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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,;, 

ISSUED TO: 

SITE lOCATION,:. 

FACILITY CONTACT: 

MAILING ADDRESS.;, 

SOURCE: 

April 24, 1996 

October 4, 2000 (Reduction in Emission limit, Addition of 

Condition G, & Revision to Report Due Date) 

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 

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 

Secondary Aluminum Production Facility 

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

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

Kaiser's remelt melter furnaces (furnaces) collectively have the potential to 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 of the attainment demonstration in 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' potential to emit. In 

an effort to maintain the validity of the SIP attainment demonstration, Kaiser has voluntarily 

requested that PM 10 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's letter, dated August 8, 1995, voluntary emission 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 extensive testing to establish an alternate opacity limit for 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 melter emissions to this level. In order to further offset 

emissions from Kaiser's other emission units, Kaiser's letter, dated March 10, 1999, 

requests a more stringent emission limitation on the melters. 

Kaiser's original request and revision request have been reviewed by SCAPCA. The 

following potential to emit limitation shall be met by the facility as required in F. below: 

1. PM 1 0 emissions from all remelt me Iter 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 

not exceed 1 200 pounds per day. 

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

midnight at ending at the following midnight) will be broken into six (6) consecutive four (4) 

hour time blocks to represent theoretical 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 

calculate that furnace's PM grainloading for that four (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 

r four (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 r four (4) hour period during each day. The airflow for each furnace, AF ;. shall be based 

on furnace design flow rates, taking into account operating conditions and other factors 

affecting flow, 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: October 4, 2000 

Page 2 
Equation 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 1 0 emissions shall be assumed to equal PM emissions unless Kaiser provides appropriate 

technical documentation to establish otherwise as 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 of the following methods: 

a. the average OP, during that period, measured by opacity monitors on operating 

furnaces that 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 calculations that are biased high), Kaiser may 

calculate emissions for the furnace using an alternate procedure, 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 by the SCAPCA Control Officer. 

B. By the 25th day of each month, Kaiser shall submit to SCAPCA a report listing the 

previous month's daily PM and PM10 emissions for all remelt melter furnaces combined and 

total PM and PM 10 emissions for that month. 

C. Kaiser shall maintain all records for a period of two years. 

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: October 4, 2000 

Page 3 
average of three valid test runs, each representing one furnace cycle, and shall include front 

and back half particulate matter. 

E. Upon submittal of appropriate technical documentation, SCAPCA may revise the method 

used to calculate PM and PM 1 0 emissions from the remelt melter furnaces. 

F. This order shall take effect upon completion of the following: 

a. EPA approval of SCAPCA Order 91-01 as part of the Washington State 

Implementation Plan; and 

b. completion of the following: 

i. submission to 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. commencement of continuous operation of the monitor(s). 

The above may be demonstrated separately for 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 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: 

Kaiser Voluntary Emission limit 

Remelt Furnaces 

SCAPCA Order #96·03 

Date Issued: April 24, 1996 

Date Modified: October 4, 2000 

Page 4 
Pollution Control Hearings Board 

c/o Environmental Hearings Office 

PO 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 

Remelt Furnaces 

SCAPCA Order #96-03 

Date Issued: April 24, 1996 

Date Modified: October 4, 2000 

Page 5