SCAPCA ORDER 

ISSUED IN ACCORDANCE WITH : 

RCW 70.94.141 - RCW 70.94.170 AND SCAPCA REGULATION I, SECTION 

2.01, 2.02, AND 2.05 

ORDER #96-06 

ORDER TO EST A BLISH VOLUNTARY EMISSIONS LIMITS FOR KAISER ALUMINUM &_ 

CHEMICAL CORPORATION'S INDUCTION FURNACES PURSUANT TQ 

DATE: 

DATE MODIFIED.i. 

DATE MOOIFIED.i. 

DATE MODIFIED.i. 

ISSUED TO: 

SITE LOCATION.i. 

FACILITY CONTACT: 

MAILING ADDRESS.i. 

SOURCE: 

WAC 1 73-400-091 

April 24, 1996 

May 8, 1996 (correction to Order #) 

October 4, 2000 (Addition of Condition F) 

October 19, 2000 (correction to Condition B) 

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 

Induction Furnaces, RM-21 

Secondary Aluminum Production Facility 

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

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

Kaiser's induction furnaces have the potential to emit about 76.2 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 induction furnaces. 

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 PM 1 0 emissions from the 

induction furnaces 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 induction furnaces' potential to emit. Revisions to the order have been made 

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

Source testing at the facility has shown that PM emissions from the induction furnaces are 

less than 0.020 grains per dry standard cubic foot, corresponding to 83.0 pounds of PM 

emitted per day. 

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

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

1. PM10 emissions from the two induction furnaces combined shall not exceed 83.0 pounds 

per day. 

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

A. Visible emissions, as measured by EPA Reference Method 9, shall not exceed 10% 

(three-minute average). 

B. SCAPCA may require testing to verify compliance with the 83.0 pounds per day PM10 

emissions limit. Testing shall be done in accordance with EPA reference methods as found 

in 40 CFR Parts 51 and 60 (1995). PM and/or PM10 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. 

PM10 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 10 emissions. 

C. An operation and maintenance plan for the induction furnaces' 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. 

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

Kaiser Voluntary Emission limit 

Induction Furnaces 

SCAPCA Order #96-06 

Date Issued: April 24. 1996 

Date Modified: May 8. 1996 

Date Modified: October 4, 2000 

Date Modified: October 19, 2000 

Page 2 
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. 

E. This order shall take effect upon EPA approval of SCAPCA Order 91-01 as· part of the 

Washington State Implementation Plan. 

F. Daily allowable emissions from the induction furnaces 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. 

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 98504-0903 

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: 

ERIC P. SKELTON 

DIRECTOR 

Kaiser Voluntary Emission limit 

Induction Furnaces 

SCAPCA Order #96-06 

Date Issued: April 24, 1996 

Date Modified: May 8, 1996 

Date Modified: October 4, 2000 

Date Modified: October 19, 2000 

Page 3