineers. May 1982.

5.     McTaggart,  Marcella.  "Overview of Rolling Mill Emissions" in Proceedings of the
      Workshop on Characterization and Control of Aluminum Cold Rolling Mill Emissions,
      November 16-17,  1983.  Clarksville, IN. The  Aluminum Association, Inc.

6.     U.S. Environmental Protection Agency.  OAQPS Control Cost Manual.  EPA-450/3-90-
      006.  Fourth Edition. Office of Air Quality Planning and Standards, Research Triangle
      Park, NC. January 1990.

1.     U.S.  Environmental Protection  Agency.  Control Techniques for  Volatile Organic
      Compound Emissions from Stationary  Sources.  EPA-450/3-85-008.  Third Edition.
      Office of Air and Radiation and the Office  of Air Quality Planning and Standards,
      Research Triangle Park, NC. 1986.

8.     Radanof, R.M. "VOC Incineration and Heat Recovery-Systems and Economics" in Third
      Conference on Advanced Pollution Control for the Metal Finishing Industry. EPA-600/2-
      81-028.   U.S. Environmental Protection Agency, Industrial Environmental Research
      Laboratory,  Cincinnati, OH. February 1981.

9.     U.S. Environmental Protection Agency. Handbook: Control Technologies for Hazardous
      Air Pollutants.  EPA-625/6-86-014.  Air and Energy Engineering Research Laboratory,
      Research Triangle Park, NC. September 1986.

10.   Heim, C.J.   "Volatile Organic  Emission Control  in  the Aluminum  Industry Using
      Fluidized Bed Carbon Adsorption" in Proceedings of the Workshop on Characterization
      and Control of Aluminum Cold  Rolling Mill Emissions,  November  16-17, 1983.
      Clarksville, IN.  The Aluminum Association, Inc.

11.   Ehrler, A.J.  "Closed-Loop Absorption for Solvent Recovery" in Metal Finishing Volume
      85, No. 11. pp. 53-56. November 1987.

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12.    Reynolds Metals Company, Richmond Foil Plant in Richmond, Virginia. Rolling Mill
      Emissions Reasonably Available Control Technology (RACT) Demonstration.  Prepared
      by Reynolds Metals Company, September 30, 1987.

13.    Barten, A.E. "A New System for Separation and Recycling of Mineral Oils from Process
      Fumes" in Lubrication Engineering, Volume 38, No. 12. pp. 754-757.  American Society
      of Lubrication Engineers;  December 1982.

14.    Wei, M.W., et  al.  "Development of An Absorption  Unit To Reduce Emission from
      Aluminum  Cold Rolling Operations"  for presentation at the 81st Annual Meeting of
      APCA, Dallas, Texas, June 19-24, 1988. Air Pollution Control Association.

15.    Trip Report to Reynolds Metals Company: Flexible Packaging Division, Richmond, VA
      by Alliance Technologies Corporation.  February 19, 1992.  See Appendix A.

16.    Burkhard, Kurt and Uwe Troll.  "Experience with the Achenbach Airpure  System to
      Control Rolling Oil Vapor and Mist" in Proceedings of the Workshop on Characterization
      and Control of Aluminum  Cold  Rolling Mill Emissions, November  16-17,  1983.
      Clarksville, IN. The Aluminum Association, Inc.

17.    U.S. Environmental Protection Agency.  Volatile Organic Compound Control  at Specific
      Sources in  Louisville, KY, and Nashville, TN.  EPA-904/9-81-087.  Region 4, Atlanta,
      GA. December 1982.

18.    Martin, Roy. "Linear Paraffin Experience - Reynolds Flexible Packaging Division" in
      Proceedings of the Workshop  on Characterization and Control of Aluminum Cold Rolling
      Mill Emissions, November 16-17, 1983. Clarksville, IN. The Aluminum Association,
      Inc.

19.    Teleconference between V. Middleton of Olin Brass Company in East Alton, IL and S.
      Snow of Alliance Technologies Corporation.  March 16, 1992.

20.    Payer, M.C.  "Development  of water based lubricants for cold rolling aluminum" in
      Proceedings of the international conference on Advances in Cold Rolling Technology,
      September  17-19, 1985..  London, England. The Institute of Metals in conjunction with
      The Institute of Measurement and Control.

21.    Landry, WJ.  "Use of Normal Paraffins in Cold Rolling Aluminum" in Proceedings of
      the Workshop on Characterization and Control of Aluminum Cold Rolling Mill  Emissions,
      November  16-17, 1983.  Clarksville, IN. The Aluminum Association, Inc.

22.    Trip  Report to Olin Brass  Corporation, East Alton,  IL  by Alliance Technologies
      Corporation. February 10, 1992.  See Appendix A.
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23.   Chapman, Kurt M.   "Trial Use of a Linear Paraffin  Rolling Coolant at  the ARCO
      Aluminum Louisville Rolling Mill" in Proceedings of the Workshop on Characterization
      and Control of Aluminum Cold  Rolling Mill Emissions, November  16-17,  1983.
      Clarksville, IN. The Aluminum Association,  Inc.
                                        3-21

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                                    CHAPTER 4
                            CONTROL COST ANALYSIS

4.1   INTRODUCTION

      This  chapter contains  estimated costs associated with VOC control  techniques for
nonferrous metal rolling mills.  Each VOC reduction method described in Chapter 3 is costed out
for a typical nonfeirous rolling mill configuration.  Section 4.2 presents the capital and annual
costs associated with VOC add-on control devices. Section  4.3 estimates the annual costs for
implementing lubricant substitution in a typical aluminum foil rolling mill. (Available literature
indicate that aluminum foil is the only nonferrous rolling industry to implement a lubricant
substitution program to reduce VOC emissions.)

4.2   VOC ADD-ON  CONTROL DEVICES

      Elements of a typical rolling mill and general cost parameters used to develop annual cost
estimates are given in Table 4-1. An exhaust flow rate of 20,000 acfm for a single mill was
chosen based on published information and review of facility operating permits.  An average
VOC concentration of 80 ppmv (vapor) was taken from Reference 1. It is noteworthy to mention
that although the control equipment costs developed in this section are for one mill, facilities may
prefer to install larger units to control emissions from two or more mills at one time.  The
following sections present capital and annual costs for the installation and  operation of carbon
adsorbers (Section 4.2.1), oil absorbers (Section 4.2.2),  thermal incinerators  (Section 4.2.3), and
catalytic incinerators (Section 4.2.4). These costs do not include any downtime costs that may
be required for installation of equipment on a specific rolling  mill.  Lost production in the short-
term would certainly increase the capital costs  associated with add-on control devices. All costs
presented here were derived from available literature and EPA cost manuals as referenced in each
subsection.
                                         4-1

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       TABLE 4-1.
GENERAL PARAMETERS AND COST FACTORS
FOR ESTIMATING COSTS FOR ADD-ON CONTROL
DEVICES
Parameter or Costs
                Specified Value
Exhaust flow rate
VOC concentration
Utilities
      Electricity
      Cooling water
      Natural gas
Operating labor (OL)
Supervision labor (SL)
Maintenance labor (ML)
Maintenance materials (MM)
Overhead
Administration costs
      Adsorption and absorption
      Thermal and catalytic incineration
Capital recovery factor

Operating hours
                20,000 acfm
                80 ppmv

                $0.06/kWh
                $0.20/1,000 gal
                $3.30/1,000 ft3
                $13.12/hr
                15% of operating labor
                $14.50/hr
                100% of maintenance labor
                60% of OL, SL, ML, and MM

                4% of total capital investment
                2% of total capital investment
                0.1628 (Based on equipment life of 10 years
                and interest rate of 10%)
                8,500/yr
                                    4-2

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4.2.1   Carbon Adsorption

       Costs for carbon adsorbers were derived from an EPA document that pertained specifically
to the aluminum foil industry.1  The costs were developed for one rolling mill configuration (see
Table 4-1).  Table 4-2 lists the assumed equipment parameters used to develop the capital and
annual costs. Table 4-3 contains annual costs which were updated to February 1992 dollars by
the use of equipment cost indices in Chemical Engineering.2 The table shows that direct annual
costs amount to $44,700, indirect annual  costs sum  to $640,600, and total annual costs equal
$685,300.  Note that the highest cost impact is associated with capital recovery, which is a
function  of total  capital investment   This indicates that high  initial  equipment  costs are
associated with carbon  adsorption as a control option.

4.2.2   Absorption (Scrubbing)

       Costs for oil absorption control were also derived from  the document that  contained
carbon adsorption costs and, as before, were developed for one rolling mill configuration.1 Table
4-4 gives the equipment parameters used to develop annual costs _pf absorption.  Table 4-5
presents the annual costs which were updated to February 1992 dollars by the use of equipment
cost indices in Chemical Engineering.2 Table 4-5 shows that direct costs amount to $120,500,
indirect costs sum to $659,100, and total annual costs equal $779,600.  As  with for carbon
adsorption, the highest  cost impact is associated with capital recovery (i.e., capital investment).

4.2.3   Thermal Incineration

       Costs for thermal incineration control were derived from published EPA documents that
provide generic estimating procedures for costing add-on  air pollution control equipment  for
industry in general.3'4  Table 4-6 lists the equipment  parameters used to derive annual costs  for
thermal and catalytic incineration. Table  4-7 presents the annual costs associated with thermal
incineration which were updated to February  1992 dollars by the use of equipment cost indices.2
The table indicates that  direct costs amount to $574,600, indirect costs sum to $126,500, and total
annual costs equal $701,100.  In contrast  to adsorption and absorption, the highest cost impact

                                          4-3

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   TABLE 4-2.  OPERATING AND LABOR REQUIREMENTS USED TO
               ESTIMATE ANNUAL COSTS FOR FLUIDIZED-BED
               CARBON ADSORPTION
Item
Requirement
Carbon required
Desorption fuel needs
Column pressure drop
Nitrogen needs
Carrier gas electrical
Operating labor
Maintenance labor
Nitrogen cost
Control efficiency
175 lb/1,000 cfm
4,000 BTU/lb of lubricant recovered
6 inches water
0.05 scf/lb of lubricant recovered
12kWh/hr
0.5  man-hr/shift
0.5  man-hr/shift
$1.10/1,000 scf
95%
                                   4-4

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 TABLE 4-3.  CAPITAL AND ANNUAL COSTS FOR FLUIDIZED-BED CARBON
             ADSORPTION*
Item
Total Capital Investment
Direct Annual Costs
Raw Materials
Carbon replacement15
Carbon reactivation1*
Utilities
Electricity
Cooling water
Nitrogen
Operating Labor and
Supervision
Maintenance
Labor
Materials
Annual
Quantity


350 Ib
3,150 Ib
2.37 x 105 kWh
5.53 x 106 gal
11,556 scf
611 man-hr
531 man-hr
(100% of
Unit
Cost($)


7.00/lb
1.10/lb
0.06/kWh
0.20/1,000 gal
1.10/1,000 scf
13.12/hr
14.50/hr
Cost($)
3,090,000

2,450
3,500
14,200
1,100
13
8,000
7,700
7,700
                                  maintenance
                                       labor)
 TotaJ Direct Annual Costs
 Indirect Annual Costs
 Administrative Costs
 Overhead
 Capital Recovery

 Total Indirect Annual Costs
 Total Annual Cost
     (4% of capital investment)
(60% of OL, SL, ML, and MM)
 (16.28% of capital investment)
 44,700

123,600
 14,000
503,000

640,600
685,300
'Costs are in May 1992 dollars.
''Based on assumption of regeneration once per year with 10 percent losses.
                                     4-5

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   TABLE 4-4.  OPERATING AND LABOR REQUIREMENTS USED TO
               ESTIMATE ANNUAL COSTS FOR OIL ABSORPTION
Item
Requirement
Wash oil
      Flow rate
      Heating capacity
      Total inventory
Heat generation
Vacuum pumps (2)
Column pressure drop
Operating labor
Maintenance labor
Absorber oil
Control efficiency
45 gpm
0.65 BTU/lbF
1,225 gal
electrical
30 hp each
10 inches water
2.0 man-hr/shift
1.0 man-hr/shift
$1.20/gal
95%
                                   4-6

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              TABLE 4-5.  CAPITAL AND ANNUAL COSTS FOR OIL
                           ABSORPTION11
 Item
  Annual
  Quantity
  Unit
 Cost($)
Cost($)
 Total Capital Investment

 Direct Annual Costs

 Raw Materials
       Absorber oil

 Utilities
       Electricity
       Cooling water


 Operating Labor and
 Supervision

 Maintenance
       Labor
       Materials
 Total^Direct Annual Costs

 Indirect Annual Costs

 Administrative Costs

 Overhead

 Capital Recovery


 Total Indirect Annual Costs

 Total Annual Cost
       300 gal


9.24 x 10s kWh
  8.96 x 106 gal


  2,444 man-hr
  1,063 man-hr
      (100% of
   maintenance
         labor)
      1.20/gal


    0.06/kWh
0.20/1,000 gal


      13.12/hr
     14.50/hr
         (4% of capital investment)

    (60% of OL, SL, ML, and MM)

     (16.28% of capital investment)
                                    3,064,000
    360


 55,400
   1,800


 32,100
 15,400
 15.400
                  120,500



                  122,600

                   37,700

                  498,800


                  659,100

                  779,600
"Costs are in May 1992 dollars.
                                      4-7

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 TABLE 4-6. OPERATING AND LABOR REQUIREMENTS USED TO
             ESTIMATE ANNUAL COSTS FOR THERMAL AND
             CATALYTIC INCINERATORS
Item
Requirement
Auxiliary fuel - natural gas
      Thermal
      Catalytic
Heat recovery
      Thermal
      Catalytic
System pressure drop
      Thermal
      Catalytic
Operating labor
Maintenance labor
Control efficiency
      Thermal
      Catalytic
Volume of catalyst bed
Precious metal catalyst
310 scfm
200 scfm

70%
50%

15 inches water
8 inches water
0.5 man-hr/shift
0.5 man-hr/shift

99%
95%
40ft3
SS.OOO/ft3
                                  4-8

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           TABLE 4-7.  CAPITAL AND ANNUAL COSTS FOR THERMAL
                        INCINERATION"
Item
Total Capital Investment
Direct AnnuaHQosts
Utilities
Natural gas
Electricity
Annual
Quantity


1.58 x 108 scf
4.96 x 105 kWh
Unit
Cost($j


3.30/1,000 scf
0.06/kWh
Cost($)
615,500

521,400
29,800
 Operating Labor and
 Supervision
 Maintenance
       Labor
       Materials
 Total Direct Annual Costs
 Indirect Annual Costs
 Administrative Costs
 Overhead
 Capital Recovery

 Total Indirect Annual Costs
 Total Annual Cost
 611 man-hr
 531 man-hr
   (100% of
maintenance
     labor)
13.12/hr
14.50/hr
      (2% of capital investment)
 (60% of OL, SL, ML, and MM)
  (16.28% of capital investment)
8,000
7,700
7.700
             574,600

              12,300
              14,000
             100.200

             126,500
             701,100
"Costs are in May 1992 dollars.
                                     4-9

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for thermal incineration is associated with direct costs, especially utilities, due to the auxiliary
fuel (natural gas) requirement.  The high natural gas requirement is directly related to the low
VOC concentrations that are typically associated with rolling mill emissions (in this example 80
ppmv - see Table 4-1).

4.2.4   Catalytic Incineration

       Costs for catalytic incineration control were derived from the same published EPA cost
literature used for thermal  incinerators.3'4  Previously shown Table 4-6 lists the equipment
parameters used to derive annual costs  for catalytic (and thermal)  incineration.  Table  4-8
presents the annual costs associated with catalytic incineration which were updated to February
1992 dollars by the use of equipment cost indices.2  The table shows that direct costs amount to
$444,900, indirect costs sum to $127,800, and  total  annual costs equal $572,700.  As with
thermal incinerators, note that  the highest annual cost impact is associated  with direct costs,
especially utilities, due  to the auxiliary fuel (natural gas) requirement.  The high natural  gas
requirement is, as stated before, directly related to the low VOC concentrations that are typically
associated with rolling mill emissions. Here, however,  natural gas costs are less than for thermal
incineration due to the presence of a catalyst.

4.3    LUBRICANT SUBSTITUTION

       This section contains cost data for implementing lubricant substitution as a VOC emission
control method. In order to consider lubricant substitution, many elements of unknown cost must
be considered. For this reason,  a complete profile of the capital and annual costs associated with
lubricant substitution is not given here.  As  stated in Chapter 3, the only nonferrous rolling
operation to have experimented with lubricant substitution is the aluminum foil industry. This
is because aluminum foil rolling oils typically have a higher vapor pressure than other nonferrous
rolling oils  and thus  higher lubricant "volatilization.5  As such, all  qualitative and quantitative
information contained here apply  only to the aluminum foil industry.
       The exact capital and annual costs for lubricant substitution are difficult to determine for
a specific facility due to all the unknowns associated with changeover.  Table 4-9 lists the general

                                          4-10

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              TABLE 4-8.  CAPITAL AND ANNUAL COSTS FOR CATALYTIC
                           INCINERATION'
Item
Total Capital Investment
Annual
Quantity

Unit
Cost($)

Cost($)
608,000
 Direct Annual Costs

 Raw Materials
       Catalyst replacement"
 Utilities
       Natural gas
       Electricity


 Operating Labor and
 Supervision

 Maintenance
       Labor
       Materials
 Total Direct Annual Costs

 Indirect Annual Costs

 Administrative Costs

 Overhead

 Capital Recovery


 Total Indirect Annual Costs

 Total Annual Cost
         40ft3


  1.02 x 108 scf
2.63 x 105 kWh


    611  man-hr
    531 man-hr
      (100% of
   maintenance
         labor)
     3,000/ft3

3.30/1,000 scf
    0.06/kWh


     13.12/hr
     14.50/hr
         (2% of capital investment)

    (60% of OL, SL, ML, and MM)

     (16.28% of capital investment)
 69,100


336,600
 15,800


  8,000
  7,700
  7,700
                  444,900



                    14,800

                    14,000

                    99,000


                  127,800

                  572,700
Costs are in May 1992 dollars.
bAssume a two year catalyst lifetime and 10 percent interest (CRF = 0.5762).
                                      4-11

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  TABLE 4-9.  GENERAL ASSUMPTIONS AND COST FACTORS USED TO
               DERIVE LUBRICANT SUBSTITUTION COST IMPACT
 Item                                           Specified Value
 Annual emission rate                              200 tons
 Lubricant sump capacity                           800 gal
 Lubricant replacement frequency                    every 14 days
 Kerosene cost                                    $1.00/gal
 Linear paraffin cost                               $1.44/gal
 Waste kerosene value                             $0.64/gal
 Lubricant density @ 60.0F                        $6.36 Ibs/gal
 Lubricant use reduction                            10-60%*
Tor purposes of showing lubricant substitution costs, lubricant use reductions of 10,20,30,40,50, and 60 percent
 were considered.
                                    4-12

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assumptions and average costs (in May 1992 dollars) used to estimate the annual costs associated
with lubricant substitution from kerosene to normal paraffin for a single aluminum foil rolling
mill.  Table 4-10 contains the algorithm that was used to determine the annual costs associated
with lubricant purchases for an example emissions reduction of 30 percent. Finally Table 4-11
presents the estimated lubricant use savings and annual costs at six different levels of lubricant
use reduction. Although lubricant use is reduced, annual costs are increased due to the higher
cost of linear paraffin compared to kerosene.  Note that an annual cost savings occurs  at a
lubricant use reduction of greater than 50 percent. Here, lubricant use savings are large enough
to offset the increased cost of linear paraffin oil.
      It should be stressed that  the costs presented in Table 4-10 do not include the research
and development required to implement lubricant substitution.  Nor do they include costs for
downtime (and thus lost production) needed to conduct pilot-scale  tests  of  new lubricant
formulations. R&D and downtime costs are difficult to determine because every rolling mill is
different and requires different lubricant properties.  It is uncertain whether all nonferrous rolling
mills would be able to implement lubricant substitution, although many aluminum foil mills have
had much success in switching from kerosene to linear paraffins.
                                         4-13

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         TABLE 4.10  EXAMPLE CALCULATION OF ANNUAL COST FOR
	LUBRICANT SUBSTITUTION	

Basis:         - one year of operation
              - annual emission of 200 tons/yr
              - 30 percent emission reduction
              - lubricant replacement every two weeks
              - 800 gallon sump capacity
              - 10 percent annual interest rate for working capital
              - lubricant density = 6.36 Ibs/gallon

                   Total oil purchased = Waste lubricant plus lost emissions
         Total kerosene purchased  = 26 (800 gallons) + 200 ton f2'000 to
                                                               ton     6.36 Ibs
                                 - 83,693 gallons/yr
       Total paraffin purchased = 26 (800 gallons) + 0.7 (200 ton) f2'000 te) f  gg/  )
                                                             V   ton  ) (6.36 Ibs)
                             = 64,825 gallonsfyr
  Oil cost differential = paraffin purchased x paraffin cost - kerosene purchased x kerosene cost
                    = (64,825 gallons) ($1.44/gallon) - (83,693 gallons) ($l.00fgallon)
                    = $9,655/yr
                Interest on working capital = oil cost differential x interest rate
                                         = 9,655 (O.lO/yr)
                                         = $966
             Total annual cost ~ oil cost difference plus interest on working capital
                             = $9,655 + $966
             Total annual cost = $10,621
                                          4-14

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          TABLE 4-11.  ANNUAL COSTS FOR LUBRICANT SUBSTITUTION
                        AT VARIOUS LUBRICANT USE REDUCTIONS
Lubricant
Use
Reduction
10%
20%
30%
40%
50%
60%
Annual Lubricant
Use Savings
(gal/yr)
6,289
12,579
18,868
25,157
31,446
37,736
Annual"1"10
Cost
($)
28,000
18,900
9,700
600
(8,500)
(17,700)
"Costs do not include research and development costs for implementing lubricant substitution.
''Costs in parentheses () are actual savings - negative costs - from reduced lubricant usage.
Costs are in May 1992 dollars.
                                     4-15

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4.5   REFERENCES
1.     U.S. Environmental Protection Agency. Volatile Organic Compound Control at Specific
      Sources in Louisville, KY, and Nashville, TN.  EPA-904/9-81-087. Region 4, Atlanta,
      GA. December 1982.

2.     "Chemical Engineering Plant Cost Index and Marshall & Swift Equipment Cost Index"
      in Chemical Engineering, Volume 99, Number 5. McGraw-Hill, New York, NY.  May
      1992.

3.     U.S. Environmental Protection Agency. Handbook: Control Technologies for Hazardous
      Air Pollutants.  EPA-625/6-91/014.  Air and Energy Engineering Research Laboratory,
      Research Triangle Park, NC.  June 1991.

4.     U.S. Environmental Protection Agency.  OAQPS Control Cost Manual.  EPA-450/3-90-
      006. Fourth Edition. Office of Air Quality Planning and Standards, Research Triangle
      Park, NC. January 1990.

5.     Teleconference between V. Middleton of Olin Brass Company in East Alton, IL and
      S. Snow of Alliance Technologies Corporation. March  16, 1992.
                                        4-16

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 APPENDIX A
TRIP REPORTS
     A-l

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          ALLIANCE
          Technologies Corporation
Date:  May 13, 1992

Re:   Site Visit - Olin Brass Corporation, East Alton, IL
      Nonferrous Metal Rolling
      EPA Contract 68-DO-0121; Work Assignment 1-30
      Alliance Reference No. 1638030
From: W. Scott Snow  ">)/.
      Alliance Technologies Corporation

To:   Joseph Myers
      OAQPS/ESD/ISB (MD-13)
      U.S. Environmental Protection Agency
      Research Triangle Park, NC 27711
I.     PURPOSE

             The purpose  of this visit was to gather background information on the metal
      rolling process including information necessary to characterize the process parameters,
      VOC emissions, emissions control techniques, and control costs.
H.     PLACE AND DATE

       Olin Brass Corporation
       427 N. Shamrock Street
       East Alton, IL 62024
       (618) 258-2000

       February 10,  1992
       ATTENDEES

       Olin Brass Corporation (Olin)
       L. William Maxson, Director, Energy and Environmental Services
       Michael L. Roark, Manager, Environmental Affairs
              100 Ejrooa Drive. Suite ^50. Chanel Hill. North Carolina 27514  919-968-9900

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       Olin (continued)
       Daniel J. Angeli, Engineer Associate
       Verne L. Middleton, Hydraulic and Lube Engineer - Mill Products Engineering

       Alliance Technologies Corporation (Alliance)
       W. Scott Snow, Environmental Engineer
       Phil J. Marsosudiro, Environmental Engineer
IV.    DISCUSSION
       A.     Summary

              Alliance's visit to Olin Brass began around 9 a.m. with Mr. Mike Roark and Mr.
       Bill Maxson at the Olin facility located on Highway 3. During the introductory meeting,
       Alliance  and Olin reviewed the agenda for the day, and Alliance requested that Olin
       provide copies of the plant's air and water operating permits as well as facility drawings
       illustrating the location of the rolling mills  and other processes within the Olin facility.
       Alliance  then toured the #3 Plant, which contains several specialty cold rolling mills, and
       the Casting Plant which contains a hot mill. After the tour, Alliance met with Mr. Dan
       Angeli, engineering  associate,  to discuss  operations at Olin's two main cold rolling
       facilities. After the meeting, Alliance proceeded to lunch for discussion with Mr. Verne
       Middleton, hydraulic and lube engineer. After lunch, Alliance toured the two cold rolling
       facilities (Brass Mill, Zone 1; and Building 280).  The tour was followed by a closing
       meeting with Mr. Angeli, Mr. Maxson, and Mr. Roark. During this meeting, Alliance and
       Olin assembled information requested in the initial questionnaire and confirmed plans for
       review of the trip report  and confidential business information  (CBI).
       B.     Olin Brass Market Profile

              Olin Brass is one of the nation's largest producers of rolled copper and copper
       alloys. Major end-users for Olin rolled alloys include the transportation industry, the U.S.
       Mint, and the military.  Other end-products may be sent to rerollers or other distributors.
       Copper and copper alloy coils  are shipped to  customers or other fabricators in various
       sizes, but the typical coil exiting a mill stand weighs approximately 11,000 to 14,000 Ibs,
       with a width of approximately 30 inches and outer and inner diameters around 4 feet and
       16 inches,  respectively.

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C.     Manufacturing Supplies

       Olin Brass uses many different raw materials in their rolled alloy manufacturing
process.  The main raw  material is metal scrap, including copper, tin, brass alloys of
copper and zinc, and other metals. Rolling oils make up another major category of raw
materials. Two types of petroleum hydrocarbon oil and an oil-in-water emulsion are used
for lubrication and cooling.   The oil-in-water  emulsion typically contains less than 10
percent oil.  In addition, both the hydrocarbon oils and the oil-in-water emulsion contain
various proprietary additives in amounts less than 10 percent of the total lubricant volume.
None of the rolling lubricants must have Food and Drug Administration (FDA) approval.

       According to material safety data sheets  (MSDSs), vapor pressures range from
"nil"  to less than 0.1 mmHg at 20C  for the two hydrocarbon lubricants used  at the
facility. The vapor pressure  of the oil-in-water emulsion was not determined.  According
to Mr. Roark, none of the rolling lubricants  are considered volatile organic compounds
(VOCs) for the purposes of  the Illinois state  permit process. However, EPA definitions
for VOC state no such vapor pressure qualification.

       Olin reported that "nearly all" of the  oil used in the rolling process is collected,
cleaned,  and reused at the plant.  An intricate collection system that includes hooding,
lubricant recovery from exhaust gases, and lubricant spillover pits is in place on most of
Olin's rolling mills.  An exact estimate of the amount of  lubricant lost per year to the
atmosphere, wastewater,  and in the exit coils was not available.
D.     Manufacturing Process Parameters

       The processes examined during this plant visit included hot rolling, cold rolling,
annealing, and finishing of copper and  copper alloy products.   These processes and
several intermediate processes are shown in Attachment 1,  taken  from promotional
material published by Olin Brass.

       In the hot rolling process, cast metal bars, measuring approximately 6" x 30" x
25', are  heated to around 900C (1650F) then transferred to the single hot rolling mill
at the Olin facility.  In the hot mill, the metal bar undergoes several passes (around 10
to 14) through a pair of steel work rolls which reduces the gauge thickness. The hot mill
is reversible  allowing the metal to be passed through the work rolls  several times until
shaped into a strip of approximately 3/8" x 30" x 460' at which time it is wound onto a
coil.  A jet water spray system serves only to cool the steel work rolls and is not designed
to cool the rolled metal.

       At this stage in the process, the metal surface is covered with a dark, rough layer
of oxidation  due to the high rolling temperatures in the presence of oxygen.  The oxide
layer is removed via a coil miller before further metal processing occurs at a cold rolling

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 mill. The coil miller uses a special knife that removes the outer layer of oxidation from
 the hot rolled coil. Normally, one pass through the milling machine is required to remove
 the layer of oxidation.  After passing through the coil miller, the coil surface is shiny
 because the oxide layer has been removed, and scalloped in texture from the milling
 machine. After leaving the coil miller, the coils are transported to the appropriate cold
 rolling mills.

       The main processes occurring at the cold mill facility  are rolling, annealing, and
 cleaning. Any given coil can cycle through the rolling/annealing/cleaning series one to
 four times before the metal is sent to the packaging and shipping department. In addition,
 the  coil may be cycled through the cold rolling step several times before annealing is
 required. In general, coils can  be rolled to around a 60 percent gauge reduction before
 annealing is necessary. For a given coil, the exact combination of rolling, annealing, and
 cleaning steps is a function of the desired product and of the equipment used.

        Olin's  East  Alton,IL facility contains approximately 15 operating  cold rolling
 mills, of which about 2/3 use an oil lubricant; the remainder use an oil-in-water emulsion.
 Lubricant is continuously applied,  by either spray or flood technique, to different parts
 of the rolling  mill while the copper coil is being rolled. The largest amount of oil (or
 emulsion) is sprayed at the roll bite  (or nip) for metal lubrication and cooling, but a
 portion of lubricant is also applied to the steel work rolls to cool them. A small amount
" of lubricant is added, via drip application, just before the take-up reel of the coil to
 prevent the wraps of the coil from scratching each other.   Mill operators control the
 application of the lubricant by means of numerous, hand-operated valves that regulate the
 flow of lubricant to each required  area and each section of the rolls.  According to Mr.
 Angeli, the proper application of lubricant to different parts of the rolls is essential to the
 production  of even, properly-sized  coils  without defects.   Sufficient training and
 experience is  necessary to ensure that the metal is produced as desired.

        After a coil is removed from  the cold mill, it is  taken  through the annealing
 process.    During  the  annealing process,  the  rolled  metal  is heated  above  its
 recrystallization temperature, reducing the internal stresses created during cold rolling.
 Also  during annealing, most of the lubricant on the coil is either vaporized or burned off.
 It has not been determined how much of the lubricant is driven off as vapor.  After the
 annealing process is complete, the metal is either sent to a mill for further cold rolling
 or directed to the packaging and shipping section for final production processes.

         At  Olin, annealing is accomplished in one of two manners; bell annealing or strip
 annealing.  In the bell annealing process, the rolled coil is placed in an enclosed chamber
 and heated for approximately 24 hours.  This annealing process is typically reserved for
 the final product when no  further cold rolling will occur.  During the strip annealing
 process, the metal strip is unwound and passes through an in-line alkaline cleaning tank
 to remove residual oil from the surface.  After passing through the annealing, cooling, and
 pickling portion of the strip annealing process, the metal is  recoiled.  At this point, the

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 annealed copper is either sent to another cold rolling mill or is sent to the shipping and
 packaging department.   The end-result of either annealing process is a nearly oil-free
 metal coil with improved ductility.
 E.     Lubricant Use. Recovery, and Recycling

        The lubricant recovery and filtration system at Olin is considered a "closed-loop"
 system. Lubricant is applied at the mill to the coil and work rolls and is recovered by
 sumps or mist collectors.  Mill overflow is captured below  the stand in a sump located
 in the "basement" of the facility.  Lubricant mist is captured by hoodsrwhich surround
 the roll stand, and routed to a mist collector where the oil is collected and returned to the
 sump.  Nearly all of the mills employ some type of mist collection device with flow rates
 ranging from 15,000 scfm to greater than 40,000 scfm.

        Each mill at the cold rolling plant has its own lubricant cleaning system, except
 for two, closely-located mills that share one device between them.  The lubricant cleaning
 system is designed to take the lubricant recovered from the  sump, clean out metal fines
 and other impurities,  and return the lubricant to  the mill for reuse.   Various cleaning
 systems are used for the different mills. The cleaning device at  some mills consists of
 a centrifugal separator (cyclone) located in series with a filter. For other mills, a paper
' and diatomaceous earth filter is used. Lubricant recycling system pumps can  operate at
 a maximum of approximately 250  gallons per minute.

        Some estimates of lubricant  oil losses have been made by Olin, the  results of
 which are discussed in the following paragraphs. Oil recovery at Olin was initially driven
 by economic incentives rather than environmental reasons. This is because the lubricant
 oil  used at Olin has a very low vapor  pressure and is  not considered a  VOC for
 permitting purposes by  the State of Illinois.  Olin has never conducted stack  tests to
 measure VOC emissions or vapor-phase emissions of their lubricant oil. Olin maintains
 an active lubricant loss reduction program and estimates that oil losses are generally very
 low.  However, when estimating losses, only carryout losses (oil on the coil after the coil
 leaves the mill) and losses through the mist eliminator were considered.  Mist or vapor
 losses to the plant atmosphere and liquid losses to the plant floor were not included.

        Olin provided lubricant  mass-flow diagrams for several of the oil and emulsion
 mills at the plant.  Calculations based on two of the oil mill flow diagrams indicate that
 hourly oil losses by carryout and through the mist eliminator are less than or  much less
 than 0.1 percent of the total oil used. These flow diagrams show that the greatest fraction
 of oil loss consists of oil carried out on the coil. Minimal losses are attributed to the mist
 eliminator because the  mass flow to the  mist eliminator is relatively small  and the
 removal efficiency of the mist eliminator is estimated to be in excess of 99 percent.

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       According to Olin, the mass flows given in the diagrams are estimates, and no
stack tests have been  conducted at the  mist eliminator exits.  Any total suspended
paniculate (TSP) calculations are made on the basis of mass balance going into the mist
eliminator and  assumed collection efficiencies.  Nearly all  of the  mills have capture
devices routed to some type of mist eliminator.  Different types of mist eliminators used
at the Olin mills include metallic wire meshes and canister-type filters.  They are designed
to remove suspended oil droplets from the exhaust stream.
F.     Observations at the Plant

       Alliance observed  a fine mist rising from the rolling area of many of the mills.
A much smaller amount of mist was seen rising from above the metal coils. A noticeable
cloud of mist was observed lingering at the ceiling level, approximately 70 ft above the
plant floor. Machinery surfaces in the  plant were  covered with a  fine  coating of oil,
presumably from the settling of  the oil mist  The floor  of the plant  was also oily,
presumably due to oil carryout on the coils and other drips or spills. Puddles located near
lubricant reclamation equipment and near mills were  confined or absorbed with absorbent
pillows or sausages.

       Within the cold rolling plant, there was a noticeable odor from the  lubricant vapor
'in the air. However, workers at the plant did not wear any respiratory equipment such
as masks or filters. According to the MSDSs, respiratory protection is not normally
required for the oil lubricant used in adequate ventilation at the mills.  An air purifying
respirator is recommended, but not required, for the oil-in-water lubricant used.
 G.    Emissions

       As mentioned previously, Olin does not estimate the amount of VOC emitted from
 their plant because the lubricants used for rolling are not considered VOCs by the State
 of Illinois.  Permits were available for several of the rolling mills, however, none of the
 permits contained VOC emission limits but most did estimate the amount  of particulate
 matter released to the atmosphere. For permitting purposes, the composition of particulate
 matter was assumed to be  100 percent mineral oil.

        Olin also reported that the facility's Form R does not include any emissions from
 the  rolling mills.  Emissions covered in Olin's Form R  are all from other areas of the
 plant.  According to Olin, the rolling  mills do  not release any SARA 313 substances.
 Also, Olin's NPDES permit makes no mention of VOC.

        Accordingly, with the  above assessment  that.VOCs are not released from Olin's
 East Alton,IL rolling mills, Olin has not attempted to install VOC control equipment at

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the plant. Therefore, no past VOC control experiences or cost data were available for
review.
H.     Maintenance

       The Olin rolling mills usually have an annual shutdown every July.  All mills are
cleaned, inspected, and repaired at this time.  Olin uses no solvents during the cleaning
process.  Other equipment  maintenance and cleaning is done on an as-needed basis.
General cleaning practices are utilized to remove lubricant and grime from the plant floor
and elsewhere.

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          ALLIANCE
          Technologies Corporation
Date:  May 18, 1992

Re:   Site Visit - Reynolds Metals Company:  Flexible Packaging Division, Richmond, VA
      Nonfenrous Metal Rolling
      EPA Contract 68-DO-0121; Work Assignment 1-30
      Alliance Reference No. 1638030
                          / i
From: W. Scott Snow  '>v- ^A.
      Alliance Technologies Corporation

To:   Joseph Myers
      OAQPS/ESD/ISB (MD-13)
      U.S. Environmental Protection Agency
      Research Triangle Park, NC 27711
I.      PURPOSE

             The purpose of this  visit was to gather background information  on the metal
       rolling process including information necessary to characterize the process parameters,
       VOC emissions, emissions control techniques,' and control costs.
 H.     PLACE AND DATE

       Reynolds Metals Company - Flexible Packaging Division
       7th & Bainbridge Streets
       Richmond, VA 23224
       (804) 281-5299

       February 19, 1992
 HI.    ATTENDEES

       Reynolds Metals Company (Reynolds)
       Kenneth W. Bourne, Plant Engineer, Richmond Foil Plant
       Kerry R. Dean, Plant Manager, Richmond Foil Plant
       Forest L. Keister, Jr., Environmental Coordinator, Richmond Foil Plant
      6320 Quadrangle Drive   Suite 100   Chapel Hill, North Carolina 27514  . (919) 493-2471
                                    A TX Company

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      Reynolds (continued)
      Tomas A. Loredo, Division Environmental Engineer
      Michael  F. Tanchuk, Manager, Air Quality and Technical Studies, Corporate
             Environmental Control

      U.S. Environmental Protection Agency (EPA)
      Al Vervaert, Chief, Standards Support Section
      Joseph Myers, Environmental Engineer
      Karen Bel], Environmental Engineer

      Alliance Technologies Corporation (Alliance)
      W. Scott Snow, Environmental Engineer
IV.    DISCUSSION
       A.    Summary

             Alliance and EPA's visit to the Richmond Foil Plant began around 10:15 a.m. with
       all attendees listed present   During the introductory meeting, Reynolds provided an
       overview of the plant operations, a RACT determination overview, and a general outline
       for the day's  agenda.  Alliance  and EPA reported on the current status of the Work
       Assignment and informed Reynolds of what information needed to be gathered during the
       visit.  Afterwards a general discussion was held in which questions were answered
       concerning confidential business information (CBI), health and safety procedures, and
       other areas of concern.  Alliance and EPA then toured the Richmond Foil Plant which
       contains three general areas of production: household foil, light-gauge foil for lamination
       and printing, and other consumer products.  After the tour was  complete, all those in
       attendance met for a last session to answer any final questions and  to layout the next
       steps.
       B.    Richmond Foil Plant Market Profile

             The Richmond Foil Plant is  a relatively large  facility in relation to others
       nationwide with approximately one million square feet of floor space and nearly 82,000
       metric tons of production in 1991. Products include household aluminum foil (Reynolds
       Wrap), light-gauge foil for lamination and printing, and other consumer products.  The
       household foil production capacity is large enough to  supply nearly all of the consumer
       demand on the East Coast for Reynolds Wrap.  Typical input rolls weigh around 32,000
       Ibs at the maximum widths available.  Light-gauge foil products are used in converter
       operations (lamination and printing) for packaging materials with an average input roll
       weighing between 26,000 and 27,000 Ibs in variable widths.  The consumer products area

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manufactures aluminum foil to consumer specifications that depend on the application,
therefore, a typical roll from this area will vary greatly in weight as well as width.
C.     Manufacturing Supplies

       Reynolds' Richmond Foil Plant uses two main types of raw materials in their
aluminum foil manufacturing process; they include coiled aluminum and rolling lubricant
(lubricant, coolant, and oil are  used interchangeably in this report).  Coiled  sheets of
aluminum manufactured at other Reynolds' facilities serve as the rolling mill input for foil
operations. These input coils are cycled through a series of breakdown, intermediate, and
finishing mills to obtain the final desired product A petroleum hydrocarbon oil (linear
paraffin) serves  as the lubricant and functions as both lubricant and coolant in all foil
rolling operations.  Previous  to  the RACT determination of 1987, Reynolds  had used
kerosene as the rolling lubricant.  Various proprietary additives are used with  the linear
paraffin oil, the specific properties of which depend on the application they are required
for. The total volume of additives is small, typically less than 10 percent of the total
lubricant volume.

       According to Reynolds' personnel, the physical properties of the linear paraffin
oil are as good or better than the kerosene lubricant that was used before 1987.  Vapor
pressure is lower and flash point is higher for the linear paraffin  oil.  These properties
have led to  reduced vapor generation and lower material costs  because more of the
lubricant can be captured  and recycled.  The lubricant is considered a VOC by EPA
regulations, however, it is somewhat less volatile than the kerosene previously used at the
foil plant  The installation of the lubricant reclamation system (see discussion in section
E of this trip report) employed by the Richmond Foil Plant was a major retrofit effort.
However, Reynolds believed the benefits associated with the reclamation system would
far exceed the costs. The benefits include nearly unlimited reuse of lubricant, reduced
waste oil generation, and lower  waste oil disposal costs.
 D.     Manufacturing Process Parameters

        The processes examined during the plant visit to Richmond,VA include various
 steps of cold  rolling aluminum sheet to produce foil  and converter  products.  Plant
 operations  examined include breakdown, intermediate, and finishing  mills as well as
 annealing ovens designed  to accomplish  the  goal  of  a  clean, unmarred foil surface
 product These operations  are discussed in this section.

        As discussed previously, there are three product areas of the Richmond Foil Plant
 that include household foil, light-gauge foil, and packaging products. The basic process
 flow in each production area is essentially the same, therefore, the discussion will focus
 on the household foil area and draw comparisons to the other areas.  The household foil

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area contains three cold rolling mills labeled the breakdown mill, intermediate mill, and
finishing mill. The light-gauge area contains one breakdown, one intermediate and two
finishing mills.   In the oldest mill section,  where various made-to-order foils are
produced, there are approximately nine mills, one of which being an intermediate mill the
rest finishing mills.  All of the mills are considered four-high single stand mills.

       The first step in foil production is the breakdown mill where the coiled aluminum
input is rolled an average of three times. Here, thick input gauges are reduced to a more
workable thickness.  Next, an average of two passes on the intermediate mill prepares the
coil for one final rolling to complete the finished product. One final pass on a finishing
mill is the last step in household foil production where two strips of intermittent foil are
combined and rolled together. The two layers exit the machine and are wound onto one
coil.  This two-layered rolling results in the household foil having a shiny side and a dull
side. A separator mill (no lubricant required) is then employed to separate the two layers
of foil onto two coils so they can be sent to an annealing oven for final anneal.

        Annealing usually occurs twice in the production of foil.  The first annealing
process is performed at the input aluminum coil stage, prior to the first rolling stage. The
second anneal is the finish anneal which occurs when all rolling stages  are complete.
During the annealing  process,  the rolled metal  is  heated above.its recrystallization
temperature, reducing internal stresses created during cold rolling. Also during annealing,
nearly all of the residual lubricant left on the coil is either vaporized or burned off.  It has
not been determined how much of the lubricant is driven off as vapor.  After the  finish
anneal and subsequent cooling of the coil, the coil is  directed to the packaging and
shipping section for final production processes. Annealing times may vary between 20
and 30 hours depending on the specific metal properties desired and at what stage the foil
is during production.

        Other rolling mill  areas at Reynolds follow the same  general processes as the
household foil.  After the input aluminum coil annealing, the coil is sent to an  initial
 breakdown mill. From there intermediate rolling passes are made on other mills.  Finally,
 the coil goes through a finishing pass and then to the finish anneal.  For a  given coil, the
 exact combination of rolling mills  and annealing parameters is a function of the desired
 product and equipment loading.   It was noted that none of the mills was reversible,
 therefore, each roll pass required re-setting of the mill input coil.

        During various rolling stages the linear paraffin oil is used to lubricate and cool
 the rolling  mill machinery and the aluminum itself.  The oil serves to reduce friction  at
 the roll nip and extract heat generated during the rolling process from both friction and
 internal stresses. The oil is also designed to cool  the steel work and back-up rolls  to
 prevent their deformation or buckling under the extreme loads. The lubricant flow rate
 per  mill depends  on several factors including mill speed,  gauge reduction,  lubricant
 temperature,  and  application technique.   The breakdown  and  intermediate  mills  at
 Reynolds were observed using a narrow stream of lubricant spray applied evenly across

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the roll nip.  On the finishing mill in the household foil area, lubricant was observed
gushing  out, via the flood technique, at a noticeably higher rate than that  for  the
breakdown or intermediate mills. Also, a small amount of lubricant was applied, via the
drip technique, between the layers of coil to prevent them from sticking to each other and
ease the separating operation.  Improving the application of the lubricant is an ongoing
activity; sufficient training  and experience is  necessary to ensure that the metal is
produced as desired.  In 1987, a RACT determination was performed at the foil plant
which determined the best applicable lubricant for VOC emissions reduction. This RACT
determination is discussed in the next section of this trip report
E.     RACT Determination

       Reynolds' selection of linear paraffin for rolling lubricant was derived from a
Reasonably Available Control Technology (RACT) demonstration performed in 1987.
Several emissions control and/or reduction options were examined and evaluated and the
results  concluded  that lubricant  changeover was the most  viable  option  for  their
operations.  The old lubricant consisted of a kerosene-based mixture which had long been
the standard in rolling operations. Other control techniques examined for RACT were oil
absorption and carbon adsorption. The conclusions and results for each control option are
discussed in this section.

        Currently, the add-on control devices at the Richmond Foil Plant consist  of mist
eliminators on every  mill or group of mills and one centrifugal impactor located on one
mill in the household  foil area. These devices were originally installed for opacity control
and are not designed for VOC vapor control.  The capture devices are  also not very
efficient especially on the  older mills (approximately  70 percent on  newer mills).
Airflows range from 6,000 to 40,000 acfm for the small  to large mills.  Mr. Tanchuk
 stated that for aluminum sheet mills, flow rates can range from 80,000 to 100,000 acfm.

        Oil absorption was considered as an applicable  emissions control technique.
 Multiple rolling plants overseas use this technology as  well  as one  plant in Canada,
 however, no plants in the United States currently employ an oil absorber for  emissions
 control.  Severe limitations exist in the areas  of retrofit (and retrofit cost), reuse  of
 lubricant oil after  absorption, and FDA requirements which render this technology not
 feasible.  An oil absorption  retrofit  system is very large  (some 60 feet tall) and heavy.
 Auxiliary equipment includes ductwork, hooding, and support structure.  Size  and space
 limitations were detrimental to oil absorption for the foil plant because the building was
 not erected with these retrofit expectations.  Another consideration involves the reuse of
 the waste lubricant oil after absorption.  The waste lubricant typically cannot be reused
 after the absorption process which would have resulted in a loss of income for Reynolds
 because the  kerosene lubricant could be re-sold after use as low-grade  fuel.  Also,
 absorption tends to  change the nature of the lubricant by reducing  the additives  and
 adding ,the step of product reformulation before reuse  as a  lubricant.  Finally, FDA

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requirements would have had to be met for the recycled oil.  For all these reasons oil
absorption was abandoned as a possible control option.

       Carbon adsorption was also considered for emissions control at the Richmond Foil
Plant, however, limitations were  found that included retrofit, retrofit cost, and low VOC
concentrations.   As stated  previously for  oil absorption  retrofit requires  ductwork,
hooding,  and support  structure  as well as  space and size examinations.  The major
impediment to adsorption is the low VOC concentration associated with rolling mill
emissions.  Large airflows  are required  to exhaust a majority of the  vapor and mist
associated with the emissions which reduces the VOC concentration.  Other disadvantages
to the adsorption process are the frequent carbon desorptions required and  the rapid
fouling that VOC mist may cause.  Only one unit is known to be installed on a new
rolling mill in the United States (i.e., no retrofit applications are known).  Problems have
been encountered with this system since its installment and do not appear as though they
will ever be corrected.  Therefore, carbon adsorption was also abandoned as a possible
control option.

       The final emissions  control technique is not truly considered control but more a
process change which results in source reduction. Lubricant substitution to a less volatile
compound can inherently reduce rolling mill emissions by increasing the heat capacity
and lowering the vapor pressure of the oil. Linear paraffin oil was the lubricant of choice
for  substitution  at Reynolds' Richmond  Foil Plant.   Factors  affecting the degree of
emissions reduction  via  lubricant  substitution include  lubricant temperature  and
 application rate. Advantages to  the linear paraffin  include equal or better foil product
quality,  FDA approval, less flammability, and lower  volatility.  Disadvantages are  the
requirements for recirculation system equipment and for research and development (R&D)
 on  the  new  oil.  Since the paraffin oil  cannot be re-sold  as  the  kerosene  could,
recirculation systems were designed to capture, filter, cool, and distill the linear paraffin
 so that  it could be reused. R&D  was required to reformulate the oil with additive
 packages to ensure the best product from each mill.

        From information gathered during the  study of all three control options, RACT
 was determined to be lubricant substitution from kerosene to a linear paraffin oil.   In
 1987, Reynolds had four new  filtration systems installed to  filter  and  cool  the oil  and
 recirculate it back to the rolling mills. Each system was designed to filter together mills
 which use the exact same lubricant composition. A distillation unit was also retrofitted
 to recover usable  oil from the  waste oil generated  in  the filtering system.  This oil
 recovery offsets some of the losses associated with lubricant substitution, namely income
 lost from the sale of used kerosene.  The linear paraffin cannot be re-sold as a waste fuel
 oil, thus oil recovery  is an economically feasible solution.  In addition, the distillation
 system  provides a longer lifetime for the lubricant and reduces off-site disposal costs
 associated with waste oil.

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       The installment costs for these reclamation systems was approximately $2,000,000
in 1985, not including R&D costs. The systems required the addition of collectors, filters,
cooling units,  oil tanks,  and a distillation unit as well as  the auxiliary equipment
associated with each. In  addition, other retrofit construction equipment (i.e.,  supports,
structure) was installed.
F.     Alliance and EPA Observations at the Richmond Foil Plant

       A fine mist was frequently observed rising from the rolling area of the household
foil mills.  A building ventilation system served to remove this  mist and vapor quite
adequately from the work area.  Machinery surfaces in the plant were covered with a fine
coating of oil, presumably from the settling of the oil mist The floor of the plant was
also oily, presumably due to oil carryout on the coils and other drips, splashes, or other
losses.

       Operating hours for the  foil plant are 24 hr/7 days per week (dpw) for household
foil operations and anywhere from 24 hr/5 dpw to 24 hr/7 dpw for other foil operations.
The fabricating and shipping  department is located  across  the  James River at the
Richmond North Plant

       Reynolds estimates that greater than 130 tons per year of lubricant oil is lost to
the oil filtration  system's filter media  and must be disposed of.  This  represents a
significant amount of oil that can be filtered, distilled, and reused. Also noteworthy, the
fact that at least one annealing oven employs an add-on thermal incinerator to destroy oil
vapor generated during the annealing process.
 G.     Emissions

        Reynolds  stated that  no estimates  are  available as to the  magnitude  of the
 reduction in VOC emitted since changeover to the linear paraffin oil.  Other studies have
 suggested  that as  much as 63  percent reduction  is  theoretically possible with  a
 combination  of reduced  lubricant application temperature and paraffin oil.  Reynolds
 stated that EPA Method 24 cannot be used since the oil is captured, filtered, and recycled.
 As stated previously, the foil plant do'es employ mist eliminators and  one centrifugal
 impactor, however, these devices are mainly for opacity reduction not VOC control.

        Accordingly, with the previous assessment of lubricant changeover as RACT for
 the Richmond Foil Plant, Reynolds has  not  been  required  to install  VOC  add-on
 equipment at the plant  Therefore,  no past VOC control experiences or cost data were
 available for review.

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H.     Maintenance

       Reynolds' Richmond Foil Plant has a preventative maintenance system to ensure
proper machine operation.  Other repairs  and/or general cleaning duties are  performed
during the year on an as needed basis.

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                                    TECHNICAL REPORT DATA
                            {Please read Instructions on the reverse before completing)
1. REPORT NO.
    453/R-92-001
                              2.
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
    CONTROL OF VOC EMISSIONS  FROM NONFERROUS METAL
    ROLLING PROCESSES
             5. REPORT DATE
              JUNE  1992
             6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
    W.  Scott  Snow, Philindo J.  Marsosudiro
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
    Alliance  Technolgies Corporation
    100 Europa Drive, Suite  150
    Chapel  Hill,  North Carolina  27514
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
              68-DO-0121,  WA# 1-30
12. SPONSORING AGENCY NAME AND ADDRESS
    U.S. Envirnomental Protection Agency (MD-13)
    Emissions  Standards Division
    Office  of  Air Quality Planning and Standards
    Research Traingle Park, North Carolina  27711
              13. TYPE OF REPORT AND PERIOD COVERED
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
    ESD Work Assignment Manager:   Joseph N. Myers,  MD-13, 919-541-5428
16. ABSTRACT
    This document was developed  in response to increasing inquiries  into the
    environmental impacts of nonferrous metal rolling which use oil  as  a
    lubricant  and coolant in rolling operations.   VOC emissions result
    from evaporative fugitive  losses caused by heat  generated in the rolling
    processes.   The focus of the document is VOC  emission control  techniques
    used by copper and aluminum  rolling mills.  A control cost anaylsis is also
    provided for each of the control techniques addressed.   The following control
    techniques are:

          Carbon Adsorption
          Absorption
          Incineration
          Lubricant Substitution
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS  C.  COS AT I Field/Group
    Air Pollution
    Aluminum Rolling Mills
    Carbon Adsorption
    Copper Rolling Mills
    Lubricant  Substitution
    VOC emission controls
18. DISTRIBUTION STATEMENT

    Release  unlimited
19. SECURITY CLASS (This Report)
                                                                          21. NO. OF PAGES
                               80
                                               20. SECURITY CLASS (This page)
                                                                          22. PRICE
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EPA Form 2220-1  (Rev. 4-77) (Reverse)

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