April 

May 1April 

In compliance with the provisions of 

The State of Washington 

Intalco Aluminum Corporation is 

authorized to operate in accordance 

with the terms and conditions 

of this permit

Issued by:State of Washington DEPARTMENT OF ECOLOGY 300 Desmond Drive P.O. Box 47600 Approved by:Carol Kraege, P.E. Industrial Section Manager

AIR OPERATING PERMIT No. 000295-0 

In compliance with the provisions of 

The State of Washington 

Clean Air Act Chapter 70.94 Revised Code of Washington

Issuance Date: 

Effective Date: 

Expiration Date: 

Page # 1 of 45 Alcoa Intalco Works Final Air Operating Permit 
Other Terms & Conditions of the Permit E. Metal ProductsF. AncillaryG. MaintenanceH. Facility-Wide Generally Applicable RequirementsSECTION III: STANDARD TERMS AND CONDITIONS OF THE PERMIT SECTION IV: GENERAL TERMS AND CONDITIONS OF THE PERMIT: Recordkeeping Terms & Conditions Reporting Terms & Conditions SECTION I: INTRODUCTION AND LEGAL AUTHORITY SECTION II: SPECIFIC TERMS AND CONDITIONS OF THE PERMITA. Green Carbon

TABLE OF CONTENTS

B. Baked CarbonC. Anode RoddingD. Potlines (Potroom Operations)SECTION V: PERMIT SHIELD/ INAPPLICABLE REQUIREMENTS SECTION VI: ABBREVIATIONS

Page # 2 of 45 Alcoa Intalco Works Final Air Operating Permit 
Process Specific Applicable Requirements: This permit categorizes permit conditions according to Intalco's aluminum smelter processes: green carbon, baked carbon, anode rodd

metal products, ancillary, and maintenance permit conditions are contained in Tables A through G respectively. The emission units identified in Tables A - G are the emission units specific requirements in addition to the generally applicable facility-wide requirements in Table H. Tables A through H are configured with a heading identifying the name of the procolumns titled Emission Unit; Pollutant/Parameter; Requirement; Monitoring, Reporting and Record-keeping; and Basis of Authority. In cases where an emission unit is subject to requirements, the citation for the most stringent of those requirements is listed first in column 6 (Basis of Authority) followed by the less stringent (or less specific) citations listed befont) [per WAC 173-301-600]. Terms used in this permit have the meaning assigned to them in the referenced regulations. The definitions of terms contained in WAC 173-401-200, and as defined in all referencthis permit unless otherwise defined in the permit.The permittee is subject to the respective requirements in each of the tables for the specific processes (Table A - G) and is also subject to all of the facility-wide generally applicablInsignificant emission units (IEUs) and activities are subject to the applicable requirements contained in the facility–wide generally applicable requirements (Table H), however, thetesting, monitoring, recordkeeping, reporting and certification requirements unless the generally applicable requirements in the State Implementation Plan (SIP) impose them [WAC All terms and conditions except state-only requirements are enforceable under the Federal Clean Air Act (FCAA). State-only requirements are specifically identified in the permit.Intalco Aluminum Corporation (Intalco) requires a Chapter 173-401 WAC Air Operating Permit because Intalco emits or has the potential-to-emit, one hundred tons per year or mopollutants as evidenced by Intalco's annual emission inventories and monthly air emission reports [WAC 173-401-300(1)].

Section I: INTRODUCTION AND LEGAL AUTHORITY

This Air Operating Permit is issued under the procedures established in the Operating Permit Regulation, Chapter 173-401 WAC (Washington Administrative Code). The provisionthe emissions limitations, operating requirements, emission monitoring, record keeping requirements, and reporting frequencies for the permitted source. 

Section II: SPECIFIC TERMS AND CONDITIONS OF THE PERMIT

During periods of total facility curtailment (100% of smelting operations are shut down), monitoring, inspections, and recordkeeping requirements can be discontinued if the permittcontemporaneous record in a log or file maintained on site of the date and time of total facility curtailment. The permittee must provide a written notice to Ecology of the date of totsubsequent monthy air monitoring report. Reporting requirements shall remain in effect. Upon start-up of the curtailed smelting operations, all requirements in this permit shall comIntalco is not required to conduct source tests on emission units that are shutdown due to a curtailment of potroom operations. Intalco is required to resume the pre-curtailment moaccordance with the permit conditions when operations are started again. For emission units subject to a source test frequency of every 2 years or greater, the commencement of shall be approved by Ecology.WAC 173-401-615 (1) of Ecology’s Operating Permit Regulation states that the AOP must fulfill the following requirement with respect to monitoring: “(1) Monitoring. Each permit srequirements with respect to monitoring: (b) Where the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring (which may consist designed to serve as monitoring), periodic monitoring sufficient to yield reliable data from the relevant time period that are representative of the source's compliance with the permisubsection (3) of this section. Such monitoring requirements shall assure use of terms, test methods, units, averaging periods, and other statistical conventions consistent with the Recordkeeping provisions may be sufficient to meet the requirements of this paragraph;”. WAC 173-401-630 (1) of Ecology’s Operating Permit Regulation states that the AOP murequirement with respect to compliance: “Consistent with WAC 173-401-615, all chapter 401 permits shall contain compliance certification, testing, monitoring, reporting, and recorsufficient to assure compliance with the terms and conditions of the permit.” The addition of these requirements is called “gapfilling”. Ecology has added gapfilling requirements (monitoring, recordkeeping, and reporting requirements to assuconditions of the AOP) that are authorized under WAC 173-401-615(1)(b) (Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping); and WAC 173-401-630(1) (General ComThe authority for the "gapfilling" requirements is distinquished in the AOP from the authority for applicable requirements that were established in approval orders issued by Ecology

Page # 3 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

A 1 Particulate 

Matter (PM) 

Emissions of PM shall not exceed 0.1 grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and A11. WAC 

401-6Monito615(2WAC Comp

A 2 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and A11. See C

A 3 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and A11. Same 

A1.

A 4 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and A11. See C

A 5 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and A11. Same 

A1.

A 6 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and A11. See C

A 7 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.e and A11. See C

A 8 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and A11. See C

A 9 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.e and A11. See C

A 10 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and A11. See C

188 Paste Plant 

Baghouse Stack, 189 

Phase “A” Ball Mill 

Baghouse, , 191 

Phase “B” Ball Mill 

Baghouse, 194 

Petroleum Coke 

Baghouse Stack, 

232 Spent Anodes 

Baghouse.

A 11 Functional 

Integrity

Inspection Intalco shall comply with Condition H4.a. See C

191 Phase “B” Ball Mill 

Baghouse (10,000 

acfm)

II A GREEN CARBON

194 Petroleum Coke 

Baghouse Stack 

(7,500 acfm)

 189 Phase “A” Ball Mill 

Baghouse (10,000 

acfm)

188 Paste Plant 

Baghouse Stack 

(19,000 acfm)

232 Spent Anode 

Crusher Baghouse 

(18,000 acfm)

Page # 4 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

A 12 PM10 Emissions of PM10 shall not exceed 2.36 pounds 

per hour [Per Order No. 02AQIS-3967]. Emissions of PM shall not exceed 0.1 gr/dscf 

[Per WAC 173-400-060; WAC 173-401-615(1)(b), WAC 173-401-615(2)(a); and WAC 173-401-630(1)].

Intalco shall comply with Condtitions H1, H2.b, and A 15. Order 

WAC 401-6Monito615(2WAC Comp

A 13 Opacity Opacity shall not exceed 5% for more than six 

consecutive minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.b, and A 15.

A 14 Polycyclic 

Organic Matter 

(POMS 

excluding 

napthalene)

Emissions of POM shall not exceed 0.54 lbs per hour

Intalco shall conduct a source test once every two years and upon Ecology’s request using EPA RM 315 as per 40 CFR 63, Appendix A, or another EPA approved method. Intalco shall submit the test report to Ecology within 90 days of the date of the test. Intalco can reduce the frequency of source testing to once every 5 years if condition H6 is met. Intalco shall comply with Conditions A15 and H14.

A 15 Functional 

Integrity

Inspection Intalco shall comply with Condition H4.b.

A16 Operation and 

Maintenance 

(O&M) Manual

O&M Manual Intalco shall develop, follow, and update an O&M manual. 

The O&M manual shall include the certification required under 40 CFR 63.843(b) and parametric monitoring in accordance 40 CFR 63.848(f)(1). 

II A GREEN CARBON (continued)

316 Pitch Fume 

Treatment System 

(50,000 acfm)

O

Page # 5 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

A 17 POM Operate and maintain equipment to capture and 

control POM emissions.

Intalco shall comply with conditions A 17 through A 19. 40CFR

A 18 Parametric 

monitoring

Operate, calibrate and maintain a continuous parameter monitoring system including, at a minimum, coke flow and air flow. Submit for approval the average coke feed rate which shall be maintained for each operating shift. Submit for approval the average air flow rate which shall be maintained for each operating shift.

Intalco shall monitor and maintain a log of coke feed and air flow rates. Intalco shall maintain records onsite and make them available to Ecology on request. Intalco shall submit a semiannual summary report of the parametric monitoring inspection results to Ecology.

40CFR40CFR

A 19 VE Visually inspect the exhaust stack(s) of each 

control device for evidence of any VE indicating abnormal operation.

Intalco shall conduct daily VE inspections (Method 9 is not required) and record the results.

40CFR

A 20 Corrective 

Action

Intalco shall intitiate the corrective action procedures identified in the current version of the startup, shutdown and malfunction (SSM) plan within 1 hour if a monitoring device measures an operating parameter outside the limit(s) established pursuant to § 63.847(h) or if VE indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection. Intalco shall comply with the SSM plan. Failure to inititate the corrective action within 1 hour or to take the necessary corrective actions to remedy the problem is a violation.

 Intalco shall maintain records of all instances of failure to initiate corrective action procedures within 1 hour or to take necessary corrective actions to remedy the problem.

40CFR

A 21 Exceedances If the limit for a given operating parameter 

associated with monitoring a specific control device (per condition A18) is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hr. period.

Intalco shall record all exceedences of the limits for operating parameters. 

40CFR

A 22 Accuracy and 

calibration

All monitoring devices required by condition A 18 [40CFR63.848] must be certified by Intalco to meet the accuracy requirements and must be calibrated in accordance with manufacturer’s instructions.

Intalco shall submit any changes to monitoring devices that affect their accuracy to Ecology for review and approval. 

40CFR

A 23 Excess 

Emissions 

report

Intalco shall submit a semiannual excess emissions report, containing information specified in 40CFR63.10(e)(3)(v), if measured emissions exceed the applicable standard unless quarterly reports are required as a result of excess emissions. 

40CFR40CFR

A 24 File 

Maintenance

Intalco shall maintain files of all information, reports and notifications required by 40CFR63.10(b) and 40CFR63 Subpart LL in accordance with 40CFR63.850(e) for a minimum of 5 years.

40CFR40CFR

316 Pitch Fume 

Treatment System 

(50,000 acfm)

II A GREEN CARBON (continued)

Conditions A17 through A 24 incorporate MACT requirements published at FR52384 October 7, 1997

Page # 6 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

B 1 PM When added to the total PM emissions from the 

primary and secondary potline control systems, PM emissions from the bake oven baghouse shall not exceed the PM limits in Conditions D6 and D7 [Per Order No. 02AQIS-3967]. Emissions of PM shall not exceed 0.1 grains/dscf [Per WAC 173-400-050(1); WAC 173-401-615(1)(b), WAC 173-401-615(2)(a); and WAC 173-401-630(1)].

Intalco shall determine and demonstrate compliance with the PM limits by conducting a source test once per year and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall report the grainloading concentration (grains/dscf) for the bake oven baghouse and Intalco shall report the monthly average of the combined total pounds of PM per day and the 3-month average of the combined total pounds of PM per ton of aluminum produced from the bake oven baghouse and the potlines (per Conditions D6 and D7) in the respective monthly air monitoring report submitted to Ecology. Intalco shall comply with Conditions H1, H14, and B5. 

Order WAC WAC (Perio401-6and W(GeneRequi

B 2 TF Emissions of TF from the bake ovens when 

added to the total TF emissions from the primary and secondary potline control systems shall not exceed the TF limits in Conditions D11 and D12.

Intalco shall determine and demonstrate compliance with the TF limits by conducting a source test on the bake oven baghouse 3 times per year using Alcoa Methods 4075A and 4046A. Intalco shall report the monthly average of the combined total pounds of TF per day and the 3-month average of the combined total pounds of TF per ton of aluminum produced from the bake oven baghouse and the potlines (per Conditions D11and D12) in the respective monthly air monitoring report submitted to Ecology. Intalco shall comply with Conditions H1, H14, and B5.

Order 

B3 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and B5. See C

B4 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with condition H 1, H 8 and B5. Define

B5 Functional 

Intregrity

Inspection Intalco shall comply with Condition H4.a. Define

II A BAKED CARBON

187 Bake Oven 

Baghouse (100,000 

acfm)

Page # 7 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

B6 TF Shall not exceed 0.20 lb/ton of green anode 

placed in the anode bake furnaces.

Intalco shall conduct source tests in accordance with the approved test plan at the exhaust stack using Alcoa Method 4075ATF/4076TF. Intalco shall compute and record the annual average of all valid test runs ( a minimum of three test runs) each year to determine compliance, using equation 2 in 40CFR63.847(e)(3). Intalco shall submit test results each year in accordance with Condition H14.

40CFR 848(c)40CFR 

B7 POM Shall not exceed 0.18 lb/ton of green anode 

placed in the anode bake furnaces.

Intalco shall conduct source tests in accordance with the approved test plan at the exhaust of module A-446 using Alcoa Method 4075ATF/4076TF. Intalco shall compute and record the annual average of all valid test runs ( a minimum of three test runs) each year to determine compliance, using equation 2 in 40CFR63.847(e)(4). Intalco shall submit test results each year in accordance with Condition H14.

40CFR 848(c)63.7(b

B8 Parametric 

Monitoring

Operate, calibrate, and maintain a continuous parameter monitoring system including, at a minimum, alumina flow and air flow. Submit for approval the average ore flow rate into each reactor which shall be maintained. Submit for approval the average air flow rate from the baking furnace which shall be maintained.

Intalco shall inspect each control device to ensure the control device is operating properly and record the results of each inspection. Intalco shall monitor and maintain a log of ore feed and air flow rates. Intalco shall maintain records onsite and make them available to Ecology upon request. Intalco shall submit a semiannual summary report of the parametric monitoring inspection results to Ecology.

40CFR40CFR

B9 Visible 

Emissions (VE)

Visually inspect the exhaust stack of each control device for evidence of any VE indicating abnormal operation.

Intalco shall conduct daily VE inspections (EPA RM 9 is not required) and record the results.

40CFR

B 10 Corrective 

Action

Intalco shall intitiate the corrective action procedures identified in the startup, shutdown and malfunction (SSM) plan (per Condition B14) within 1 hour if a monitoring device measures an operating parameter outside the limit(s) established pursuant to § 63.847(h) or if VE indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection. Intalco shall comply with Condition B13 (SSM plan). Failure to inititate the corrective action within 1 hour or to take the necessary corrective actions to remedy the problem is a violation.

 Intalco shall maintain records of all instances of failure to initiate corrective action procedures within 1 hour or to take necessary corrective actions to remedy the problem.

40CFR

187 Bake Oven Baghouse (100,000 acfm)

Conditions B6 through B 15 incorporate MACT requirements published at FR52384 October 7, 1997

II B BAKED CARBON (continued)

Page # 8 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

B 11 Exceedances If the limit for a given operating parameter 

associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hr. period.

Intalco shall record all exceedences of the limits for operating parameters. 

40CFR

B 12 Green anode 

material weight

Intalco shall operate and maintain a monitoring device to determine the daily weight of green anode material by measuring the weight of all anodes or by monitoring the number of green anodes placed in the furnace and determining an average weight from measurements of a representative sample of anodes. 

Intalco shall record the monthly average weight of anodes placed in each furnace in tons, to calculate the daily weight of anodes placed in each furnace in tons. Per approved Parameter Monitoring Plan. 

40CFR

B 13 Accuracy and 

calibration

All monitoring devices required by condition B8 must be certified by Intalco to meet the accuracy requirements and must be calibrated in accordance with manufacturer’s instructions.

Intalco shall submit any changes to monitoring devices that affect their accuracy to Ecology for review and approval. 

40CFR

B 14 Excess 

Emissions 

Report

Intalco shall submit an excess emission report semiannually containing information specified in 40CFR63.10(e)(3)(v), if measured emissions exceed the applicable standard unless quarterly reports are required as a result of excess emissions. 

40CFR40CFR

 B 15 File 

Maintenance

Intalco shall maintain files of all information, reports and notifications required by 40CFR63.10(b) and 40CFR63 Subpart LL in accordance with 40CFR63.850(e) for a minimum of 5 years.

40CFR40CFR

B16 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and B19. Same 

A1

B17 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and B19. See C

B18 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with condition H 1 and H8. See C

B19 Functional 

Integrity

Inspection Intalco shall comply with condition H4.c. See C

II B BAKED CARBON (continued)

187 Bake Oven 

Baghouse (100,000 

acfm)

251 Anode Bake 

Building Roof Vents

Page # 9 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

C1 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.c and C5. See C

C2 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and C5. See C

C3 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.c and C5. See C

C4 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and C5. See C

198 Rodshop 

Baghouse (West), 

199 Rodshop 

Baghouse (East), 

C5 Functional 

Integrity

Inspection Intalco shall comply with condition H4.a. See C

C6 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and C8. Same 

A1

C7 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and C8. See C

C8 Functional 

Integrity

Inspection Intalco shall comply with condition H4.c. See C

198 Rodshop 

Baghouse (West) 

(50,000 acfm)

199 Rodshop 

Baghouse (East) 

(50,000 acfm)

II C ANODE RODDING

253 Rod Shop Building 

Roof Vents North

Page # 10 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D1 Aluminum 

Production

Net potline production of aluminum shall be limited to < 307,000 tons of aluminum per 

calendar year. 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. 

Intalco shall maintain a record of the daily net production of aluminum and report the average daily net aluminum production in the monthly air monitoring report that is submitted to Ecology per Condition H14. 

Order 

Intalco shall maintain a record of the data collected for the parameters below, compute the monthly average, and report the monthly average (unless another average is noted below) for each parameter in the respective monthly air monitoring report submitted to Ecology per Condition H14: · Number of pots operated per day (potdays) · Percent sulfur in pitch (Intalco shall analyze each incoming load or batch of pitch for sulfur content using the procedures in ASTM D4239 or other ASTM sulfur methods) 

Order 

 · Percent sulfur in coke (Intalco shall analyze each incoming load or batch of coke for sulfur content using the procedures in ASTM D4239 or other ASTM sulfur methods) · Percent sulfur in baked anode as a weekly composite of anode core samples . Current Efficiency · Carbon consumption ratio as a daily average computed monthly · Amperes of current · Average number of days per pot to complete a pot relining · Total pounds of aluminum sent to cast house per day 

D3 “Water Off” 

(periods when the secondary control system roof scrubbers are turned off due to potential freezing conditions) emission limits and conditions are covered under WAC 173-415-030(6).

All of the limits and conditions in Conditions D1 through D26 were developed for “water on” conditions. Water Off emission limits and conditions are covered under WAC 173-415-030(6) until Ecology issues an order with new conditions. Intalco shall follow the procedures specified in the current version of the Startup Shutdown and Malfunction Plan to determine when shutdown is necessary, and when the roof scrubbing system can be safely started again. During these periods where the scrubbers continue to operate, but conditions prohibit safe roof access, Intalco will not conduct source testing of the roof scrubbers.

Intalco shall notify Ecology that the roof scrubbers are going to be shut off. Intalco shall use all tests conducted over the calendar month to demonstrate compliance. For potlines where less than the required three tests were completed in the calendar month according to the schedules specified in the approved Air Monitoring Plan per Condition H15, data from the preceding 24 months shall be substituted. The average and standard deviation of all roof scrubber tests shall be computed from the data set of each potline. The average plus two standard deviations will be used for all tests that could not be run. Intalco shall report the average of all actual tests run during the compliance period and the values obtained from the average and standard deviations described above as the roof emissions for each potline in the respective monthly air monitoring report submitted to Ecology. 

Order 

D2 Operational 

Limits

The following limits shall not be exceeded : · Operating ≤ 720 pots/day 

· 3.0 % sulfur in coke · 0.6 % sulfur in pitch · 91.25 % current efficiency · 150,000 amps of current · 0.4250 carbon consumption ratio (pounds of carbon consumed per pound of Aluminum produced).

Order 

II D POTLINES Potlines A, B, and C primary (6 baghouse centers with varying numbers of individual stacks (emission units 181-186) combined flow = 1.75 million scfm) and secondary control systems (159 baghouse stacks (emission units 22-180) combined flow = 16 million scfm). 

Page # 11 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/P t

Requirement Monitoring, Reporting and Record-keeping 

D4 PM Emissions of PM from potrooms shall not 

exceed 0.1 grains/dscf.

Intalco shall determine and demonstrate PM compliance with the the PM limit of 0.1 grains/dscf by complying with the the monitoring, recordkeeping, and reporting requirements in Condition D6 and Intalco shall comply with Conditions D17, D18, and D19. 

WAC WAC (Perio401-6and W(GeneRequi

D5 PM The total emissions of PM to the atmosphere 

from the reduction process (potlines) shall be reduced to the lowest level consistent with reasonably available control technology (RACT). Emissions of PM shall not exceed fifteen (15) pounds of PM per ton of aluminum produced on a daily basis. 

Intalco shall determine PM emissions and demonstrate compliance with the the PM limit of 15 lb/ton of Al produced by complying with the 6.0 lb PM/ton Al limit and the monitoring, recordkeeping, and reporting requirements in Condition D7. A demonstration of compliance with the 6.0 lbPM/ton Al limit in Condition D7 will be considered a demonstration of compliance with this less stringent 15lbPM/ton Al limit. Intalco shall comply with Conditions D17, D18, and D19. 

WAC WAC (Perio401-6and W(GeneRequi

D7 PM 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.

II D POTLINES (continued) 

D6 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. 

PM

Potlines A, B, and C primary (6 baghouse centers with varying numbers of individual stacks (emission units 181-186) combined flow = 1.75 million scfm) and secondary control systems (159 baghouse stacks (emission units 22-180) combined flow = 16 million scfm). 

Intalco shall determine PM emissions and demonstrate compliance with the PM limits in Conditions D4 through D7 by source testing the primary control systems of potlines A, B, and C (4 cells per month per potline [2 cells from each of 2 baghouse centers]) using Alcoa Method B-54 or another EPA approved method for a minimum of 24 hours and by sampling the secondary control systems of potlines A, B, and C using Alcoa Method B-54b (three roof scrubbers simultaneously three times per month per potline). Intalco shall report the results of the source tests conducted in compliance with Conditions D4 through D7 in the respective monthly air monitoring report submitted to Ecology per condition H14. Intalco shall comply with Conditions D17, D18, D19, and H14. 

Order 

Page # 12 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D8 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H3.a, D17, D18, and D19.

See C

Intalco shall determine representative TF emissions from the potline primary control system by conducting a minimum of three pairs of source tests on each operating primary control system per year (40 CFR 63.847(b)(1)) using Alcoa Method 4075A. To meet this requirement Intalco shall conduct source tests on a minimum of 8 cells in each potline in a 12 month period (4 cells from each of the 2 CDs in Potline A and 2 cells from each of the 4 CDs in Potline B and in Potline C) [40 CFR 63.847(b)(7))]. Intalco shall calculate the total primary TF emissions from each potline by multiplying the average representative emissions per stack (determined by source testing) by the number of stacks per potline. Intalco shall determine representative TF emissions from the potline secondary control system by conducting a minimum of three source tests simultaneously on three wet scrubbers per operating potline each month using Alcoa Method B-54b. Intalco shall determine the total secondary TF emissions by multiplying the average representative emissions per wet scrubber (determined by source testing) by the number of wet scrubbers per potline. Intalco shall demonstrate compliance with the TF limits in Conditions D9 and D10 by summing the total TF emissions from the primary control systems and the total TF emissions from the secondary control systems of each potline and comparing the sum to the respective limits. Intalco shall report the results of the source tests conducted in compliance with Conditions D9 and D10 in the respective monthly air monitoring report submitted to Ecology per Condition H14. Intalco shall comply with Conditions D17, D18, D19, and H14. Intalco shall conduct initial and ongoing performance tests in accordance with the approved Air Monitoring Plan per Condition H15.

Potlines A, B, and C primary (6 baghouse centers with varying numbers of individual stacks (emission units 181-186) combined flow = 1.75 million scfm) and secondary control systems (159 baghouse stacks (emission units 22-180) combined flow = 16 million scfm).

Emissions of TF shall not exceed a combined total of 1,350 pounds per day (calculated on a one month average) from the potlines (primary and secondary control systems) and the bake ovens.

II D POTLINES (continued) 

D9 Total Fluoride Ord

(TF)

Page # 13 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D10 TF Emissions of TF shall not exceed a combined 

total of 1.6 pounds per ton of aluminum (calculated on a three month average) produced from the potlines (primary and secondary control systems) and the bake ovens.

Intalco shall determine TF emissions and demonstrate compliance with the the TF limit of 1.6 lb/ton of Al produced by complying with the the monitoring, recordkeeping, and reporting requirements in Condition D9. Intalco shall comply with Conditions D17, D18, and D19.

O

D11 Sulfur dioxide 

(SO2)

SO2 concentration shall not exceed 1000 ppm corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with Condition H8. See C

D12 SO2 Emissions of SO2 shall not exceed 37, 780 

pounds per day (calculated on a one month average). 

Intalco shall determine the SO2 emitted by using the following 

formula: SO2 emissions in lbs./day = (carbon consumption ratio)x(% sulfur in baked anodes/100)x (2 lb sulfur dioxide per lb sulfur)x(2000 pounds Aluminum per ton)x (Tons of 

Aluminum per day). 

Carbon consumption ratio (pounds of carbon consumed per pounds of Aluminum produced) Intalco shall report the monthly average of pounds of SO2 per day in the respective monthly air monitoring report submitted to Ecology per Condition H14. Intalco shall maintain records of production data used to develop carbon consumption ratio and tons of aluminum produced. Intalco shall provide the records to Ecology upon request. Intalco shall comply with Condition H7. 

D13 SO2 Emissions of SO2 shall not exceed 44.8 pounds 

per ton of aluminum produced (calculated on a three month average).

Intalco shall determine the SO2 emitted by using the formula 

in Condition D12. Intalco shall report the three month average of the pounds of SO2 per ton of aluminum in the respective monthly air monitoring report submitted to Ecology per Condition H14. 

II D POTLINES (continued) Potlines A, B, and C primary (6 baghouse centers with varying numbers of individual stacks (emission units 181-186) combined flow = 1.75 million scfm) and secondary control systems (159 baghouse stacks (emission units 22-180) combined flow = 16 million scfm).

Order 

Page # 14 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D14 Carbon 

monoxide (CO)

Emissions of CO shall not exceed 236,150 pounds per day (calculated on a one month average).

Intalco shall calculate CO emissions based on current efficiency of the potlines using the following formula: Emissions of CO in pounds per day = (100/C.E.) -1)x (3/2)x (28.01/21.98)x (aluminum production)x(0.917). C.E.= Current Efficiency of the potlines. 0.917 = the ratio of measured CO emissions to calculated CO emissions (Intalco's self reported empirical value). Intalco shall report the monthly average of pounds of CO per day in the monthly air monitoring report submitted to Ecology per Condition H14. 

D15 CO Emissions of CO shall not exceed 280 pounds 

per ton of aluminum produced (calculated on a three month average).

Intalco shall determine CO emissions and demonstrate compliance with the 280 lb CO/ton Al limit by using the method described in Condition D14. Intalco shall report the three month average of the pounds of CO per ton of aluminum in the monthly air monitoring report submitted to Ecology per Condition H14.

D16 Nitrogen oxides 

(NOx)

Emissions of NOx shall not exceed 590 pounds per day (calculated on a one month average).

Intalco shall determine the NOx emitted by using the AP-42 emission factor of 140 lbs. of NOx per million cubic feet of natural gas consumed (as in a large natural gas combustion boiler unit). Intalco shall report the monthly average of pounds of NOx per day in the monthly air monitoring report submitted to Ecology per Condition H14.

D17 Primary Control 

System Functional Integrity

Inspection Intalco shall comply with Condition H4.d. 

D18 Secondary 

Control System Functional Integrity

Inspection Intalco shall comply with Condition H4.e. 

Potlines A, B, and C 

primary (6 baghouse 

centers with varying 

numbers of individual 

stacks (emission units 

181-186) combined flow 

= 1.75 million scfm) and 

secondary control 

systems (159 baghouse 

stacks (emission units 

22-180) combined flow 

= 16 million scfm).

II D POTLINES (Continued) 

Order 

Page # 15 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

Intalco shall comply with Condition H1 by: D26.a) Maintaining sufficient draft in the pots to capture direct pot emissions. Intalco shall demonstrate compliance by meeting the parametric monitoring requirements in Condition D22. D26.b) Maintaining flow of fresh alumina into the inlet flow of each potline baghouse. Intalco shall demonstrate compliance by meeting the parametric monitoring requirements in Condition D22. D26.c) Maintaining records of sight glass readings and making those records available to Ecology upon request. D26.d) Checking flows on a minimum of four baghouse cells each month. During this process, Intalco shall readjust the damper position, remeasure the flow, and mark the correct damper position on the stack if the flow from a baghouse cell exceeds the established maximum flow rate for that cell. Intalco shall provide records of these inspections to Ecology upon request. D26.e) Conducting weekly inspections to assure that only one hood at a time is open for anode change and tapping operations and that only two hoods are open in any 20 pot section during line breaks for all shifts and for all potlines. If Intalco observes that these practices are not being followed, Intalco shall take corrective action. Corrective action shall include, at a minimum, closing the extra open hoods immediately. Intalco shall provide records of these pot hood inspections to Ecology upon request.. D26.f) Maintaining sufficient flow of recycle water to the wet roof scrubbers. Intalco shall demonstrate compliance by meeting the parametric monitoring requirements of Condition 29. D26.g) Complying with the functional integrity inspection requirements in Conditions D17 and D18. D26.h) Conducting semi-annual "limited root cause analyses". These analyses consist of gathering Intalco staff (environmental manager, operator(s) with extensive knowledge of current potroom hood and wet scrubber conditions, potroom source testing staff, and staff who conduct the procedures which generate, m

review, and report emissions data in the monthly air monitoring reports submitted to Ecology) to evaluate trends in the emissions data and to determine measures to minimize emissions. Intalco shall submit a summary of the findings of the "limited root cause analysis" and anymeasures implemented to minimize emissions in the subsequent month's air monitoring report. Intalco shall include a bar chart of "Potline Emissions" for each of the respective pollutants illustrating the contributions from dry and wet scrubbers for each operating potline for that month and the previous 24 months to illustrate trends in the emissions data.

II D POTLINES (Continued) 

Potlines A, B, and C D19 Potroom O&M Potroom O&M Order 

primary (6 baghouse 

centers with varying 

numbers of individual 

stacks (emission units 

181-186) combined flow 

= 1.75 million scfm) and 

secondary control 

systems (159 baghouse 

stacks (emission units 

22-180) combined flow 

= 16 million scfm). 

Page # 16 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D20 TF Emissions of TF shall not exceed 1.6 lbs/ton of 

Al produced from each potline.

Intalco shall determine emissions of TF and demonstrate compliance with the 1.6 lb/ton of aluminum produced TF limit by complying with the monitoring, recordkeeping, and reporting requirements of Condition D9. Intalco shall determine compliance by averaging all valid source tests of potline primary control systems conducted less than one year before the compliance date for the reporting period, and all valid source tests conducted on the potline secondary control system collected during the compliance period (40 CFR 63.848(a)).

40CFR 848(a63.7(b

D21 Audit Materials Intalco shall request performance audit materials 

45 days prior to each performance test.

40CFR 

D22 Parametric 

Monitoring

Intalco shall operate, calibrate, and maintain a continuous parameter monitoring system including, at a minimum, alumina flow, air flow, and water flow. Intalco shall maintain alumina flow, air flow, and water flow rates per the approved parametric monitoring plan. 

Intalco shall submit proposed changes to approved parametric monitoring plan for alumina flow and air flow rates prior to making changes in parametric limits. Intalco shall maintain records of air flow and alumina flow rates. Intalco shall report exceedances of parametric limits semiannually. Intalco shall comply with Condition D24. 

40CFR40CFR

D23 VE Visually inspect the exhaust stack(s) of each 

control device for evidence of any VE indicating abnormal operation.

Intalco shall conduct daily VE inspections (Method 9 is not required) and maintain records of the inspections. 

40CFR

D24 Corrective 

Action

Intalco shall intitiate the corrective action procedures identified in the current version of the SSM plan within 1 hour if a monitoring device measures an operating parameter outside the limit(s) established pursuant to § 63.847(h) or if VE indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection. Intalco shall comply with the SSM plan. Failure to inititate the corrective action within 1 hour or to take the necessary corrective actions to remedy the problem is a violation. 

 Intalco shall maintain records of all instances of failure to initiate corrective action procedures within 1 hour or to take necessary corrective actions to remedy the problem.

40CFR

II D POTLINES (Continued) 

Potlines A, B, and C 

primary (6 baghouse 

centers with varying 

numbers of individual 

stacks (emission units 

181-186) combined flow 

= 1.75 million scfm) and 

secondary control 

systems (159 baghouse 

stacks (emission units 

22-180) combined flow 

= 16 million scfm). 

Conditions D20 through D29 incorporate MACT requirements published at FR52384, October 7, 1997

Page # 17 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

D25 Exceedances If the limit for a given operating parameter 

associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed to any given 24-hr. period.

Intalco shall record all exceedences of the limits for operating parameters. 

40CFR

D26 Weight of 

Aluminum 

Produced

Operate and maintain a monitoring device to determine the daily weight of aluminum produced.

Intalco shall record the tons of aluminum produced daily for each potline.

40CFR

D27 Accuracy and 

calibration

All monitoring devices required by condition D29 [40CFR 63.848] must be certified by Intalco to meet the accuracy requirements and must be calibrated in accordance with manufacturer’s instructions.

Intalco shall submit any changes to recommended accuracy requirements to Ecology for review and approval.

40CFR

D28 Excess 

Emissions 

Reports

Intalco shall submit an excess emission report semiannually, containing information specified in 40CFR63.10(e)(3)(v), if measured emissions exceed the applicable standards. Intalco shall submit quarterly reports if excess emissions are observed during the quarter. 

40CFR40CFR

D29 File 

Maintenance

Intalco shall maintain files of all information, reports and notifications required by 40CFR63.10(b) and 40CFR63 Subpart LL in accordance with 40CFR63.850(e) for a minimum of 5 years.

40CFR40CFR

Potlines A, B, and C 

primary (6 baghouse 

centers with varying 

numbers of individual 

stacks (emission units 

181-186) combined flow 

= 1.75 million scfm) and 

secondary control 

systems (159 baghouse 

stacks (emission units 

22-180) combined flow 

= 16 million scfm). 

II D POTLINES (Continued) Conditions D20 through D29 incorporate MACT requirements published at FR52384, October 7, 1997

Page # 18 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 1 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.d, and E4. See C

E 2 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and E4. See C

E3 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen base on the average of any period of 60 consecutive minutes

Intalco shall comply with condition H 1 and H8. See C

E4 Functional 

Integrity

Inspection Intalco shall comply with condition H4.f See C

E5 Carbon 

monoxide (CO)

Emissions of CO shall not exceed 100 ppm of CO on a dry basis corrected to 3% oxygen from the remelt furnace stack. CO mass emission rate shall not exceed 5.5 tons for any 12 month period or 0.47 tons for any single month from the remelt furnace stack.

CO levels shall be controlled by limiting natural gas consumption and the quantities of aluminum scrap remelted (per Conditions E12 and E13) until new limits are established. CO limits and monitoring requirements will be determined based on the results of performance testing on the modified system and will be established in a new order issued by Ecology.

O

E6 PM PM emissions shall not exceed a concentration 

of 0.1 grains/dscf 

PM levels shall be controlled by limiting natural gas consumption and the quantities of aluminum scrap remelted (per Conditions E12 and E13) until new limits are established.

 WA

40

Mon

615(2

WAC 

Com

E7 PM PM emissions shall not exceed 2.5 tons for any 

twelve month period, or 0.22 tons for any single month from the remelt furnace stack.

E8 PM10 

(particulate with 

a mean 

aerodynamic 

diameter of less 

than or equal to 

ten 

micrometers)

PM10 emissions shall not exceed 1.5 tons of PM 

for any twelve month period, or 0.13 tons of PM10 for any single month from the remelt furnace stack.

217 Remelt Furnace 

Holding Furnaces: 4, 5, 

7, 8, 10, 11, 13, 14, 16, 

17, 18, 19 

(153,000 acfm)

Intalco shall report all PM as PM10. PM levels shall be Ocontrolled by limiting natural gas consumption and the quantities of aluminum scrap remelted (per Conditions E12 and E13) until new limits are established. PM limits and monitoring requirements will be determined based on the results of performance testing on the modified system and will be established in a new order issued by Ecology. Intalco has opted to report all PM as PM10 and to comply with the PM10 limit in Condition E8. Should Intalco decide to establish emission factors for PM and PM10 and to report PM and PM10 separately, Intalco shall develop a source test plan which describes how the emission factors will be derived. Intalco shall submit the source test plan to Ecology for review and approval. Intalco may use the Ecology approved emission factors to report separate emission rates for PM and PM10. When reporting PM and PM10 derived from the approved emission factors, Intalco shall comply with the respective PM and PM10 limits in Conditions E7 and E8. 

II E METAL PRODUCTS

Page # 19 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

Intalco shall determine and demonstrate compliance with opacity limits by: a). Conducting weekly visible emission tests using EPA RM 9 per 40 CFR Part 60 until the COM is operational. b). Increasing the opacity monitoring (conducted per Condition 5.a) to three times per week if the opacity limits in Condition 1.f are exceeded more than once in any 7 day period. c). Installing a continuous opacity monitor (COM) on the remelt furnace stack by August 01, 2004. d). Maintaining the COM in compliance with EPA Performance Specification 1 per 40 CFR Part 60, Appendix B. If Intalco shuts down all casthouse operations prior to August 01, 2004, Intalco shall install the COM before startup of remelt operations.e). Taking corrective action if opacity exceeds any of the opacity limits. Corrective actions include but are not limited to: (a) adjusting flue residence time by adjusting charge door height; (b) reducing firing rate; (c) re-analyzing scrap for oil content; and (d) reviewing and modifying cast house work practices. Intalco shall record the date and time of each corrective actionduring the exceedance, and the actions taken to prevent future occurrences.f). Reporting all opacity exceedances, noncompliance with the requirements defined in a) through e) above, and the corrective actions taken in the respective monthly air monitoring report submitted to Ecology.

E10 Nitrogen oxides 

(NOx)

New NOx limits and monitoring requirements will be determined based on the results of performance testing on the modified system and will be established in a new order issued by Ecology.

Intalco shall control NOx levels by limiting natural gas consumption and the quantities of aluminum scrap remelted (per Conditions E12 and E13) until new NOx limits are established. 

O

E11 Modifications of 

the remelt 

furnace

Intalco shall complete the modifications on the remelt furnace system recommended in the Engineering Study submitted to Ecology on November 26, 2003 by August 01, 2004.

Intalco shall complete the modifications recommended in the engineering study submitted to Ecology on November 26, 2003 by August 01, 2004. 

O

E12 Natural Gas 

Consumption

Intalco shall not use more than 75,000 MMBtu of natural gas/year in the remelt furnace. This is an interim limit until source testing on the modified remelt furnace demonstrates (to Ecology's satisfaction) that restrictions on consumption of natural gas are not necessary to meet the emission limits in Conditions E5 through E8 and E10. 

Intalco shall monitor, electronically record, and maintain records of the total number of cubic feet of natural gas consumed by the remelt furnace each month. Intalco shall provide the electronic records to Ecology upon request. 

Order 

217 Remelt Furnace E9

(continued)

Opacity shall not exceed: E7.a) an average of 5 % for any 60 minute period and; E7.b) 20 % for more than 3 minutes in any 1 hour period, or E7.c) 5 % for more than 6 consecutive minutes in any 60 minute period.

II E METAL PRODUCTS (continued)

Opacity O

Page # 20 of 45 Alcoa Intalco Works Final Air Operating Permit 
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/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E13 Remelted 

Aluminum 

Scrap

Intalco shall not remelt more than 45,640 tons of scrap per year in the remelt furnace. This is an interim limit until source testing on the modified remelt furnace demonstrates (to Ecology's satisfaction) that restrictions on the amount of scrap melted are not necessary to meet the emission limits in Conditions to meet the emission limits in Conditions E5 through E8 and E10. 

Intalco shall monitor, record electronically, and maintain records of the total number of tons of aluminum produced by the remelt furnace per month. Intalco shall provide the electronic records to Ecology upon request. 

Order 

E14 O&M Manual Intalco shall develop an O&M manual for the 

remelt furnace by October 29, 2004, follow it and update it as necessary for all associated equipment and work practices that may affect emissions of pollutants to the atmosphere. 

Copies of the manual shall be available for review by Ecology.The O&M manual shall ensure that, at all times, including periods of abnormal operation and upset, Intalco personnel, to the extent practicable, maintain the remelt furnace, and operate and maintain air pollution control equipment associated with the remelt furnace in a manner consistent with good air pollution control practice. Emissions that result from a failure to follow the requirements of the manual may be considered proof that the equipment was not properly operated and maintained. Intalco shall follow the O&M manual and update the manual as necessary to include any changes in operation of the remelt furnace and activities related to its operation.

Order 

E15 Functional 

Integrity

Inspection Intalco shall conduct a weekly functional integrity inspection 

of the remelt furnace system that, at a minimum, includes a visual check for visible emissions. Intalco shall record the observations of the parameters assessed in the inspection log. Any time visible emissions are present, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log.

Order 

217 Remelt Furnace 

(continued)

II E METAL PRODUCTS (continued)

Page # 21 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 16 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.f and E20 See C

E 17 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and E20 See C

E18 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with condition H 1 and H8. WAC 

E 19 NOx Emissions of NOx shall not exceed 83 ppm 

corrected to 3% oxygen at 1500 – 1600 Deg. F

Intalco shall conduct a source test on each MHD furnace at startup and on alternating MHD furnaces once every five years during full operation using EPA RM 7E for NOx and RM 3A for Oxygen as per 40 CFR Part 60, Appendix A, or another EPA approved method. Intalco shall comply with Condition E20 and H14.

DE 02

E 20 Functional 

Integrity

Inspection Intalco shall conduct a weekly functional integrity inspection

of the furnaces that, at a minimum, includes a visual checkfor visible emissions. Intalco shall record the observations inthe emission unit’s inspection log. If visible emissions arepresent or another problem is observed, Intalco shall takecorrective action as soon as practical but within 24 hours.Intalco shall record the results of corrective actions taken inthe inspection log. Taking a corrective action shall include butnot be limited to preparing a work order, ordering parts,shutting down the unit, or completing the repair thateliminates the respective problem. Corrective actions shall betaken by employees or contractors designated by Intalco. 

DE 02

220a, 220b, 221a, 

221b MHD Holding 

Furnaces (51,000 

acfm)

II E METAL PRODUCTS (continued)

Page # 22 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 21 Dross storage Intalco shall limit storage of dross to only the 

casthouse building extension.

 Intalco shall comply with Condition E23. 

E 22 Opacity Opacity shall not exceed 5% for more than six 

minutes in any sixty minute period.

Intalco shall conduct source tests upon Ecology’s requestusing EPA RM 22 per 40 CFR 60, Appendix A, or anotherEPA approved method. Intalco shall comply with ConditionsH1 and E23.

E 23 Functional 

Integrity

Inspection Intalco shall conduct a weekly functional integrity inspection 

of the system that, at a minimum, includes a visual check for visible emissions. Intalco shall record the observations of the parameters assessed in the inspection log. Any time visible emissions are present, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log.

E 24 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall determine and demonstrate compliance with the emission limit by using natural gas consumption to calculate particulate emissions. Intalco shall calculate worst-case particulate emissions by using an AP-42 emission factor (7.6 pounds PM10/1e+6 cubic feet of natural gas from Section 1.4, 

Small Industrial Boilers) for particulate generated from natural gas combustion, the volume of natural gas combusted by the furnace, and the furnace design excess air settings. Intalco shall report the PM emissions from the furnace in the respective monthly air monitoring report submitted to Ecology. Intalco shall comply with Conditions H1 and E28.

WAC 173-40(Reco

401-63Comp

E 25 Opacity Opacity shall not exceed 5% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.b, and E28. DE 02

E 26 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with condition H 1 and H8. WAC 

E 27 NOx Emissions of NOx shall not exceed 83 ppm 

corrected to 3% oxygen 

Intalco shall conduct an annual source test on the furnace during full operation using EPA RM 7E for NOx and RM 3A for Oxygen as per 40 CFR Part 60, Appendix A, or another EPA approved method. Intalco shall comply with Condition E27 and H14. Intalco can reduce the frequency of source testing to once every 5 years if condition H6 is met. 

DE 02

E28 Functional 

Integrity

Inspection Intalco shall conduct a weekly functional integrity inspection 

of the furnace that, at a minimum, includes a visual check for visible emissions. Intalco shall record the observations of the parameters assessed in the inspection log. Any time visible emissions are present, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log.

DE 02

271 Inert Dross Cooling Order 

and Handling System 

314 Homogenization 

Furnace 

II E METAL PRODUCTS (continued)

Page # 23 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 29 PM Emissions of PM shall not exceed 0.005 

grains/dscf.

Intalco shall conduct a source test upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall comply with Conditions H1, E31, and H14.

DE 02

E 30 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and E31. See C

E 31 Functional 

Integrity

Inspection Intalco shall conduct a weekly functional integrity inspection 

of the baghouse, that, at a minimum, includes a visual check of the following parameters: visible emissions, leaks in ductwork and housing, excess vibration, and pressure drop. Intalco shall record the observations of the parameters assessed in the inspection log. Any time visible emissions are present, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log.

DE 02

Remelt Furnace 217; Holding Furnaces: 4, 5, 7, 8, 10, 11, 13, 14, 16, 17, 18, and 19; and the MHD Holding Furnaces: 220a, 220b, 221a, 221b 

E 32 PM and HCL For a group 1 furnace that is not a 

melting/holding furnace processing only clean charge, emissions of PM shall not exceed: 0.20 kg of PM per Mg (0.40 lb of PM per ton) of feed/charge. For a group 1 furnace that is not a melting/holding furnace processing purchased scrap charge, emissions of HCl shall not exceed: 0.20 kg of HCl per Mg (0.40 lb of HCl per ton) of feed/charge. 

40CFR 63.15063.15063.15063.1563.1563.1563.1563.1563.1563.15

E 33 Dioxin/Furan 

(D/F)

For a group 1 furnace that is not a melting/holding furnace processing purchased scrap charge, Intalco must not exceed: 15 μg of D/F TEQ per Mg.

40CFR40CFRPart 6

E34 Scrap 

Inspection 

Program 

Intalco shall comply with the Scrap Inspection Program outlined in Intalco's OM&M plan. 

Intalco shall comply with the Scrap Inspection Program outlined in Intalco's OM&M plan. 

40CFR 

Remelt Furnace 217

315 Dross/Silicon 

Storage Baghouse 

(55,000 acfm)

II E METAL PRODUCTS (continued)

Intalco shall determine compliance with the PM, HCl, and D/F emission limits for individual furnaces. Intalco shall submit a site-specific test plan meeting the requirements of 40 CFR 63.6 and conduct a performance test once every five years using the procedures in the approved site specific test plan to demonstrate compliance with applicable emission limits. Intalco shall use equation 7 in 40 CFR Part 63.1513(b) to determine compliance with the emission limits for PM, HCl,and D/F. 

Conditions E32 through E55 incorporate MACT requirements published in Federal Register, March 23, 2000.

Page # 24 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 35 Solid Reactive 

Flux

Intalco shall use solid reactive flux in the holding furnaces only.

Intalco shall measure and record the weight and time of solid reactive flux addition to the holding furnaces

40CFR 

Intalco must, for each group 1 furnace (including a group 1 furnace that is part of a secondary aluminum processing unit) without add-on air pollution control devices: 1) Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the performance test at or below the average rate established during the performance test. 2) Operate each furnace in accordance with the work practice/pollution prevention measures documented in the OM&M plan and within the parameter values or ranges established in the current version of the OM&M plan.

Intalco must, for each group 1 furnace (including a group 1 furnace that is part of a secondary aluminum processing unit) without add-on air pollution control devices: 1) Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the performance test at or below the average rate established during the performance test. 2) Operate each furnace in accordance with the work practice/pollution prevention measures documented in the OM&M plan and within the parameter values or ranges established in the current version of the OM&M plan.

3) Operate each group 1 melting/holding furnace subject to the emission standards in §63.1505(i)(2) using only clean charge as the feedstock.

3) Operate each group 1 melting/holding furnace subject to the emission standards in §63.1505(i)(2) using only clean charge as the feedstock.

E37 Clean charge 

certification for Group 1 furnace subject to the emission standards in §63.1505(i)(2) using only clean charge as feedstock 

Intalco shall submit a certification of compliance with the applicable operational standard for clean charge materials in §63.1506(n)(3) for each 6-month reporting period. Each certification must contain the information in §63.1516(b)(2)(iv). 

II E METAL PRODUCTS (continued)

E 36 Operation and 

Maintenance of 

Group 1 

Furnaces 

without Add-On 

Control Devices

40CFR

Holding Furnaces: 4, 5, 

7, 8, 10, 11, 13, 14, 16, 

17, 18, and 19

Page # 25 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 38 PM For an in-line fluxer that uses reactive flux 

material, Intalco shall not exceed: 0.005 kg of PM per Mg (0.01 lb of PM per ton) of feed/charge.

40CFR Part 6

E 39 HCl For an in-line fluxer that uses reactive flux 

material, Intalco must not exceed: 0.02 kg of HCl per Mg (0.04 lb of HCl per ton) of feed/charge.

40CFR

E 40 Inline Fluxer 

Compliance

Intalco shall determine compliance with the PM and HCl emission limits for in-line fluxers.

Intalco shall measure the rate of reactive gas flux addition to the in-line fluxer and assume that all reactive flux added to the in-line fluxer is emitted as HCl.

40CFR

E41 Reactive Flux 

Use

Intalco shall use reactive gas flux in the in-line fluxers only.

Intalco shall record and report any reactive gas flux used in inline fluxers.

E42 Chlorine Flux 

Injection Rate

Intalco shall continuously measure and record the weight of gaseous reactive flux injected for each 15 minute period, determine and record the 15-minute block average weights, and calculate and record the total weight of the gaseous reactive flux in the in-line fluxers.

40 CF

II E METAL PRODUCTS (continued)

Intalco shall assume that all chlorine added to the in-line fluxers is converted to HCl and 1000 pounds of PM are assumed to be emitted for every ton of chlorine gas added to the in-line fluxers (per Compilation of Air Pollutant Emission Factors, AP-42, fifth Edition, Volume 1 (Stationary Point and Area Sources) Section 12.8: Secondary Aluminum Operations.)" Intalco shall comply with procedures and conditions in the approved OM&M Plan to demonstrate compliance with applicable emission limits.

6 In-fluxers in Casting 

Pits 1-6

Page # 26 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

Intalco must provide and maintain easily visible labels posted at each group 1 furnace, group 2 furnace and in-line fluxer as described in 40 CFR 63.1515(b)(3) that identifies the applicable emission limits and means of compliance, including:

Intalco must inspect the labels for each group 1 furnace, group 2 furnace and in-line fluxer at least once per calendar month to confirm that posted labels as required by the operational standard in §63.1506(b) are intact and legible. 

40CFR40CFR40CFR

(1) The type of affected source or emission unit (e.g., group 1 furnace, group 2 furnace, in-line fluxer).(2) The applicable operational standard(s) and control method(s) (work practice or control device). This includes, but is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials and addition practices, and the applicable operating parameter ranges and requirements as incorporated in the OM&M plan.For each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of feed/charge, Intalco shall: (1) Install and operate a device that measures and records or otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the performance test (except as provided in paragraph (3) of this Requirement); (2) Operate each weight measurement system or other weight determination procedure in accordance with the current version of the OM&M plan; (3) Intalco may choose to measure and record aluminum production weight from an affected source or emission unit rather than feed/charge weight to an affected source or emission unit, provided that (i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission units within a SAPU; and (ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum 

For each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or ug/Mg (gr/ton) of feed/charge Intalco must install, calibrate, operate, and maintain a device to measure and record the total weight of feed/charge to, or the aluminum production from, the affected source or emission unit over the same operating cycle or time period used in the performance test. Feed/charge or aluminum production within SAPUs must be measured and recorded on an emission unit-by-emission unit basis. (1) The accuracy of the weight measurement device or procedure must be +/-1 percent of the weight being measured. The owner or operator may apply to the permitting agency for approval to use a device of alternative accuracy if the accuracy cannot be achieved as a result of equipment layout or charging practices. A device of alternative accuracy will not be approved unless the owner or operator provides assurance through data and information that the affected source will meet the relevant emission standard.

production weight rather than feed/charge weight.

(2) Intalco must verify the calibration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

E44 Production 

Weight

40CFR

Remelt Furnace 217, E 43 LabelingHolding Furnaces: 4, 5, 7, 8, 10, 11, 13, 14, 16, 17, 18, 19 MHD Furnaces 6 In-fluxers in Casting Pits 1-6II E METAL PRODUCTS (continued)

Page # 27 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 45 Corrective 

Action

Intalco shall take corrective action, when a process parameter deviates from the value or range established during the performance test and incorporated in the current approved OM&M plan, as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must include the follow-up actions necessary to return the process or control device parameter level(s) to the value or range of values established during the performance test and steps to prevent the likely recurrence of the cause of a deviation. Intalco shall comply with the corrective action procedures in the current Ecology approved OM&M Plan.

40CFR

E 46 Operation, 

Maintenance, 

and Monitoring 

(OM&M) Plan

Intalco shall comply with the provisions of the current approved OM&M plan and update the OM&M plan as necessary for each affected source and emission unit. 

40CFR

1) The monitoring system must record the weight for each 15-minute block period, during which reactive fluxing occurs, over the same operating cycle or time period used in the performance test. 2) Intalco shall assure that the accuracy of the weight measurement device is +/-1 percent of the weight being measured by using the following. a) solid flux vendor certification that the weight of solid flux in each package has been measured to an accuracy of +/- 1% as an alternative measurement system (Ecology approved). and b) a reactive gas flux flow monitor with an accuracy of +/-1% of the full scale of the measuring device as an alternative to +/-1% accuracy of the actual flow measurement (Ecology approved).3) Intalco shall verify the calibration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration is specified, at least once every six months. 4) Intalco shall, for each operating cycle or time period used in the performance test, calculate and record the gaseous or solid reactive flux injection rate using the procedure in 40 CFR Part 63.1512(o) or an EPA approved alternative as authorized in 40 CFR 63.1510(j)(5)).5) Intalco shall record, for each 15-minute block period during each operating cycle or time period used in the performance test during which reactive fluxing occurs, the time, weight, and type of flux for each addition of: (i) Gaseous or solid reactive flux other than chlorine; and (ii) Solid reactive flux.

II E METAL PRODUCTS (continued)

Weight 

measurement 

device (this 

condition does 

not apply to the 

remelt furnace).

Intalco shall operate and maintain a device to 

continuously measure and record the weight of 

gaseous or solid reactive flux injected to each 

affected source or emission unit.

E 47 

Remelt Furnace 217, Holding Furnaces: 4, 5, 7, 8, 10, 11, 13, 14, 16, 17, 18, 19 6 In-fluxers in Casting Pits 1-6

Page # 28 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E 48 Test Methods Intalco shall use following EPA methods (from appendix A of 

40 CFR part 60) or EPA approved alternatives to determine compliance with the applicable emission limits or standards: (1) Method 1 for sample and velocity traverses. (2) Method 2 for velocity and volumetric flow rate. (3) Method 3 for gas analysis.(4) Method 4 for moisture content of the stack gas. (5) Method 5 for the concentration of PM. ( 6) Method 9 for visible emission observations. (7) Method 23 for the concentration of dioxins and furans. (8) Method 25A for the concentration of THC (see definition in the glossary), as propane.

40

E 49 Compliance 

Information

If the group 1 furnace processes only clean charge, Intalco must conduct emission tests to simultaneously measure emissions of PM and HCl at the furnace exhaust outlet. Each test must be conducted while the group 1 furnace (including a melting/holding furnace) processes only clean charge. Intalco may choose to determine the rate of reactive flux addition to the group 1 furnace and assume, for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added to the group 1 furnace is emitted. Under these circumstances, the owner or operator is not required to conduct an emission test for HCl.

Intalco shall demonstrate compliance in accordance with the site specific monitoring plan submitted per §63.1510(o). 

4

E 50 Startup, 

Shutdown, and 

Malfunction 

Reports

 Intalco shall record and report if an action taken during a 

startup, shutdown, or malfunction is not consistent with the procedures in the current version of the SS&M Plan as described in §63.6(e)(3). 

40 CF

II E METAL PRODUCTS (continued)

Remelt Furnace 217, 

Holding Furnaces: 4, 5, 

7, 8, 10, 11, 13, 14, 16, 

17, 18, 19 

6 In-fluxers in Casting 

Pits 1-6 E = P Page # 29 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

Intalco shall submit semiannial reports within 60 days after the end of each 6-month reporting period. Each report shall contain the information specified in 40 CFR 63.10(c). When no deviations of parmaeters have occured, Intalco shall submit a report stating that no excess emissions occcurred during the reporting period. Intalco shall sumit an excess emissions report if any of the following occur during a 6-month reporting period: 1) An excursion of a compliant process or operating parameter value or range (e.g. total reactive chlorine flux injection rate, definition of acceptable scrap, or other approved operating parameter). 2) An action taken during a startup, shutdown, or malfunction was not consistent with the procedures in the plan as described in §63.6(e)(3). 3) An affected source was not operated according to the requirements of this subpart. Intalco shall submit semiannual reports within 60 days after the end of each 6-month period. Intalco shall submit the information specified in §63.10(c). When no deviationsof parameters have occurred, Intalco shall state in the semiannual report that no excess emissions occurred during the reporting period.

E52 (in-line 

fluxers are not 

subject to this 

condition)

Certifications Intalco shall include in each report each of these 

certifications, as applicable: (iv) For each group 1 holding furnace: ``Each group 1 furnace without add-on air pollution control devices subject to emission limits in Sec. 63.1505(i)(2) processed only clean charge during this reporting period." (v) For each group 2 furnace: ``Only clean charge materials were processed in any group 2 furnace during this reporting period, and no fluxing was performed or all fluxing performed was conducted using only nonreactive, non-HAP-containing/non-HAP-generating fluxing gases or agents, except for cover fluxes, during this reporting period.''

40 CFand (v

E53 (in-line 

fluxers are not 

subject to this 

condition)

Performance 

tests

Intalco shall submit the results of any performance test conducted during the reporting period, including one complete report documenting test methods and procedures, process operation, and monitoring parameter ranges or values for each test method used for a particular type of emission point tested.

40 CF

Remelt Furnace 217, 

Holding Furnaces: 4, 5, 

7, 8, 10, 11, 13, 14, 16, 

17, 18, 19 

6 In-fluxers in Casting 

Pits 1-6

Semiannual 

Reports and 

Excess 

Emissions 

Reports

40 CF

C

E 51

II E METAL PRODUCTS (continued)

Page # 30 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

E54 Annual 

Compliance 

Certification

Intalco shall certify continuing compliance based upon the following conditions:(1) Any period of excess emissions, as defined in 40CFR Part 63.1516(b)(1), that occurred during the year were reported as required by this subpart; and (2) All monitoring, recordkeeping, and reporting requirements were met during the year in an annual compliance certification submitted to Ecology no later than January 31 of the following year. 

40 

E55 Records Intalco shall maintain records in accordance with §63.10(b) 

for at least 5 years. 

40 CFCFR PCFR PCFR PCFR PCFR PCFR PCFR PCFR PCFR P

Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

F1 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.e and F23. See C

F2 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a and F23. See C

F3 SO2 SO2 concentration shall not exceed 1000 ppm 

corrected to 7% oxygen based on the average of any period of 60 consecutive minutes.

Intalco shall comply with condition H 1, H 8 and F23. WAC 

F4 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.e and F23. See C

F5 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F24. See C

F6 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g and F24. See C

F7 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3, and F24. See C

207 Annex Paste Plant 

Baghouse Stack (5,550 

acfm)

II E METAL PRODUCTS (continued)

195 Primary WTP Kiln 

Wet Scrubber (2,700 

acfm) 

Remelt Furnace 217, 

Holding Furnaces: 4, 5, 

7, 8, 10, 11, 13, 14, 16, 

17, 18, 19 

6 In-fluxers in Casting 

Pits 1-6

II F ANCILLARY 

208 Ladle Cleaning 

Baghouse (14,100 

acfm)

Page # 31 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

F8 PM Emissions of PM shall not exceed 5.0 tons of 

PM per year.

Order 

F9 PM Emissions of PM shall not exceed 0.01 grains 

per dscf.

Order 

F10 Opacity Opacity shall not exceed 5% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.b, and F12. Order 

F11 TF Emissions of TF shall not exceed 2.7 tons per 

year.

Intalco shall conduct source tests once every 5 years and upon Ecology’s request using EPA RM 5/13B as per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall comply with condition F12.

O

F12 Functional 

Integrity 

Inspection Intalco shall conduct a weekly functional integrity inspection 

of the baghouse, that, at a minimum, includes a visual check of the following parameters: visible emissions, leaks in ductwork and housing, excess vibration, and pressure drop. Intalco shall record the observations of the parameters assessed in the inspection log. Any time visible emissions are present, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log.

Order 

209 Autogenous Mill 

Baghouse 

(45,000 acfm)

II F ANCILLARY (continued)

Intalco shall conduct a source once every 5 years and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall include the results of the source test in the respective monthly air monitoring report submitted to Ecology. Intalco shall comply with Condition F12.

Page # 32 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

F13 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and F24. WAC 

401-6and W(GeneRequi

F14 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F24. See C

F15 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and F24. Same 

F13.

F16 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F24. See C

F17 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and F24. Same 

F13.

F18 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F24. See C

F19 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g and F24. See C

F20 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F24. See C

F21 PM Emissions of PM shall not exceed 0.1 

grains/dscf.

Intalco shall comply with Conditions H1, H2.g, and F25. Same 

F13.

F22 Opacity Opacity shall not exceed 20% for more than six 

minutes in any sixty minute period.

Intalco shall comply with Conditions H1, H3.a, and F25. See C

195 Primary Waste 

Treatment Plant 

(PWTP) Kiln Wet 

Scrubber

F23 Intalco shall comply with Condition H4.g See C

Emission Units #'s: 

207, 208, 209, 210, 

214, 216, 229 and 274

F24 Intalco shall comply with Condition H4.a See C

Emission Unit #: 280 F25 Intalco shall comply with condition H4.c. See C

308 Paint Shop G1 VOC Recordkeeping Intalco shall track VOC usage through purchase records or 

other methods approved by Ecology. Intalco shall report annual VOC usage in the December Air Monitoring Report submitted to Ecology.

WAC WAC (Perio401-6and W(GeneRequi

216 Alumina Ore Ship 

Unloading Baghouse 

Stack (15,000 acfm)

229 Brick Crushing 

Facility Baghouse Stack 

(20,000 acfm)

280 Annex Cathode 

Assembly Area Roof 

Vents

274 Alumina Silo #4 

Truck Loader 

Baghouse Stack (5,000 

acfm)

Functional 

Integrity

II F ANCILLARY (continued)

Inspection

214 Alumina Ore Silo 

#4 Rail Car Unloader 

Baghouse Stack 

(19,600 acfm)

II G MAINTENANCE

Page # 33 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

All emission units and control systems on Intalco’s facility

H1 Operation and 

Maintenance (O&M) 

At all times, including periods of abnormal operation and upset, Intalco shall, to the extent practicable, maintain the facility, and operate and maintain air pollution control equipment in a manner consistent with good air pollution control practice. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to Ecology which may include, but is not limited to, monitoring results, opacity observations, visible emission observations, inspections of the source, and reviews to determine that the plant is following its O & M procedures.

Intalco shall comply with applicable PM and Opacity monitoring requirements in the respective unit specific conditions and the applicable Functional Integrity Inspection requirements in Condition H4 for the affected emission unit or emission control. 

WAC WAC (Perio401-6and W(GeneRequi

H2.a Intalco shall conduct a source test annually and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall submit the results of the source test in the respective monthly air monitoring report submitted to Ecology per Condition H14.

WAC 

3/22/

W

(Perio

401-6

and 

(

H2.b Intalco shall conduct a source test once every two years and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method . Intalco shall submit the results of the source test in the respective monthly air monitoring report submitted to Ecology per Condition H14. 

Order WAC 3/22/9on 8/2WAC (Perio401-6and W(GeneRequi

H2.c Intalco shall conduct a source test once every two years and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method . Intalco shall submit the results of the source test in the respective monthly air monitoring report submitted to Ecology per Condition H14. 

Same H2.a.

H2.d Intalco shall conduct a source test every two years on alternating holding furnaces during full operation and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall submit the results of the source tests in the respective monthly air monitoring report submitted to Ecology per Condition H14. 

Same H2.a.

Emission units that are 

subject to grainloading 

requirments 

PM

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

H2 PM Limit (see individual emission unit for the 

limit). 

Page # 34 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

H2.e Intalco shall conduct a source test once every 5 years and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall submit the results of the source test in the respective monthly air monitoring report submitted to Ecology per Condition H14.

Same H2.a.

H2.f Intalco shall conduct a source test on each MHD furnace after each furnace is put back into operation and then conduct source tests once every five years on alternating MHD furnaces during full operation and upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall submit the results of the source tests in the respective monthly air monitoring report submitted to Ecology per Condition H14. 

Same H2.a.

H2.g Intalco shall conduct a source test upon Ecology’s request using EPA RM 5 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall submit the results of the source test in the respective monthly air monitoring report submitted to Ecology per Condition H14.

Same H2.a.

Opacity shall not exceed an average of 20% for more than six consecutive minutes in any sixty minute period.

H3.a Intalco shall conduct source tests upon Ecology’s request using EPA RM 9 per 40 CFR 60, Appendix A, or another EPA approved method. If visible emissions are observed at any time, Intalco shall comply with Condition H5. 

WAC [appro2/19/93/22/9WAC 

401-6Monito615(2WAC Comp

Opacity shall not exceed an average of 5% for more than six consecutive minutes in any sixty minute period.

H3.b Intalco shall conduct source tests upon Ecology’s request using EPA RM 9 per 40 CFR 60, Appendix A, or another EPA approved method. If visible emissions are observed at any time, Intalco shall comply with Condition H5. 

Order 

H4.a Intalco shall conduct a weekly functional integrity inspection of the baghouse, that, at a minimum, includes a visual check of the following parameters: visible emissions, leaks in ductwork and housing, excess vibration, and pressure drop. Intalco shall comply with Condition H5. 

WAC (Perio401-6and W(GeneRequi

H4.b Intalco shall continuously monitor coke and air flow in accordance with 40 CFR 63.848(f)(1) and conduct a daily visible emission check and a weekly functional integrity inspection that, at a minimum, includes a visual check of the following parameters: visible emissions, leaks, pump outlet pressure, and amperage to recirculation pumps. Intalco shall comply with Condition H5.

Order 

H4.c Intalco shall conduct a weekly functional integrity inspection of the vents that, at a minimum, includes a visual check of visible emissions. Intalco shall comply with Condition H5.

Same H4.a

Emission units subject Opacity 

to an opacity limit

H3

PM (continued)

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

Emission units that are 

subject to grainloading 

requirments 

H2 (continued)

Emission units that are 

subject to a functional 

integrity inspection

H4 Functional 

Integrity (FI)

Inspection

Page # 35 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

H4.d Intalco shall conduct a daily functional integrity inspection of the potroom baghouses that, at a minimum, includes a visual check of the following parameters: visible emissions, leaks in ductwork and housing, excess vibration, pressure drop, and sight glass readings. Intalco shall comply with Condition H5. 

Order 

H4.e Intalco shall conduct a weekly functional integrity inspection of all the pot hoods. During that inspection, Intalco shall classify the condition of each hood as good, fair, or poor. Intalco shall direct hood repair crews to begin the repair process for the poor condition hoods during their first shift after the inspection. Hoods classified as fair shall be repaired within 15 days. Intalco shall conduct a daily functional integrity inspection of the potroom wet scrubbers that, at a minimum, includes a visual check of the following parameters: visible emissions (per 40 CFR 63.848(g) Primary Aluminum MACT), processing adequate volumes of water and air (per Condition 40 CFR 60.848(f)(5)(Primary Aluminum MACT)). Intalco shall comply with Condition H5.

Order 

H4.f Intalco shall conduct a weekly functional integrity inspection of the furnaces that, at a minimum, includes a visual check of visible emissions. Intalco shall comply with Condition H5.

Same H4.a

H4.g Intalco shall conduct a weekly functional integrity inspection of the PWTP kiln wet scrubber that, at a minimum, includes a visual check of the following parameters: visible emissions, processing adequate volumes of water and air. Intalco shall comply with Condition H5.

Same H4.a

H4.h Intalco shall conduct a weekly functional integrity inspection of the baghouse that , at a minimum, includes a visual check of the following parameters: visible emissions, leaks in ductwork and housing, and excess vibration. Intalco shall comply with Condition H5.

Same H4.a

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) Emission units subject to a functional integrity inspection

H4 (continued) FI (continued) Inspection (continued) 

Page # 36 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

All emission units and 

control systems subject 

to an opacity limit and 

those subject to 

functional integrity 

inspections.

H5 Recording 

Inspections and taking Corrective actions

Recording Inspections and taking Corrective actions

Intalco shall record the observations and readings of the parameters assessed (e.g., amperage to recirculation pumps on the PFTS) in the emission unit’s inspection log. If visible emissions are present or another problem is observed, Intalco shall take corrective action as soon as practical but within 24 hours. Intalco shall record the results of corrective actions taken in the inspection log. Taking a corrective action shall include but not be limited to preparing a work order, ordering parts, shutting down the unit, or completing the repair that eliminates the respective problem. Corrective actions shall be taken by employees or contractors designated by Intalco. 

WAC (Perio401-6and W(GeneRequi

Emission units subject 

to source testing 

requirments to 

determine compliance with an emission limit.

H6 Monitoring 

Frequency Reduction

Monitoring Frequency Reduction Intalco can reduce monitoring frequencies to the frequencies 

defined in the respective unit specific conditions 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 shall 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. Intalco shall submit the notification to Ecology within 60 days after the last source test used to make the demonstration.

WAC (Perio401-6and W(GeneRequi

a. Intalco shall conduct source tests upon Ecology’s request using EPA RM 6 per 40 CFR 60, Appendix A, or another EPA approved method. b. Intalco shall determine total facility-wide SO2 emissions by summing the SO2 generated from the potlines and the anode bake ovens. Intalco shall calculate SO2 emissions from the potlines, anode bake ovens, and paste plant by using the mass balance calculation in Condition D16 (using the daily aluminum production rate and average sulfur content for the month being evaluated). Intalco shall assume, in the mass balance calculation, that 100% of the sulfur in coke and raw materials converts to SO2. Intalco shall calculate the SO2 generated by natural gas combustion using an Ecology approved emission factor as described in Condition H13.

W

WAC 

40

Mon

615(2

WAC 

Com

c. Intalco shall report the aluminum production; SO2 

emissions in pounds per ton of aluminum produced, the sulfur content of the coke and pitch, raw material usage, representative raw material sulfur analysis and any exceedences of the SO2 limits in the monthly air monitoring 

reports submitted to Ecology. d. Intalco shall maintain electronic records of aluminum production, SO2 emissions in pounds per ton of aluminum produced, the sulfur content of the coke and pitch, raw material usage, and representative raw material sulfur analysis of raw material usage for a minimum of 5 years. 

247 Plantwide Sulfur 

Dioxide Emissions 

(generation points are 

the aluminum reduction 

pots, anode bake 

ovens, green carbon 

heaters and mixers, 

emergency generators, 

and natural gas 

combustion units)

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

H7 Total emissions of SO SO2 2 from all emissions units 

shall not exceed thirty grams of sulfur dioxide per kilogram of aluminum produced on a monthly average (sixty pounds per ton of aluminum produced).

Page # 37 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

All emission units 

subject to the 1000 

ppm limit in WAC 173-

400-040(6) and WAC 

173-415-030(5)(b)

H8 SO2 Intalco shall not cause or permit the emission of 

a gas containing sulfur dioxide in excess of one thousand parts per million corrected to dry standard conditions for an hourly average.

 Intalco shall conduct source tests upon Ecology’s request using EPA RM 6 per 40 CFR 60, Appendix A, or another EPA approved method. Intalco shall comply with condition H7. 

WAC WAC 

401-6Monito615(2WAC Comp

Intalco shall: a. Intalco shall continue to monitor ambient fluoride at the monitoring station identified as station #2 continuously for 24 hours a day every day of the year in accordance with the Fluoride Ambient Monitoring procedures outlined in Intalco’s approved Air Monitoring Plan. Station #2 is located at Latitude 48 degrees 50 minutes 44 seconds and Longitude 122 degrees 41 minutes 35 seconds (approximately 1.05 miles East Northeast of the center of the potlines). Intalco will keep stations 1 and 5 in place. Ambient fluoride monitoring is not required at stations 1 and 5. b. . Intalco shall continue monitoring ambient fluoride at the ambient monitoring station for a minimum period of 60 days after a shutdown of all potlines.c.Intalco shall report the data collected from the ambient monitoring station in the respective monthly air reports submitted to Ecology. Intalco shall report the ambient data in a format that will allow a comparison of the data to the ambient fluoride standards in WAC 173-481-110 (2)(a) through 2(e). d. . Intalco shall determine the mass of gaseous fluoride emitted per day (pounds/day) from the facility (averaged on a monthly basis). Intalco shall report the average pounds of gaseous fluoride emitted from the facility per day in the respective monthly air monitoring report submitted to Ecology. 

e. Intalco shall follow the approved forage sampling and analysis plan in Intalco’s approved Air Monitoring Plan.f. Intalco shall continue forage monitoring (per Condition H9.e) through the end of the growing season if a shutdown occurs during the growing season. g. Intalco shall report the forage data collected (in accordance with the Forage Sampling Plan in Intalco’s approved Air Monitoring Plan) in the respective monthly air monitoring reports submitted to Ecology. Intalco shall report the data in a format that will allow a comparison of the forage data to the forage standards in WAC 173-481-100 (2)(a) through 2(c). 

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

H9 Fluoride 

emissions. 

(State Only)

The emissions of gaseous fluoride and the 

forage fluoride content shall not exceed the 

respective ambient and forage fluoride 

standards in WAC 173-481-110 (2) (a) through 

(e) and WAC 173-481-100 (2)(a) through 2(c). 

Ord

WAC 

Emission Units 4, 5, 7, 

8, 10, 11, 13, 14, 16, 

17, 18, 19, 22-180, 181-

186, 187, 195, 198, 

199, 209, 210, 220a,b, 221a,b, 240, 251, 251, 

253, 257a,b, 259a,b, 

295, 296, 316 

Page # 38 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

h. Intalco shall maintain electronic records of the data collected for compliance with the conditions above for a minimum of 5 years. i. Ecology may impose additional requirements if Intalco’s gaseous fluoride or forage monitoring results exceed the standards in WAC 173-481. j. Intalco shall develop and submit to Ecology a draft Air Monitoring Plan containing the procedures for ambient fluoride and forage fluoride content monitoring outlined in the conditions H9.a - H9.h above for review within 60 days of issuance of this order. Ecology shall provide comment and approve a plan that meets the requirements of this order within 60 days of receipt of the plan. Intalco shall implement all requirements of the plan within 60 days of Ecology’s approval. Prior to implementing any changes to the procedures outlined in the approved Air Monitoring Plan, Intalco shall submit a written request and receive Ecology’s approval for the changes. Intalco shall develop and submit to Ecology an updated Air Monitoring Plan containing the procedures for ambient fluoride and fluoride forage monitoring outlined in the conditions above within 60 days of issuance of this order for review and approval. Intalco shall implement all requirements of the plan within 60 days of Ecology’s approval. Prior to implementing any changes to the procedures outlined in the approved AirMonitoring Plan. Intalco shall submit a written request and receive Ecology’s approval for the changes. 

235 Plantwide Usage 

of VOC Containing 

Products

H10 VOC Recordkeeping and Reporting Intalco shall track VOC usage through purchase records. 

Intalco shall report VOC usage annually in the December Air Monitoring Report per Condition H14.

WAC-

239 (Fugitive Dust from 

Vehicle Traffic on Paved 

Roads); 240, 295, and 296

(Landfill Fugitive 

Emissions); 252 (Anode 

Block Hole Blower); 

257a&b (Crust Recovery 

Discharge to Truck from 

Bins 1& 2); 

 259a&b (Carbon 

Recovery Discharge to 

Truck from Bins 1 & 2); 

275 (Aluminum 

Fluoride/Anthracite Railcar

Unloading Fugitive Dust); 

276 (Coke Unloading and 

Transfer Fugitive Dust); 

306 (Alumina Ore Ship 

Unloader Clamshell); 312 

(Rod Shop Induction 

Furnace (East))

313 (Rod Shop Induction 

Furnace (West)).

Emission Units 4, 5, 7, 

8, 10, 11, 13, 14, 16, 

17, 18, 19, 22-180, 181-

186, 187, 195, 198, 

199, 209, 210, 220a,b, 221a,b, 240, 251, 251, 

253, 257a,b, 259a,b, 

295, 296, 316 

(continued) 

H9 Fluoride 

emissions. 

(State Only) 

continued

For each of the emission units identified in column 1 of this condition, Intalco shall comply with the reasonable available control technology (RACT) requirements identified in Intalco's Air Monitoring Plan per Condition H15. H11.a For emission unit number 306 (Alumina Ore Ship Unloader Clamshell), Intalco shall limit alumina ore unloading activities to periods when sustained winds are less than 35 mph averaged over a period of 30 minutes.

H11 Fugitive 

Emissions

Intalco shall use RACT to prevent fugitive 

emissions.

W

W

Ord

WAC 

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

Page # 39 of 45 Alcoa Intalco Works Final Air Operating Permit 
Emission Unit Condition No. Pollutant 

/Parameter

Requirement Monitoring, Reporting and Record-keeping 

H12 Natural Gas 

Consumption

Intalco shall maintain electronic records of daily natural gas consumption. Intalco shall report natural gas usage in the monthly Air Monitoring Report per Condition H14.

WAC 

H13 SO2 SO2 emissions from natural gas combustion 

shall not contribute to an exceedance of the facility wide SO2 limit in condition H7.

Intalco shall include SO2 emissions from natural gas 

combustion to demonstrate compliance with the SO2 limit in 

Condition H7. Intalco shall use an Ecology approved natural gas emission factor for SO2 emissions.

WAC WAC (Perio401-6and W(GeneRequi

All emission units 

having reporting 

requirements

H14 Monthly Air 

Monitoring 

Report 

Intalco shall submit a monthly air monitoring report which contains the respective results of the monitoring required in the conditions of this permit. The report shall be submitted within 30 days of the end of each calendar month. Intalco shall report the data in a format that will allow a comparison of all the data to the respective emission limits. The format shall include a table which summarizes the required source tests conducted during that month and the dates when they were completed. Intalco shall submit the results of source tests to Ecology in the air monitoring report for the month that the results are received by Intalco. Ecology will review the format of the first monthly report submitted after final issuance of this AOP and propose recommendations for revisions if necessary.

WAC WAC (Perio401-6and W(GeneRequi

All emission units with 

monitoring 

requirements

H15 Air Monitoring 

Plan 

Intalco shall update their Air Monitoring Plan (Plan) to include the sampling and source testing procedures and testing frequencies that will be used to determine and demonstrate compliance with the emission limits (including ambient fluoride and fluoride content in forage and Primary and Secondary MACT) in the respective conditions of this AOP. The Plan shall include a section which identifies the individual sources of fugitive emissions (identified in Condition H11) and the RACT procedures that will be used to assure compliance with WAC173-415-030(4). Intalco shall submit the Plan to Ecology within 90 days of final issuance of this 

AOP for review and approval. Ecology shall approve the plan 

within 60 days of receipt of the Plan. 

WAC WAC (Perio401-6and W(GeneRequi

II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued) 

241 Plantwide Natural 

Gas Combustion 

Emissions

Page # 40 of 45 Alcoa Intalco Works Final Air Operating Permit 
III.1. Duty to comply WAC 

III.2. Need to halt or 

reduce activity not a defense

WAC 

III.3. Permit actions WAC III.4. Property rights WAC III.5. Duty to Provide 

Information

WAC 

III.6. Permit fees WAC III.7 Emissions 

Trading

WAC 

III.8 Severability 

Clause

WAC 

III.9 Permit Appeals WAC III.10 Permit 

Continuation

WAC 

III.11 Federally 

Enforceable Requirements

WAC 

III.13 Tampering and 

False Statements

WAC and 40 

The permittee shall furnish to the permitting authority, within a reasonable time, any information that the permitting authority 

may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to

determine compliance with the permit. Upon request, the permittee shall also furnish to the permitting authority copies of records required to be kept by the permit or, for information claimed to be confidential, the permittee may furnish such records 

directly to the EPA Administrator along with a claim of confidentiality. Permitting authorities shall maintain confidentiality of such information in accordance with RCW 70.94.205.The permittee shall pay fees as a condition of this permit in accordance with Ecology’s fee schedule. Failure to pay fees in a

timely fashion shall subject the permittee to civil and criminal penalties as prescribed in chapter 70.94 RCW.

SECTION III: STANDARD TERMS AND CONDITIONS OF THE PERMIT

The permittee must comply with all conditions of this chapter 401 permit. Any permit noncompliance constitutes a violation of chapter 70.94 RCW and, for federally enforceable provisions, a violation of the FCAA. Such violations are grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.This permit does not convey any property rights of any sort, or any exclusive privilege.No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for in this permit.The permittee may appeal this permit or any conditions in it only by filing an appeal with the pollution control hearings board and 

serving it on the permitting authority within thirty days of receipt pursuant to RCW 43.21B.310. This provision for appeal in this section is separate from and additional to any federal rights to petition and review under § 505(b) of the FCAA.This permit and all terms and conditions contained therein, including any permit shield provided under WAC 173-401-640, shall not expire until the renewal permit has been issued or denied if a timely and complete application has been submitted.

Reopening for Cause

III.12

All terms and conditions of this permit, including any provisions designed to limit potential to emit, are enforceable by EPA and 

citizens under the FCAA, unless they are specifically designated as not federally enforceable.If any provision of this permit is held to be invalid, all unaffected provisions of the permit shall remain in effect and be enforceable.This permit shall be reopened and revised under any of the following circumstances: 

(a) Additional applicable requirements become applicable when the remaining permit term is greater than three years. Such reopening shall be completed not later than 18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms and conditions have been extended pursuant to WAC 173-401-620(2)(j). (b) Additional requirements (including excess emissions requirements) become applicable under the acid rain program. Upon approval by EPA, excess emissions offset plans shall be deemed to be incorporated in the permit. (c) Ecology determines that the permit contains a material mistake or that inaccurate statements were made in establishing theemissions standards or other terms or conditions of the permit; or 

(d) Ecology determines that the permit must be revised or revoked to assure compliance with the applicable requirement. Procedures to reopen and issue a permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of the permit for which cause to reopen exists. No person shall make any false materials statement, representation or certification in any form, notice or report required in this 

permit. No person shall render inaccurate any monitoring device or method required under this permit.

WAC 

Page # 41 of 45 Alcoa Intalco Works Final Air Operating Permit 
IV.1 Monitoring 

Records

WAC WAC 

IV.2 Inspection 

Checklists

WAC 

IV.3 Changes at 

Source

WAC 

IV.4 Records 

Retention

WAC 

IV.5 Recording of 

Permit Deviation

WAC 

IV.6 Certifications WAC IV.7 Monthly Reports WAC 

WAC 

IV.8 Permit 

Deviations/Excess Emissions

WAC WAC 

IV.9 Emission 

Inventory

WAC 173-40

IV.10 Compliance 

Requirements/Certification

WAC WAC 401-63630 (5

A. The permittee shall continue to comply with applicable requirements with which the permittee is in compliance; B.The permittee shall meet applicable requirements that will become effective during the permit period. C. The permittee shall submit a report to the Department of Ecology and to Region 10 of EPA within 105 days after the close of the calendar year, and every year thereafter, certifying compliance with the terms and conditions contained in this permit for the previous calendar year. The initial compliance certification shall cover the period from when the permit is effective to the end of the calendar year. The

certification shall describe the following: i.the permit term or condition that is the basis of the certification; ii.the compliance status; iii. whether compliance was continuous or intermittent; and iv. the methods used for determining compliance [WAC 173-401-630(5)]. The compliance status shall be based on compliance with the final averaging period of the annual certification period. Determination of continuous or intermittent compliance shall be based on compliance during the entire annual certification period. The Permittee 

IV.11Reporting Terms & Conditions

The permittee shall keep records of any periodic and continuous monitoring required by this permit. These records shall include

the following, where applicable: (i) The date, place as defined in the permit, and time of sampling or measurements; (ii) The date(s) analyses were performed; (iii) The company or entity that performed the analyses; (iv) The analytical techniques or methods used; (v) The results of such analyses; and (vi) The operating conditions existing at the time of sampling or measurement.is not required to certify compliance for insignificant emission units or activities. [WAC 173-401-530(2)(d)]The permittee shall promptly submit a report of any deviations from permit conditions. A. For purposes of this permit, submitting a report “promptly” means the following: (1) if the deviation presents a potential threat to human health or safety, the report shall be made as soon as possible but no later than 12 hours after the discovery of the deviation; (2) for other deviations, “promptly” means that the deviations are identified in the respective monthly report. B. Reports shall describe the probable cause of suchdeviations, and any corrective actions or preventive measures taken. The permittee may include in its reports demonstrations that excess emissions were unavoidable, consistent with the requirements of WAC 173-400-107.The permittee shall retain records of all required monitoring data and support information for a period of 5 years from the date of monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all data from continuous monitoring instrumentation, and copies of all reports required by this permit.The source shall maintain a contemporaneous record of all deviations including the date and nature of the deviation.Where the permittee is required to use and maintain an inspection checklist, the checklist must contain, at a minimum, the following information: (i) The person conducting the inspection; (ii) The date/time of the inspection; (iii) Location of the inspection; (iv) The observations made during the inspection; (v) Corrective actions taken if any; (vi) The date and time corrective action was initiated and completed.The permittee shall keep records describing changes made at the source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from those changes.All reports, renewal applications, and compliance certifications required by this permit shall be submitted to: Department of Ecology, Industrial Section, P.O. Box 47706, Olympia, WA 98504-7706.Compliance certification shall also be submitted to: Environmental Protection Agency, Air Operating Permits, Region 10, 1200 Sixth Avenue, OAQ-108, Seattle, Washington 98101-1128.Any application form, report, or compliance certification submitted pursuant to Chapter 173-401 WAC shall contain certificationby a responsible official of truth, accuracy, and completeness. This certification and any other certification required under Chapter 173-401 WAC shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.Results of monitoring shall be reported within 30 days of the last calendar day of each month. All instances of deviations frompermit requirements must be clearly identified in such reports.The permittee shall submit an inventory of emissions, as specified in WAC 173-415-080, from the source each year no later than 105 days after the end of the calendar year. The permittee shall maintain records of information necessary to substantiateany reported emissions.

Report Address

Recordkeeping Terms & Conditions

SECTION IV: GENERAL TERMS AND CONDITIONS OF THE PERMIT

Page # 42 of 45 Alcoa Intalco Works Final Air Operating Permit 
IV.12 Asbestos WAC 

IV.13 Concealment and 

Masking

WAC 

IV.14 Inspection and 

Entry

WAC 

IV. 15 Application and 

Issuance of a Renewal Permit

WAC 

IV.17 Insignificant 

Emission Units

WAC 

IV.18 Providing 

Additional Data

WAC 

IV.19 Section 112(j) 

Industrial Boiler and Process Heater Phase II MACT Application

40 CF400-07

Pursuant to WAC 173-401-640(2), the Department of Ecology has determined that the requirements listed below do not apply to the facility, as of the date of permit issuance, for thPursuant to WAC 173-401-640(1), compliance with the terms and conditions of this permit shall be deemed compliance with the applicable requirements identified in this permit, as issuance. This permit shield does not exempt the permittee from requirements enacted after the permit issuance date. This permit shield shall not apply to any insignificant emissdesignated under WAC 173-401-530.

SECTION V: PERMIT SHIELD/ INAPPLICABLE REQUIREMENTS

For Ecology to evaluate a plant's emissions or emission control program, each primary aluminum plant shall furnish other data requested by Ecology.

IV.16 Stratospheric 

Ozone Protection

The permittee shall comply with applicable standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, except as provided for Motor Vehicle Air Conditions (MVACs) in Subpart B: i.Persons opening appliances for maintenance, service, repair or disposal must comply with the required practices pursuant to § 82.156; ii. Equipment used during the maintenance, service, repair or disposal must comply with the standards for recycling and recovery equipment pursuant to § 82.158; iii. Persons performing maintenance, service, repair or disposal of appliances must be certified by an approved technical certification program pursuant to § 82.161; iv. Persons disposing of small appliances, MVACs, and MVAClike appliances must comply with recordkeeping requirements pursuant to § 82.166 (“MVAC-like appliance” is defined at § 82.152.; v. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to § 82.156; Owners/operators of appliances normally containing 50 or more pounds or refrigerant purchased and added to such appliances pursuant to § 82.166."; B. Permittee may switch from any The generally applicable requirements that apply to IEUs are, WAC 173-415-030, WAC 173-400-040, WAC 173-400-050(1) & (3), and WAC 173-400-060.

40 CF70.94.only re

On or before April 28, 2004 the Permittee shall file a Part 2 application for a MACT determination, if by that date EPA has notpromulgated a generally applicable federal MACT standard for the Industrial Boiler and Process Heater source category. The application need only cover those emission points and hazardous air pollutants that would be subject to control under the MACT standard proposed for comment at 68 Fed.Reg. 1660 (January 13, 2003). ozone-depleting substance to any alternativ approved pursuant to the Significant New Alternatives Program (SANP), 40 CFR Part 82, Subpart G, without a permit revision but shall not switch to a substitute listed as unacceptable pursuant to such program. [40 CFR 82.174]; C. Any certified technician employed by Permittee shall keep a copy of their certification at their place of employment. [40 CFR 82.166(1)]; D. The Permittee shall not willfully release any regulated refrigerant and shall use refrigerant extraction equipment to recover regulated refrigerant that would otherwise be released into the atmosphere. [RCW 7070.94.970(2), 970(4)] State Only; E. Compliance with this term and condition will be demonstrated by using a certified contractor or employee.The permittee shall submit a complete permit renewal application to Ecology no later than six months, but no earlier than 18 months, prior to the expiration date of the existing permit. Permits being renewed are subject to the same procedural requirements, including those for public participation, affected state and EPA review that apply to the initial permit.The permittee shall not install or use any means that conceal or mask an emission of an air contaminant that would otherwise violate provisions in this permit.Inspection and entry. The permittee shall allow the permitting authority or an authorized representative to perform the following 

upon presentation of credentials and other documents as may be required by law:(a) Enter upon the permittee's premises where a chapter 401 source is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit; (b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (c) Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and (d) As authorized by WAC 173-400-105 and the FCAA, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit or applicable requirements.The permittee shall comply with 40 CFR Part 61, subpart M (asbestos NESHAP) and WAC 173-400-075 when conducting any renovation or demolition at the facility.

Other Terms & Conditions of the Permit

Page # 43 of 45 Alcoa Intalco Works Final Air Operating Permit 
WAC 173-490-040(8) (2/19/91) Conveyorized Degreasers It does not apply to any of the emission units at Intalco.

WAC 173-490-040(6) (2/19/91) Surface Coaters It does not apply to any of the emission units at Intalco.WAC 173-490-040(7) (2/19/91) Open Top Vapor Degreasers It does not apply to any of the emission units at Intalco.

None of the facility’s emission units are incinerators burning a solid wmeaning of WAC 173-434-030.The facility does not have any petroleum liquid storage tanks.

WAC 173-490-040(2) (2/19/91) Petroleum Liquid Storage Tanks The facility does not have any petroleum liquid storage tanks.Chapter 173-434 WAC (9/17/90) Solid Waste Incinerator FacilitiesWAC 173-490-030 (2/19/91) Registration and Reporting--Petroleum liquid storage tanks.

Not applicable because applicable requirements apply only to "emisssource," per WAC 173-401-200(4), and motor vehicles are not "emissWAC 73-401-200(11).The facility’s operations do not include open burning.Not applicable because there are no "agricultural operations," as defi020(1), at IntalcoThe facility’s emission units are not “solid fuel burning devices” as de030(9).

Chapter 173-430 WAC Agricultural BurningChapter 173-433 WAC (9/17/90) Solid Fuel Burning Device Standards40 CFR 60, Subpart S Standards of Performance for Primary Aluminum Reduction Plants The facility was constructed before October 23, 1974 and was not mo

after that date.

RCW 70.94.610 Burning Used Oil Fuel in Land-based Facilities The facility does not burn used oil.

Not applicable because WAC173-400-101(7) exempts sources subjeprogram from registration requirements of WAC173-400-100 throughNot applicable because WAC173-400-101(7) exempts sources subjeprogram from registration requirements of WAC173-400-100 throughNot applicable because WAC173-400-104(4) exempts sources subjepermit fee from paying an interim registration fee.None of the listed categories are found at Intalco. Not applicable because WAC173-400-101(7) exempts sources subjeprogram from registration requirements of WAC173-400-100 through

Chapter 173-422 WAC Motor Vehicle EmissionsChapter 173-425 WAC (9/17/90) Open BurningChapter 173-421 WAC Emission Control SystemsWAC 173-400-136 Use of Emission Reduction Credits

Facility was not regulated by a local air authority.

WAC 173-406 Acid Rain Regulation Not applicable because Intalco in not an "affected source" within the 

101(9).

WAC173-400-210 Emission requirements

The facility does not perform work on motor vehicle emission systemIntalco is not located in an non-attainment area.

WAC 173-400-115 Standards of performance for new sources The facility was constructed before October 23, 1974 and was not mo

as defined by NSPS, after that date.

WAC173-400-112 Requirements for new sources in non-attainment areasRCW 70.94.775 Outdoor Burning--Fires Prohibited—Exceptions The facility does not conduct outdoor burningRCW 70.94.743 Outdoor Burning--Areas Where ProhibitedWAC 173-400-131 Issuance of Emission Reduction CreditsWAC173-400-104 Registration feesWAC 173-400-105(5) Continuous monitoring and reporting

The facility has not applied for a bubble.The facility has not applied for emission reduction credits.

WAC 173-400-120 Bubble RulesWAC 173-400-070 Emission standards for certain source categories

Alcoa is not in an affected CountyFacility is not a significant contributor to the non-attainment status of non-attainment area.

RCW 70.94.531 Transportation demand management

INAPPLICABLE REQUIREMENTS

Regulatory Citation Reason for Inapplicability

RCW 70.94.650 Burning Permits for Weed Abatement, Fire Fighting Instruction and Agricultural Activities The facility does not engage in any of the covered burning activities.

The facility does not conduct outdoor burning

WAC173-400-040(8)(b) Fugitive emissionsWAC 173-400-050(2) (9/20/93) Emission Standards for Incinerators None of the facility’s emission units are “incinerators” as that term is 

030.

WAC173-040-102 Scope of registration and reportingWAC173-400-103 Emission estimates

The facility does not have and has not used emission reduction credi

WAC173-400-100 Registration of sources

None of the listed categories are found at Intalco.

Page # 44 of 45 Alcoa Intalco Works Final Air Operating Permit 
gr grain

HAP hazardous air pollutantMACT maximum available control technologyIEU insignificant emission unitkg kilogramlbs pounds

general terms and conditions

g/m3 grams per cubic meter

FCAA Federal Clean Air Actgpm gallons per minutegt&cdscf dry standard cubic footEPA Environmental Protection Agency

dioxins and furans

CO carbon monoxideDOE Department of EcologyBTU British thermal unitCEM continuous emission monitoravg averageBACT best available control technologyFCCA section 183(f) Tank vessel Standards Applys only to loading and unloading of marine vessels carrying petr

activity does not occur at Intalco.

FCCA section 328 Standards to control air pollution from outer continental shelf sources Not applicable because Intalco is not an "Outer Continental Shelf So

of FCAA section 328(a)(1).

FCAA Title IV, Acid Deposition Control Not applicable because Intalco has not volunteered to participate.FCCA section 183(e) Standards for VOC-emitting Products Not applicable because Intalco is not a "regulated entity" within the m

183(e)(1)©, and because EPA has not promulgated any rules under regulated primary aluminum smelters.

WAC463-39 EFSEC General regulations Applies only to facilities under the jurisdiction of EFSEC.Ecology Order DE 90-I035 Request Air Monitoring Plan Intalco submitted the Plan in compliance with the requirement. Cond

requires Intalco to update the plan.

WAC 173-490-201 (2/19/91) Petroleum Liquid Storage In External Floating Roof Tanks The facility does not have any petroleum liquid storage tanks.WAC 173-490-205 (2/19/91) Surface Coating of Miscellaneous Metal Parts and Products The facility does not engage in the surface coating of metal parts or pWAC 173-490-040(10) (2/19/91) Cold Cleaners It does not apply to any of the emission units at Intalco.WAC 173-490-080 (2/19/91) Exceptions and Alternative Methods Subsection (1) not applicable because facility has not applied for an a

reduction method. Subsection (2) The facility does not have a gas-fircomply with the requirements of this chapter.

WAC 173-490-040(9) (2/19/91) Cutback Asphalt Paving The facility does not engage in the activity subject to requirements of 

Regulatory Citation Reason for Inapplicability

INAPPLICABLE REQUIREMENTS (continued)

million British thermal units

D/F

SECTION VI: ABBREVIATIONS

NSPS new source performance standardsPM particulate matterNOx nitrogen oxides

μg/m3 micrograms per cubic meter

MMBTUPM10 particulate matter less than 10 microns in diameterPOM polycyclic organic matterVE visible emissionsppm parts per millionRACT reasonable available control technologyppmdv part per million dry volumePSD prevention of significant deteriorationRCW Revised Code of WashingtonWAC Washington Administrative Code

sulfur dioxide

tpy tons per yearSO2

VOC volatile organic compoundU.S.C. United States CodeSERP source emission reduction planSIP state implementation planTHC total hydrocarbon emissions that also serve as a surrogate for the emission of organic HAP compounds

Page # 45 of 45 Alcoa Intalco Works Final Air Operating Permit