ISSUED TO: 

SITE LOCATION: 

FACILITY CONTACT: 

MAILING ADDRESS: 

SOURCE: 

April 24, 1996 

May 8, 1996 (correction to Order #) 

Kaiser Aluminum & Chemical Corporation 

Trentwood Works 

15000 E Euclid Avenue 

Spokane, Wa 

Pat Blau 

(509) 927-6350 

PO Box 15108 

Spokane, Wa 99215-5108 

Skim Cooler, RM-20 

Secondary Aluminum Production Facility 

Kaiser Aluminum & Chemical 

secondary aluminum production 

Spokane, Wa. 

Corporation (Kaiser) operates a 

facility at 15000 E. Euclid Avenue, 

Kaiser's skim cooler has the potential to emit about 22 tons of 

particulate matter (PM) per year as calculated assuming maximum 

allowable emissions of 0.025 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 

skim cooler. 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 

PMlO emissions from the skim cooler 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 skim cooler's potential to 

emit. 

Source testing at the facility has shown that PM emissions are 

below 0:01 grains per dry standard cubic foot, corresponding to 

50.0 pounds of PM emitted per day. 

Kaiser's request has been reviewed 

potential to emit limitation shall 

required in D. below: 

by 

be 

SCAPCA. 

met by 

The following 

the facility as 

1. PMlO emissions from the skilo. cooler shall not exceed 50.0 pounds 

per day. 

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

meet the following: 

A. SCAPCA may require testing to verify compliance with the 50.0 

pounds per day PMlO emission limit. Testing shall be done in 

accordance with EPA reference methods as found in 40 CFR Part 51 

(1995). PM emissions shall be determined from the average of three 

valid 1-hour, or longer, test runs. 

PMlO 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 PMlO emissions. 

B. An operation and maintenance plan for the skim cooler baghouse 

shall be developed and submitted to SCAPCA for approval within 30 

days of the effective date of this order. 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. 

C. 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. 

D. This order shall take effect upon EPA approval of SCAPCA Order 

91-01 as part of the Washington State Implementation Plan. 

Ko..i•or Vol.untuy Emi.ss:<on Limit 

Sk:Ltn Cool.e" 

SCAPCA Ordo.x #96-04 

!>&!:<> Hsued: Aprll 24, 1995 

nat" Mo<ii:Ei•c:l: Mlly a, ngs 

P&q., 2 
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 

comply with all other applicable federal, 

regulations and requirements. 

the obligation to 

state and local 

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 

PO Box 40903 

4224 6th Avenue SE, Building nz, Rowe Six 

Lacey, Wa 98504-0903 

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: 

DIRECTOR 

~ser Vo~unt&Iy Emiss~on L~t 

!lltim Coolar 

BcaFCA ara.r fS5-n4 

D~te l~su.d: Apr1l 24, 1996 

Da.te Modi:!!"-<>d' ""'Y a, 1995 

·~'