### SCAPCA ORDER ISSUED INACG061)ANCE WJTH :



### · RCW 70.94.141 •. RCW

## 70.94~170ANO,.SCAPCA REGULA

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## 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,;,

FACILITYCONTACT,;,

MAILINGADDRESS.;.

SOURCE: April 24, 1996 May 8, 1996 (correctionto Order #) October 4, 2000 (Addition of Startup/Shutdown Opacity Limit 

### & AdditionofConditionG) KaiserAluminum 

### & Chemical Corporation TrentwoodWorks 15000E 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 SecondaryAluminum Production Facility

Kaiser Aluminum & Chemical Corporation (Kaiser) operates a secondary aluminum productionfacility at 15000 E. Euclid Avenue, Spokane, WA. Kaiser's remelt holders and SNIF unitsthat 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'sassumed emissions for this modeling exercise were higher than actual emissions but much lower than the potential to emit. In an effortto maintain the validity of the SIP attainment demonstration, Kaiser has voluntarily requested that PM10 emissions from the remelt holders be limitedto a level such that Kaiser's potentialto 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/baghousesystem 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 furhterassurancethat facilty-widePM10 emissions are belowthe level used in the SIP modeling. The request has been reviewed by SCAPCA. The following potentialto emit limitation shall be met bythefacilityas 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 ensurethatthe above emission limit is met, the facilityshall meetthe following: A. Emissions from the 8 remelt holders and vented SNIF units listed in 1 . above shall 

### be controlled usingthe dry scrubbing/baghousesystem. B. Except during periods of startup and shutdown, visible emiSSions from the dry scrubbing/baghousesystem, 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 opacitymonitordata shall be collected in accordancewith 40 CFR 60.13 (1995) exceptthat 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-minuteaverage).

Kaiser Voluntary Emission Limit Remelt Holders SCAPCA Order #96-05 Date Issued: April 24, 1996 Date Modified: May 8, 1996 Date Modified: October4, 2000 Page 2C. 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 10 emissions shall be determined from the average of three valid 1-hour, or longer, test runs and shall include front and back half particulatematter. PM10 emissionsshall 

### be assumed to equal PM emissions unless Kaiser provides appropriate technicaldocumentationto demonstrateotherwise. Upon submittal of such documentation, SCAPCA may revisethe methodfordeterminingPM10 emissions. D. An operation and maintenance plan for the dry scrubbing/baghousecontrol system shall be developed and submittedto SCAPCA for approval within 30 days of start-up of the dry scrubbing/baghousesystem. The plan shall include, at a minimum:

• routine maintenanceactivities, required to keep the control system in proper operating condition, including manufacturer recommended operation and maintenanceprocedures

· a description of recordkeeping activities, including those records being kept, method(s) of recordkeeping, and length oftimethat records are kept. E. Maintenancerecords shall be kept forthe baghouse. Compliancewith this conditionmay be demonstrated by implementing a computerized preventative maintenance system that regularly schedules and tracks maintenance activities. All records shall be kept for a minimumoftwoyears. F. This ordershall take effectafter: i) October31, 1996; and ii) EPA approval of SCAPCA Order 91-01 as part of the Washington State ImplementationPlan. 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 173-400-112and WAC 173-400- 113. Any such approval, issued under SCAPCA's new source review program, shall include new daily allowable emissions levels which supersedethe levels establishedin this order. Any proposed deviationfrom this order shall require revision or revocationofthis order. The revision or revocationshall occur priortothe deviation. This order does not relieve the proponent of the obligation to comply with all other applicablefederal, state and local regulationsand requirements.

Kaiser Voluntary Emission limit Remelt Holders SCAPCA Order #96-05 Date Issued: April 24. 1996 Date Modified: May 8, 1996 Date Modified: October4, 2000 Page 3The provisions of this authorization are severable and, if any provision of this order, or the applicationof any provisionofthis order to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this order shall not be affectedthereby. This order may be appealedto Pollution Control Hearings Board c/o EnvironmentalHearingsOffice P.O. Box 40903 42246th Avenue SE, Building #2, Rowe Six Lacey, WA 98504-0903 Appeals must be filed within 30 days after receipt of this order. Concurrentlya 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: October4, 2000 Page 4