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## ORDER #96-03 ORDER TO ESTABLISH VOLUNTARY EMISSIONS LIMITS FOR KAISER AlUMINUM 

### &_ CHEMICAl CORPORATION'S REMElT FURNACES PURSUANT TO WAC 173-400-091_
DATE: DATE MODIFIED,;,
ISSUEDTO: SITE lOCATION,:.

FACILITYCONTACT:
MAILINGADDRESS.;,
SOURCE: April 24, 1996 October 4, 2000 (Reduction in Emission limit, Addition of ConditionG, 

### & Revisionto Report Due Date) Kaiser Aluminum 

### &Chemical Corporation TrentwoodWorks 15000 E Euclid Avenue Spokane, WA Pat Blau (509)927-6350 P.O. Box 15108 Spokane, WA 99215-5108 10 Remelt Melter Furnaces: RM(Ml-1, RM(Ml-2E, RM(M)-2W, RM(M)-3, RM(M)-4, RM(M)-5, RM(M)-6, RM(M)-7, RM(M)-8E, RM(MI-8W SecondaryAluminum Production Facility
Kaiser Aluminum 

### & Chemical Corporation (Kaiser) operates a secondary aluminum productionfacilityat 15000E. Euclid Avenue, Spokane, WA. Kaiser's remelt melterfurnaces (furnaces) collectively have the potentialto emit 428 tons of particulate matter (PM) per year as calculated assuming maximum allowable emissions of 0.1 grains per dry standard cubic foot. As part ofthe attainmentdemonstrationin the State Implementation Plan (SIP) emissions were modeled, including those from Kaiser's remelt melter furnaces. The remelt melter furnace's assumed emissions for this modeling were much higher than actual emissions but much lower than the furnaces' potentialto emit. In an effort to maintain the validity of the SIP attainment demonstration, Kaiser has voluntarily requested that PM10 emissions from the remelt melter 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'sletter, dated August 8, 1995, voluntaryemission limits on the remelt furnaces' potential to emit. Revisions to the order have been made as requested in Patrick. Blau's letter, dated March 10, 1999. Kaiser has done extensivetesting to establish an alternate opacity limitfor the remelt melter furnaces. This testing yielded a correlation between opacity and grainloading, as detailed in Equations 1-3 below. The alternate opacity limit, set forth in SCAPCA Order 91-01, correlates to a grainloading of 0.068 which corresponds to daily PM emissions of 1590 pounds. This order originally limited melteremissionsto this level. In order to furtheroffset emissions from Kaiser's other emission units, Kaiser's letter, dated March 10, 1999, requestsa more stringentemission limitationon the melters. Kaiser's original request and revision request have been reviewed by SCAPCA. The following potentialto emit limitationshall be met bythefacility as required in F. below: 1. PM 10 emissions from all remelt meIter furnaces; RM(M)-1, RM(M)-2E, RM(M)-2W, RM(M)-3, RM(M)-4, RM(M)-5, RM(M)-6, RM(M)-7, RM(M)-8E, RM(M)-8W, combined shall notexceed 1200 pounds per day. To ensurethatthe above emission limit is met, the facility shall meetthe following: A. Compliance with the daily PM10 limit shall be determined using each furnace's opacity monitor in the following manner. For each furnace, a day (24 hour period beginning at midnightat ending at the following midnight) will be broken into six (6) consecutivefour (4) hour time blocks to representtheoretical furnace cycles. For each furnace, i, each four (4) hour block., j, shall be processed to obtain the maximum average opacity for any one hour interval during that four hour period, OP ii· This value shall then be used in Equation 1 to calculatethatfurnace's PM grainloadingfor thatfour (4) hour block., GL ij: Equation 1 

### GLiJ

## =0.003694

## *OPiJ

### +0.004699
where**G~** 

## = PM grainloading in grains per dry standard cubic foot for the i th furnace for the 

# rfour (4) hour block. OPij = highest 60 minute average opacity for the i th furnace for the 

### j'h four (4) hour block. Equation 2 shall be used to calculate PM emissions in pounds, PM ii• from the 

### Ph furnace, for the

# rfour (4) hour period during each day. The airflowfor each furnace, AF ;. shall be based on furnace design flow rates, taking into account operating conditions and other factors affectingflow, and shall be in terms of dry standard cubic feet per minute.

Kaiser Voluntary Emission limit Remelt Furnaces SCAPCA Order #96-03 Date Issued: April 24, 1996 Date Modified: October4, 2000 Page 2Equation 2 

### GLu •AF;*60*4 

### PMo= 7000 Equation 3 shall be used to calculate daily PM emissions in pounds for all furnaces combined, PM. Equation 3 /0 6 

### PM=LLPMu**i~l** j•l PM 10 emissions shall be assumed to equal PM emissions unless Kaiser provides appropriate technicaldocumentationto establishotherwiseas allowed in E. below. If opacity monitor data are not available for an operating furnace, OP ij for the furnace shall be estimated using any ofthe following methods:
a. the average OP, during that period, measured by opacity monitors on operating furnacesthat are charging similar materials; b. the highest OP, measured by the other opacity monitors on operating furnace for that period; or c. if circumstances suggest that the methods in i. and ii. above are inappropriate (e.g., if a number of monitors are down and high opacity readings from an operating monitor result in emission calculationsthat are biased high), Kaiser may calculateemissionsforthe furnace using an alternateprocedure, based on process parameters which are indicative of the emissions from the furnace (e.g., type of charge, activities occurring in the furnace, any EPA Reference Method tests performed, historic COM data, etc
...), provided that the alternate method is approved in advance bythe SCAPCA Control Officer. B. By the 25th day of each month, Kaiser shall submit to SCAPCA a report listing the previous month'sdaily PM and PM10 emissionsfor all remelt melterfurnaces combined and total PM and PM10emissionsfor that month. C. Kaiser shall maintainall recordsfor a period oftwoyears. D. SCAPCA may require testing to verify compliance with the PM 10 em1ss1on 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 60 (1995). Emissions shall be determined from the

Kaiser Voluntary Emission Limit Remelt Furnaces SCAPCA Order #96-03 Date Issued: April 24, 1996 Date Modified: October4, 2000 Page 3average of three valid test runs, each representing one furnace cycle, and shall include front and back half particulatematter. E. Upon submittal of appropriatetechnical documentation, SCAPCA may revise the method used to calculate PM and PM1 0 emissions from the remelt melterfurnaces. F. This order shall take effectupon completionofthefollowing:
a. EPA approval of SCAPCA Order 91-01 as part of the Washington State ImplementationPlan; and b. completionof the following: i. submissionto and approval by the Control Officer of a report demonstrating that the opacity monitor(s) installed on the furnace(s) meets the performance specifications set forth in 40 CFR Part 60, Appendix B, Performance Specification 1 (1990); ii. approval by the Control Officer of a quality assurance plan for the opacity monitor(s); and iii. commencementofcontinuousoperationofthe monitor(s). The above may be demonstratedseparatelyfor each furnace. G. Daily allowable emissions from the remelt melter furnaces; RM(M)-1, RM(M)-2E, RM(M)- 2W, RM(M)-3, RM(M)-4, RM(M)-5, RM(M)-6, RM(M)-7, RM(M)-8E, RM(M)-8W, 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 deviationfrom this order shall require revision or revocationofthis order. The revisionor revocation shall occur prior tothe deviation. This order does not relieve the proponent of the obligation to comply with all other applicablefederal, state and local regulations and requirements. The provisions of this authorization are severable and, if any provision of this order, or the applicationof 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 affectedthereby. This order may be appealed to:

Kaiser Voluntary Emission limit Remelt Furnaces SCAPCA Order #96·03 Date Issued: April 24, 1996 Date Modified: October4, 2000 Page 4Pollution Control Hearings Board c/o Environmental Hearings Office PO Box 40903

. 42246thAvenue 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:

## ~?~ ERIC P. SKELTON DIRECTOR

Kaiser Voluntary Emission limit Remelt Furnaces SCAPCA Order #96-03 Date Issued: April 24, 1996 Date Modified:October4, 2000 Page 5