SCAPCA ORDER 

ISSUED IN ACG061)ANCE WJTH : 

· RCW 70.94.141 •. RCW 70.94~170 ANO,.SCAPCA REGULA TIQN I,~~CTtON 2.0~, 2.02, AND 2.06 

ORDER #96-05 

ORDER TO ESTABLISH VOLUNTARY EMISSIONS LIMITS FOR KAISER ALUMINUM &_ 

CHEMICAL CORPORATION'S REMELT HOLDERS & VENTED SNIF UNITS PURSUANT TO_ 

WAC 173-400-091 

DATE: 

DATE MODIFIED,;, 

DATE MODIFIED,;, 

ISSUED TO: 

SITE LOCATION,;, 

FACILITY CONTACT,;, 

MAILING ADDRESS.;. 

SOURCE: 

April 24, 1996 

May 8, 1996 (correction to Order #) 

October 4, 2000 (Addition of Startup/Shutdown Opacity Limit 

& Addition of Condition G) 

Kaiser Aluminum & Chemical Corporation 

Trentwood Works 

15000 E Euclid Avenue 

Spokane, WA 

Pat Blau 

(509)927-6350 

P.O. Box 15108 

Spokane, WA 99215-5108 

Remelt Holders: RMCH)-1, RMCH)-2, RMCH)-3, RM(H)-4, RM(H)-

5, RM(H)-6, RM(H)-7, RM(H)-8 

Vented SNIF Units 

Secondary Aluminum Production Facility 

Kaiser Aluminum & Chemical Corporation (Kaiser) operates a secondary aluminum 

production facility at 15000 E. Euclid Avenue, Spokane, WA. 

Kaiser's remelt holders and SNIF units that are vented to the dry scrubbing baghouse system 

(i.e., vented SNIF units) have the potential to emit over 200 tons of particulate matter (PM) 

per year as calculated assuming maximum allowable emissions of 0.1 grains per dry 

standard cubic foot. As part of the attainment demonstration in the State Implementation 

Plan (SIP), emissions were modeled, including those from Kaiser's remelt holders. Kaiser's 
assumed emissions for this modeling exercise were higher than actual emissions but much 

lower than the potential to emit. In an effort to maintain the validity of the SIP attainment 

demonstration, Kaiser has voluntarily requested that PM1 0 emissions from the remelt 

holders be limited to a level such that Kaiser's potential to emit will be equal to or less than 

the levels used for the SIP modeling. As allowed in WAC 173-400-091, Kaiser has 

requested, in Raymond J. Milchovich's letter, dated August 8, 1995, voluntary emission 

limits on the remelt holders' potential to emit. Revisions to this order have been made as 

requested in Patrick Blau's letter, dated March 10, 1999. 

A dry scrubbing/bag house system has been designed and installed to control the emissions 

from the remelt holders and vented SNIF units. Emissions from the dry scrubbing/baghouse 

system will not exceed 0.015 grains per dry standard cubic foot as required in Notice of 

Construction #660. Although the grainloading standard of 0.015 corresponds to 215 

pounds of PM emitted per day, this order will limit emissions to 83 pounds per day, 

providing furhter assurance that facilty-wide PM 1 0 emissions are below the level used in the 

SIP modeling. 

The request has been reviewed by SCAPCA. The following potential to emit limitation shall 

be met by the facility as required in F. below: 

1. Total PM10 emissions from the 8 remelt holders; RM(H)-1, RM(H)-2, RM(H)-3, RM(H)-4, 

RM(H)-5, RM(H)-6, RM(H)-7, RM(H)-8 and vented SNIF units shall not exceed 83.0 pounds 

per day. 

To ensure that the above emission limit is met, the facility shall meet the following: 

A. Emissions from the 8 remelt holders and vented SNIF units listed in 1 . above shall be 

controlled using the dry scrubbing/baghousesystem. 

B. Except during periods of startup and shutdown, visible emiSSions from the dry 

scrubbing/baghouse system, as measured using EPA Method 9, except that a three minute 

average shall be calculated instead of a six-minute average, shall not exceed 10% (threeminute average). Visible emissions from the dry scrubbing/baghotjsesystem, as determined 

by the continuous opacity monitor, shall not exceed 10% (three-minute average). The 

opacity monitor data shall be collected in accordance with 40 CFR 60.13 (1995) except that 

one cycle of data recording shall be a three minute average and each three minute average 

shall be calculated from 18 or more datapoints, equally spaced over each three minute 

period. 

During periods of startup and shutdown, visible emissions from the dry scrubbing/baghouse 

system, as measured using EPA Method 9 (except that a three-minute average shall be 

calculated instead of a six-minute average) or the continuous opacity monitor, shall not 

exceed 20% (three-minute average). 

Kaiser Voluntary Emission Limit 

Remelt Holders 

SCAPCA Order #96-05 

Date Issued: April 24, 1996 

Date Modified: May 8, 1996 

Date Modified: October 4, 2000 

Page 2 
C. SCAPCA may require testing to verify compliance with the emission limit in Condition 1 

. of this order. Testing shall be done in accordance with EPA reference methods as found in 

40 CFR Parts 51 and/or 60 ( 1995). PM and/or PM 1 0 emissions shall be determined from 

the average of three valid 1-hour, or longer, test runs and shall include front and back half 

particulate matter. 

PM 1 0 emissions shall be assumed to equal PM emissions unless Kaiser provides appropriate 

technical documentation to demonstrate otherwise. Upon submittal of such documentation, 

SCAPCA may revise the method for determining PM 1 0 emissions. 

D. An operation and maintenance plan for the dry scrubbing/bag house control system shall 

be developed and submitted to SCAPCA for approval within 30 days of start-up of the dry 

scrubbing/baghousesystem. The plan shall include, at a minimum: 

• routine maintenance activities, required to keep the control system in proper 

operating condition, including manufacturer recommended operation and 

maintenance procedures 

· a description of recordkeeping activities, including those records being kept, 

method(s) of recordkeeping, and length of time that records are kept. 

E. Maintenance records shall be kept for the baghouse. Compliance with this condition may 

be demonstrated by implementing a computerized preventative maintenance system that 

regularly schedules and tracks maintenance activities. All records shall be kept for a 

minimum of two years. 

F. This order shall take effect after: 

i) October 31, 1996; and 

ii) EPA approval of SCAPCA Order 91-01 as part of the Washington State 

Implementation Plan. 

G. Daily allowable emissions from the dry scrubbing baghouse system may be increased 

above the levels allowed in this order if such increases are approved under SCAPCA's new 

source review program as being in compliance with WAC 173-400-112 and WAC 173-400-

113. Any such approval, issued under SCAPCA's new source review program, shall include 

new daily allowable emissions levels which supersede the levels established in this order. 

Any proposed deviation from this order shall require revision or revocation of this order. The 

revision or revocation shall occur prior to the deviation. 

This order does not relieve the proponent of the obligation to comply with all other 

applicable federal, state and local regulations and requirements. 

Kaiser Voluntary Emission limit 

Remelt Holders 

SCAPCA Order #96-05 

Date Issued: April 24. 1996 

Date Modified: May 8, 1996 

Date Modified: October 4, 2000 

Page 3 
The provisions of this authorization are severable and, if any provision of this order, or the 

application of any provision of this order to any circumstance, is held invalid, the application 

of such provision to other circumstances, and the remainder of this order shall not be 

affected thereby. 

This order may be appealed to 

Pollution Control Hearings Board 

c/o Environmental Hearings Office 

P.O. Box 40903 

4224 6th Avenue SE, Building #2, Rowe Six 

Lacey, WA 98504-090 3 

Appeals must be filed within 30 days after receipt of this order. Concurrently a copy of the 

appeal must be sent to the Spokane County Air Pollution Control Authority, West 1101 

College Avenue, Room 403, Spokane, WA 99201. 

ORDERED BY: 

~tfl~ 

ERIC P. SKELTON 

DIRECTOR 

Kaiser Voluntary Emission Limit 

Remelt Holders 

SCAPCA Order #96-05 

Date Issued: April 24, 1996 

Date Modified: May 8, 1996 

Date Modified: October 4, 2000 

Page 4