Final December 201 0 

STAH OF WASI-IINGTON 

DEPARTMENT OF ECOLOGY 

PO lJox 47600 o Olympia, WA 911504-760() o 3MJ-,W7-GOOO 

711 fur Wasllinglou /lelify Service o Persons with ,, speech clis,,bi/ity c,m ca/11177-1133-63·11 

November 9, 2010 

Mr. BatTy Hullett 

Alcoa In talco Works 

4050 Mountain View Road 

Ferndale, WA 98248-0937 

Dear Mr. Hullett: 

Regionnl Haze Best Avnilnble Retrofit Technology (BART) Detcrrnination 

Best Available Retrofit Technology (BART) is required to reduce the regional haze hnpacts of 

emissions of your facility. The enclosed Order #7837, Revision 1, contains our BART 

determination for your facility including a schedule for compliance. 

This revision is in response to a request by the company to repeat the emission limitation, 

monitoring, recordkeeping, and reporting requirements contained in Order No. DE02AQIS-3967 

rather than incorporating them by reference. 

If you have questions or requests relating to this order, please contact Alan Newman at 

(360) 407-6810 or alan.ne\vman@ecy.wa.gov. 

Sincerely, 

Jeff 

~bb Johnston, Ph.D. 

Manager, Science and Engineering Section 

Air Quality Program 

JJ/lb 

Enclosure 

cc: Kathym Mitchell, Intalco Ferndale 

Alan Newman, Ecology 

Rick Graw, USFS Portland 

James Jones, EHS Services North America 

Judy Schwieters, Industrial Section 

John Bunyak, National Park Service 
_ STATEOFWASI-lTNGTON . 

DEPARTMENT OF ECOLOGY 

Final December 2010 

IN EMATTEROFAN ] 

ADM STRA TIV~ ORDER AGAINST: ] 

] 

] 

---------T------------------] 

TO: Mr. Barry 

Alcoa Intalco orks 

4050 Mountain 'ew Road 

Ferndale, WA 982 -0937 

This is an Administrative Orde equiring your company comply with WAC 173-400~ 151 by 

taking the actions that are describ below. Chapter 70 4 RCW authorizes the Washington 

State Department of Ecology's Air ality Progran1 cology) to issue Administrative Orders to 

require compliance ~th the requireme is of Chapt 70.94 RCW and regulations issued to 

itnplement it. · 

Ecology has determined that portions of you cility are subject to the provisions of the federal 

and state visibility protection program (W C 1 -400-151 and 40 CFR Part 51, Subpart P)~ The 

rules require that the State determine w t techno I ies and level of emission control constitutes 

Best Available Retrofit Techilology ( T) for the · gible emission units at your facility. 

FINDINGS 

A. elter facility subject to BART. 

B. The BART-eligible e ission units at Intalco are the three potlin , anode bake furnace, 13 

aluminum holding aces, material handling and trru~~fer operatl s, and a number ofsmall 

miscellaneous . 

C. Emissions fr m existing BART units are· controlled by: 

a. Use six existing primary control systems each consisting of a dry almnin injection 

sy em follow~d by a baghouse for the prin1ary control of PM and fluoride em· sions from 

e potline buildings . 

. Use of a series of 159 wet roof scrubbers to control secondary PM and fluoride ernlss 

from the potline buildings. 

c. Use of a dry alwnina injection syste1n followed by a baghouse for control of PM and 

fluoride emissions from the Anode Bake Furnace. 

L- 89 
Alcoa In talco Works 

BART Compliance Order #783 7, Revision 1 

J ly 7, 2010 

f sulfur content limitations to limit so2 emissions due to th 

tion of anodes. 

Final December 201 0 

Page 2 of4 

e. Use of baghou s and fabric filters to control PM en1is · ns fr01n various Material 

Handling and Trm er Operations throughout the f ity. 

D. Ecology has determined that 

requirements of BART. 

currently installed at Intalco meet the 

E. 

F. On July 29,2010 Intalco re ested the original BA 

a. Incorporate the speci emission limitations, tnonito · g and reporting requirements 

contained in Orde E02AQIS-3967 rather than incorpo e that order and its 

requirements reterence as done in the original version of · s order, and 

ecific NOx emission rates, especially a revised N . emission rate for the 

used on recent source test information. 

Additio I information and analysis is available in the BART Determination Supp Document 

for coa lntalco Works, Ferndale, Washington, prepared by the Washington State De ment 

~cology, and the BART Determination for Alcoa Intalco Works Ferndale, Washington, 

prepared by ENVIRON Corporatioh on behalf of Alcoa Intalco Works, November 2007. 

YOU ARE ORDERED: To operate existing emission control equipment in accordance with the 

following conditions: 

1. BART Emission Litnitations are contained in the tables contained in Attaclunent A to this 

Order. 

2. Schedule for Compliance 

2.1. Compliance with the emissionlin1itations for particulate n1atter, nitrogen oxides, and 

sulfur dioxide is required upon the effective date of this Order. 

3. Monitoring and Rccordkeeping, Requirements are contained in Attachn1ent A to this Order 

4. Recordkeeping Requirements 

L- 90 
Alcoa In talco Works 

BART Compliance Order #7837, Revision 1 

July7,2010 

Final December 2010 

Page 3 of4 

4.1. Intalco shall submit a monthly air monitoring report which contains the respective 

results of the monitoring required in the conditions of this order. The report shall be 

submitted within 30 days of the end of each calendar month. In talco shall report the data 

in a format that will allow a comparison of all the data to the respective emission limits. 

The fonnat shall include a table which summarizes the required source tests conducted 

during that tnonth and the dates when they were completed. Intalco shall submit the 

results of source tests to Ecology in the air monitoring report tor the month that the 

results are received by Intalco. This reporting requirement applies to all Conditions in 

Attachment A of this Order. 

·ailure to comply with this Order may result in the issuance of civil penalties or other acf 

wfi 1er administrative or judicial, to enforce the tem1s of this Order. 

ight to appeal this Order. To appeal you must: 

• File your a eal with the Pollution Control Hearing Board with' 30 days of the "date of 

receipt" ofthi ocument. Filing means actual receipt by th oard during regular office 

hours. 

• Serve your appeal on the mtment of Ecology 1thin 30 days of the "date of receipt" 

of this document. Service rna be accomplis by any of the procedures identified in 

WAC 371-08-305(10). "Date o · eipt" · defined at RCW 43.218.001(2). 

If you appeal, you must: 

• Include a copy of this docu ent with your Notic f Appeal. 

• Serve and file your apR ~ in paper form; electronic 

e Pollution Control Hearing Board: 

The P ution Control Hearings Board 

P .. Box 40903 OR 

lympia, W A 98504-0903 

The Pollution Control Hearing 

4224-6th A venue SE Rowe Six, 

Lacey, W A 98503 

To serve your appeal on the Department of Ecology: 

·l- 91 
Alcoa Intalco Works 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Depart nt of Ecology 

Appeals C rdinator 

P.O. Box47 

Olympia, WA 9 04-7608 

And send a copy of you 

Alan Newman 

Department of Ecology 

Air Quality Progran1 

P.O. Box 47600 

Olympia, W A 98504-7600 

For additional infonnation, go to the Enviro 

http://www.eho.wa.gov. 

OR 

Final December 2010 

Page 4 of4 

Deliver your appeal in person to· 

Department of Ecology 

Appeals Coordinator 

300 Desmond Drive 

Lacey, WA 98503 

e Legislator website at 

Your appeal alone will not st the effectiveness of this Order. ay requests must be submitted 

in accordance with RCW 4 .21 B.320. These procedures are consi nt with 

Chapter 43.218 RCW. 

y of Nove~r, 20 1'0 at Olyn1pia, Washington. 

Ma ger, Science and Engineering Section 

partment of Ecology 

Air Quality Program 

L- 92 
r-

. 

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w 

Attachment A 

BART Emission limitations, Monitoring, Recordkeeping and Reporting Requirements 

Approval Process Area Pollutant Emission limit l\1onitoring and Recordkeeping 

Condition requirements 

Plant Wide Limitations 

AI Plantwide Natural Nitrogen oxides 341 lb/day, calendar Intalco shall demonstrate compliance by 

gas Usage (not (NOx month average using the following equation: 

including Bake 

furnace) Natural gas NOx from sources excluding 

the Bake Ovens and the Remelt Furnace = Plant wide natural gas - bake oven natural 

gas - remelt natural gas 

In talco shall maintain a record of natural 

# gas usage at the plant. Records maintained 

shall be sufficiently complete to quantify 

natural gas used in the bake furnace and 

remelt furnace. 

Natural gas usage shall be converted to a 

calendar month average NOx emission rate 

through the use of an Ecology specified 

emission factor of 140 lb/I.Ox 1 06

scf of 

natural gas. 

A2 Plantw.ide so2 Sulfur dioxide Comply with the emission a. Intalco shall conduct source tests upon 

Emissions (S02) limitation contained in Ecology's request using EPA RM 6 per40 

WAC 173-415-030(5); CFR Part 60, Appendix A, or another EPA 

Total emissions of S02 approved method. 

from all emissions units b. Intalco shall determine total facilityshall not exceed thirty wide S02 emissions by summing the S02 

grams of sulfur dioxide genez:ated from the potlines, the anode 

per kilogram of aluminum bake ~lVens and natural gas usage. lntalco 

produced on a shall calculate S02 emissions from the 

monthly average (sixty potlines, anode bake ovens, and paste plant 

pounds per ton of by using the following mass balance 

aluminum produced). equations and information: 

Reporting requirements 

30 days after the end of each 

calendar month 

30 days after the end of each 

calendar month or, for source 

tests, 30 days after the end of 

the month the source test 

report is received by Jntalco 

---·--·---------·----<--------
r 

Alcoa lntalco Works 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

Miscellaneous Materials Handling 

systems 

A3 Unspecified PM 

emission units 

Emission limit 

Meet the more restrictive 

applicable emission. 

limitation contained in 

• WAC 173-400-060, 

or 

• WAC 173-415-

Page2 of4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

Total S02 =Raw Material S02 

(Coke and Pitch) +Natural Gas 

so2 

Raw material so2 (coke and 

pitch) will be determined by 

using the following mass balance 

equation: 

Coke and Pitch S02 = (total Pet 

coke weight %S) + (total pitch 

weight %S) + (total packing coke 

weight %S)- (COS x 64/60) 

Carbon consumption ratio is pounds of 

carbon consumed per pounds of Aluminum 

produced. 

Intalco shall assume 95% of the sulfur in 

green anodes is converted to so2 and 5% 

is converted to COS (Carbonyl Sulfide). 

Intalco shall calculate the so2 generated 

by natural gas combustion using an 

Ecology approved emission factor. 

Intalco shall conduct source tests upon 30 days after the end of the 

Ecology's request using EPA RM 5 per40 month the source test report 

CFR 60, Appendix A, The test m~thod is received by Intalco. 

required to demonstrate compliance with 

an applicable particulate matter control 

requirement of 40 CFR Part 63 Subpart 
I 

Alcoa In talco Works 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

A4 Autogenous Mill PM 

-Unit #209 

Aluminum Production 

A5 Aluminum 

Production Limit 

A6 Potline Primary Operational 

and Secondary limits 

Control Systems 

Emission limit 

030(2), or 

• 40 CFR Part 63, 

Subpart RRR 

Emissions of PM shall not 

exceed 5.0 tons of PM per 

year 

AND 

Emissions of PM shall not 

exceed 0.01 grains per 

dscf. 

Net potline production of 

Aluminum shall be 

l~mited to ~307,000 tons 

of aluminum per calendar 

year. 

The following limits shall 

not be exceeded : 

Operating < 720 pots/day 

S 3 .0 % sulfur in coke 

S 0.6% sulfur in pitch 

:S 150,000 amps of current 

S 0.4250 carbon 

consumption ratio 

(pounds of carbon 

consumed per pound of 

Aluminum produced) 

Page 3 of4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

RRR, or another EPA approved method. 

Intalco shall conduct source tests once 30 days after the end of the 

every 5 years and upon Ecology's request month the source test report 

using EPA RM 5 per 40 CFR 60, is received by Intalco. 

Appendix A, or another EPA approved 

method. 

In talco shall maintain a record of the daily 30 days after the end of each 

net production of aluminum and report the calendar month 

average daily net aluminum production in 

the monthly air monitoring. 

Net production of aluminum is the total 

mass of molten metal produced from 

tapping all pots in all operating potlines, 

measured at the casthouse scales and the 

rod shop scales 

In talco shall maintain a record of the data 30 days after the end of each 

co1lected for the parameters listed below, calendar month 

compute the monthly average, and report 

the monthly average (unless another 

average is noted below) for each parameter 

in the monthly air monitoring report 

submitted to Ecology: 

• Number of pots operated per day 

(potdays) 

• Percent sulfur in pitch (Intalco shall 
· Alcoa Intalco \Vorks 

BART Compliance Order #7837, Revision I 

July 7, 2010 

Approval Process Area Pollutant 

·condition 

I 

A7 Particulate (PM) 

Emission limit 

Emissions of PM shall not 

exceed a combined total 

of 5050 pounds per day 

(calculated on a monthly 

average) from the potlines 

(primary and secondary 

control systems) and the 

bake ovens 

AND 

Emissions of PM shall not 

exceed a combined total 

of 6.0 pounds per ton of 

aluminum (calculated on 

a three month average) 

produced from the 

potlines (primary and 

secondary control 

systems) and the bake 

ovens 

Page 4 of4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

analyze each incoming load or batch 

of pitch for sulfur content using the 

proce4ures in ASTM D4239 or other 

ASTM sulfur methods) 

• Percent sulfur in coke (Intalco sha11 

analyze each incoming load or batch 

of coke for sulfur content using the 

procedures in ASTM D4239 or other 

ASTM sulfur methods) 

• Carb~n consumption ratio as a daily 

average computed monthly 

• Amperes of current 

Unless a different testing schedule is 30 days after the end of each 

contained in an Ecology approved Air calendar month I 

Monitoring Plan, Intalco shall.determine 

PM emissions by testing the primary and 

secondary control systems and the bake 

furnace using the following methodology: 

Primary control system: Intalco shall test 4 

cells (J run/cell) per month per potline (2 

cells from each ofthe 2 baghouse centers) 

for a minimum of 5 hours using EPA RM 

5 per 40 CFR Part 60 Appendix A, Alcoa 

method B-54, or another EPA approved 

method. 

Secondary control system: lntalco shall 

test three roof scrubbers simultaneously (I 

run/test) three times per month per potline 

using EPA RM 5 per 40 CFR Part 60 

Appendix A, Alcoa method B-54b, or 
Alcoa Intalco Works 

BART Compliance Order #783 7, Revision I 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

A8 Sulfur dioxide 

(S02) 

Emission limit 

Emissions of S02 shan 

not exceed 37, 780 

pounds per day 

Page 5 of4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

another EPA approved method. 

Bake Ovens: lntalco shall conduct a source 

test (3 runs/source test) once per year and 

upon Ecology's request using EPA RM 5 

per 40 CFR Part 60 Appendix A 

Intalco shall determine the so2 emitted Intalco shan report the 

by using the following formula: 3monthly average of pounds 

so2 emissions in lbs. /day = of so2 per day in each month 

.3 0 days after the end of each 

(carbon consumption ratio) calendar month 

(2000 pounds Aluminum per 

ton) x (% sulfur in baked 

anodes/ I 00) x (% S 

converted to S0211 00) x (2 

lb sulfur dioxide per lb 

sulfur)x (Tons of Aluminum 

per month)/ days per month. 

Carbon consumption ratio is pounds of 

carbon consumed per poW1d of Aluminum. 

Percent sulfur in baked anode material 

(Jntalco shall analyze baked anode material 

for sulfur content using the procedures in 

ASTM D4239 or other ASTM sulfur 

methods). 

%S converted to S02 is 95% 

Intalco shall report the monthly average of 

pounds ofS02 per day. 

Intalco shall maintain records ·of 
r 

I 

<0 

(X) 

Alcoa Intalco Works 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

A9 Sulfur dioxide 

(S02

) 

AIO Nitrogen oxides 

(NOx) 

Emission limit 

Emissions of S02 shall 

not exceed 44.8 pounds 

per ton of aluminum 

produced (calculated on a 

three month average). 

Emissions ofNOx shall 

not exceed 219 pounds 

per day (calculated on a 

one month average). 

Page 6 of 4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

production data used to develop carbon 

consumption ratio and tons of aluminum 

produced. Intalco shall provide the records 

to Ecology upon request 

Intalco shall determine the S02 lntalco shall report the 3 

emitted by using the following month average of pounds of 

fonnula: so2 per ton of aluminum 

so2 emissions in Jbs. /month = produced 30 days after the 

end of each calendar month 

(carbon consumption ratio) 

(2000 pounds Aluminum per 

ton) x (% sulfur in baked 

anodes/1 00) * (% S converted to 

S02/1 00) x (2 lb sulfur dioxide 

per lb sulfur)x(Tons of 

Aluminum per month) 

Carbon consumption ratio is 

pounds of carbon consumed per 

pound of Aluminum. 

Percent sulfur in baked anode material 

(Intalco shall analyze baked anode material 

for sulfur content using the procedures in 

ASTM 04239 or other ASTM sulfur 

methods) .. 

%S converted to S02 is 95% 

Intalco shall determine plant wide 30 days after the end of each 

emissions ofNOx by using the plant calendar month 

specific emission factor ofD.26 lb NOx/ton 

of Aluminum produced. 
r 

I 

co 

co 

Alcoa Intalco \Vorks 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

Anode Production and Baking 

All Green Carbon PMJO 

Pitch Fume 

Treatment System 

Al2 Anode Baking Nitrogen oxides 

(NOx) 

Emission limit 

Emissions of PM 1 0 shall 

riot exceed 2.36 lb/hour 

933 lb/calendar day, 30 

day average 

Page 7 of4 

Monitoring and Record keeping Reporting requirements 

requirements 

lntalco shall conduct a source test once 30 days after the end of the 

every two years and upon Ecology's month the source test report 

request using EPA RM 5 per 40 CFR Part is received by Intalco. 

60, Appendix A, or another EPA approved 

method. 

Intalco can reduce monitoring frequencies 

if each of three consecutive source tests 

demonstrates that the emission rate is< 

75% of the applicable limit. lntalco shall 

resume the original source testing 

frequency any time a source test 

demonstrates emissions have increased 

above 75% of the applicable limit. Intalco 

shall submit a letter notifying Ecology that 

the monitoring frequency will be reduced. 

The notification shall demonstrate the 

justification for the reduced monitoring 

frequencv and schedule. 

lntalco shall determine N Ox 30 days after the end of the 

emissions from its anode baking month the source test report 

furnace operation by multiplying is received by Intalco. 

the Ecology approved sitespecific emission factor of2.02 

lbs ofNOx per ton of baked 

anodes times the tons of baked 

anodes produced during the 

month divided by the number of 

operating days during the month. 

Intalco shall report the monthly 

average of pounds ofBaking 
.... 

0 

0 

Alcoa Intalco \Vorks 

BART Compliance Order #7837, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

I 

I 

Metal Products Area 

A13 Remelt Furnace Nitrogen oxides 

(NOx) 

\ 

Emission limit 

NOx emissions shall not 

exceed: 

5. 72 tons for the most 

I recent 12-month period or 

0.48 tons for any single 

month or 

32 lb/calendar day, 30 day 

average. 

Remelt furnace NOx is , 

also included in plantwide 

natural gas NOx emission 

limit 

Page 8 of4 

MonitoriJJ.g and Recordkeeping Reporting req uir~ments 

requirements 

Furnace NOx per day. 

I 

Baking Furnace NOx Equation: 

Pounds NOx 

= day 

tons of Aluminum x 2.02lbNox 

month tonAL 

month 

x days per month 

Intalco shall detennine Remelt 30 days after the end of each 

Furnace NOx emission by the calendar month 

following method: 

Natural gas usage shall be converted to a 

calendar month average NOx emission rate 

through the use of an Ecology specified 

emission factor of 0.048 tons NOx 

/l.Ox I 06

scf of natural gas. 

For each month Intalco shall report: 

• The volume of natural gas 

consumed during the month 

(l.Oxl06scf) 

• The volume of natural gas 

consumed (I. Ox I 06

scf) in 

the most recent 12-month 

period 

• The tons ofNOx emitted 
r 

Alcoa In talco Works 

BART Compliance Order #783 7, Revision 1 

July 7, 2010 

Approval Process Area Pollutant 

Condition 

Al4 Homogenization NOx 

I Furnace - Unit 

#314 

I 

I 

Emission limit 

Emissions ofNOx shall 

not exceed 83 ppm 

corrected to 3% oxygen. 

Page 9 of4 

Monitoring and Recordkeeping Reporting requirements 

requirements 

during the month, 

The total tons ofNOx emitted for the most 

recent 12-month period 

Intalco shall conduct an annual source test 30 days after the end of the 

on the furnace dUring full operation using month the source test report 

EPA RM 7E forNOx and RM 3A for is received by Intalco. 

Oxygen as per 40 CFR Part 60, Appendix 

A, or another EPA approved method. 

lntalco can reduce the frequency of source 

testing to once every 5 years if each of 

three consecutive source tests 

demonstrates that the emission rate is < 

75% of the applicable limit. Intalco shall 

resume the original source testing 

frequency any time a source test 

demonstrates emissions have increased 

above 75% of the applicable limit. Intalco 

shaiJ submit a letter notifYing Ecology that 

the monitoring frequency will be reduced. 

The notification shall demonstrate the 

justification for the reduced monitoring 

frequency and schedule. In talco shall 

submit the notification to Ecology within 

60 days after the last source test used to 

make the demonstration.