April 15, 2004May 1, 2004April 15, 2009In compliance with the provisions ofThe State of WashingtonIntalco Aluminum Corporation isauthorized to operate in accordancewith the terms and conditionsof this permitIssued by:State of WashingtonDEPARTMENT OF ECOLOGY300 Desmond DriveP.O. Box 47600Approved by:Carol Kraege, P.E.Industrial Section ManagerAIR OPERATING PERMIT No. 000295-0In compliance with the provisions ofThe State of WashingtonClean Air Act Chapter 70.94 Revised Code of WashingtonIssuance Date:Effective Date:Expiration Date:Page # 1 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004334710111931333441424242434345Other Terms & Conditions of the PermitE. Metal ProductsF. AncillaryG. MaintenanceH. Facility-Wide Generally Applicable RequirementsSECTION III: STANDARD TERMS AND CONDITIONS OF THE PERMITSECTION IV: GENERAL TERMS AND CONDITIONS OF THE PERMIT:Recordkeeping Terms & ConditionsReporting Terms & ConditionsSECTION I: INTRODUCTION AND LEGAL AUTHORITYSECTION II: SPECIFIC TERMS AND CONDITIONS OF THE PERMITA. Green CarbonTABLE OF CONTENTSB. Baked CarbonC. Anode RoddingD. Potlines (Potroom Operations)SECTION V: PERMIT SHIELD/ INAPPLICABLE REQUIREMENTSSECTION VI: ABBREVIATIONSPage # 2 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Process Specific Applicable Requirements: This permit categorizes permit conditions according to Intalco's aluminum smelter processes: green carbon, baked carbon, anode rodding, potroom operation,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 that are subject tospecific 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 process and with sixcolumns titled Emission Unit; Pollutant/Parameter; Requirement; Monitoring, Reporting and Record-keeping; and Basis of Authority. In cases where an emission unit is subject to a number of similarrequirements, 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 below it (typed in italicizedfont) [per WAC 173-301-600].Terms used in this permit have the meaning assigned to them in the referenced regulations. The definitions of terms containedin WAC 173-401-200, and as defined in all referenced regulations, apply tothis 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 applicable requirements (Table H).Insignificant emission units (IEUs) and activities are subject to the applicable requirements contained in the facility–wide generally applicable requirements (Table H), however, they are not subject totesting, monitoring, recordkeeping, reporting and certification requirements unless the generally applicable requirements in the State Implementation Plan (SIP) impose them [WAC 173-401-530(2)(c).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 more of one or more airpollutants as evidenced by Intalco's annual emission inventories and monthly air emission reports [WAC 173-401-300(1)].Section I: INTRODUCTION AND LEGAL AUTHORITYThis Air Operating Permit is issued under the procedures established in the Operating Permit Regulation, Chapter 173-401 WAC (Washington Administrative Code). The provisions of this permit describethe emissions limitations, operating requirements, emission monitoring, record keeping requirements, and reporting frequenciesfor the permitted source.Section II: SPECIFIC TERMS AND CONDITIONS OF THE PERMITDuring periods of total facility curtailment (100% of smelting operations are shut down), monitoring, inspections, and recordkeeping requirements can be discontinued if the permittee makes acontemporaneous 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 total curtailment in thesubsequent monthy air monitoring report. Reporting requirements shall remain in effect. Upon start-up of the curtailed smelting operations, all requirements in this permit shall come back into effect.Intalco 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 monitoring schedule inaccordance with the permit conditions when operations are started again. For emission units subject to a source test frequencyof every 2 years or greater, the commencement of monitoring after startupshall 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 shall contain the followingrequirements with respect to monitoring: (b) Where the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring (which may consist of recordkeepingdesigned to serve as monitoring), periodic monitoring sufficient to yield reliable data from the relevant time period that arerepresentative of the source's compliance with the permit, as reported pursuant tosubsection (3) of this section. Such monitoring requirements shall assure use of terms, test methods, units, averaging periods,and other statistical conventions consistent with the applicable requirement.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 must fulfill the followingrequirement with respect to compliance: “Consistent with WAC 173-401-615, all chapter 401 permits shall contain compliance certification, testing, monitoring, reporting, and recordkeeping requirementssufficient to assure compliance with the terms and conditionsof the permit.” The addition of these requirements is called “gapfilling”. Ecology has added gapfilling requirements (monitoring, recordkeeping, and reporting requirements to assure compliance with theconditions 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 Compliance Requirements).The authority for the "gapfilling" requirements is distinquished in the AOP from the authority for applicable requirements thatwere established in approval orders issued by Ecology.Page # 3 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityA 1 ParticulateMatter (PM)Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and A11. WAC 173-400-060; WAC 173-401-615(1)(b) (PeriodicMonitoring), WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).A 2 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and A11. See Condition H3.a.A 3 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and A11. Same authority as for ConditionA1.A 4 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and A11. See Condition H3.a.A 5 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and A11. Same authority as for ConditionA1.A 6 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and A11. See Condition H3.a.A 7 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.e and A11. See Condition H2.eA 8 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and A11. See Condition H3.a.A 9 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.e and A11. See Condition H2.eA 10 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and A11. See Condition H3.a.188 Paste PlantBaghouse Stack, 189Phase “A” Ball MillBaghouse, , 191Phase “B” Ball MillBaghouse, 194Petroleum CokeBaghouse Stack,232 Spent AnodesBaghouse.A 11 FunctionalIntegrityInspection Intalco shall comply with Condition H4.a. See Condition H4.a191 Phase “B” Ball MillBaghouse (10,000acfm)II A GREEN CARBON194 Petroleum CokeBaghouse Stack(7,500 acfm)189 Phase “A” Ball MillBaghouse (10,000acfm)188 Paste PlantBaghouse Stack(19,000 acfm)232 Spent AnodeCrusher Baghouse(18,000 acfm)Page # 4 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityA 12 PM10Emissions of PM10shall not exceed 2.36 poundsper hour [Per Order No. 02AQIS-3967].Emissions of PMshall not exceed 0.1 gr/dscf[Per WAC 173-400-060; WAC 173-401-615(1)(b), WAC 173-401-615(2)(a); and WAC173-401-630(1)].Intalco shall comply with Condtitions H1, H2.b, and A 15. Order No. 02AQIS-3967WAC 173-400-060; WAC 173-401-615(1)(b) (PeriodicMonitoring), WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).A 13 Opacity Opacity shall not exceed 5% for more than sixconsecutive minutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.b, and A 15.A 14 PolycyclicOrganic Matter(POMSexcludingnapthalene)Emissions of POM shall not exceed 0.54 lbs perhourIntalco shall conduct a source test once every two years andupon Ecology’s request using EPA RM 315 as per 40 CFR63, Appendix A, or another EPA approved method. Intalcoshall submit the test report to Ecology within 90 days of thedate of the test.Intalco can reduce the frequency of source testing to onceevery 5 years if condition H6 is met.Intalco shall comply with Conditions A15 and H14.A 15 FunctionalIntegrityInspection Intalco shall comply with Condition H4.b.A16 Operation andMaintenance(O&M) ManualO&M Manual Intalco shall develop, follow, and update an O&M manual.The O&M manual shall include the certification requiredunder 40 CFR 63.843(b) and parametric monitoring inaccordance 40 CFR 63.848(f)(1).II A GREEN CARBON (continued)316 Pitch FumeTreatment System(50,000 acfm)Order No. 02AQIS-3967Page # 5 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityA 17 POM Operate and maintain equipment to capture andcontrol POM emissions.Intalco shall comply with conditions A 17 through A 19. 40CFR63.843(b)A 18 ParametricmonitoringOperate, calibrate and maintain a continuousparameter monitoring system including, at aminimum, coke flow and air flow. Submit forapproval the average coke feed rate which shallbe maintained for each operating shift. Submitfor approval the average air flow rate which shallbe maintained for each operating shift.Intalco shall monitor and maintain a log of coke feed and airflow rates. Intalco shall maintain records onsite and makethem available to Ecology on request. Intalco shall submit asemiannual summary report of the parametric monitoringinspection results to Ecology.40CFR63.848(f) and40CFR63.847(h)A 19 VE Visually inspect the exhaust stack(s) of eachcontrol device for evidence of any VE indicatingabnormal operation.Intalco shall conduct daily VE inspections (Method 9 is notrequired) and record the results.40CFR63.848(g)A 20 CorrectiveActionIntalco shall intitiate the corrective actionprocedures identified in the current version ofthe startup, shutdown and malfunction (SSM)plan within 1 hour if a monitoring devicemeasures an operating parameter outside thelimit(s) established pursuant to § 63.847(h) or ifVE indicating abnormal operation are observedfrom the exhaust stack of a control device duringa daily inspection. Intalco shall comply with theSSM plan. Failure to inititate the correctiveaction within 1 hour or to take the necessarycorrective actions to remedy the problem is aviolation.Intalco shall maintain records of all instances of failure toinitiate corrective action procedures within 1 hour or to takenecessary corrective actions to remedy the problem.40CFR63.848(h)A 21 Exceedances If the limit for a given operating parameterassociated with monitoring a specific controldevice (per condition A18) is exceeded six timesin any semiannual reporting period, then anysubsequent exceedance in that reporting periodis a violation. For the purpose of determiningthe number of exceedances, no more than oneexceedance shall be attributed in any given 24-hr. period.Intalco shall record all exceedences of the limits for operatingparameters.40CFR63.848(i)A 22 Accuracy andcalibrationAll monitoring devices required by condition A18 [40CFR63.848] must be certified by Intalcoto meet the accuracy requirements and must becalibrated in accordance with manufacturer’sinstructions.Intalco shall submit any changes to monitoring devices thataffect their accuracy to Ecology for review and approval.40CFR63.848(k)A 23 ExcessEmissionsreportIntalco shall submit a semiannual excess emissions report,containing information specified in 40CFR63.10(e)(3)(v), ifmeasured emissions exceed the applicable standard unlessquarterly reports are required as a result of excessemissions.40CFR63.850(d) and40CFR63.10(e)(3)A 24 FileMaintenanceIntalco shall maintain files of all information, reports andnotifications required by 40CFR63.10(b) and 40CFR63Subpart LL in accordance with 40CFR63.850(e) for aminimum of 5 years.40CFR63.850(e) and40CFR63.10(b)316 Pitch FumeTreatment System(50,000 acfm)II A GREEN CARBON (continued)Conditions A17 through A 24incorporate MACT requirements published at FR52384 October 7, 1997Page # 6 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityB 1 PM When added to the total PM emissions from theprimary and secondary potline control systems,PM emissions from the bake oven baghouseshall not exceed the PM limits in Conditions D6and D7 [Per Order No. 02AQIS-3967].Emissions of PM shall not exceed 0.1grains/dscf [Per WAC 173-400-050(1); WAC173-401-615(1)(b), WAC 173-401-615(2)(a);and WAC 173-401-630(1)].Intalco shall determine and demonstrate compliance with thePM limits by conducting a source test once per year andupon Ecology’s request using EPA RM 5 per 40 CFR 60,Appendix A, or another EPA approved method. Intalco shallreport the grainloading concentration (grains/dscf) for thebake oven baghouse and Intalco shall report the monthlyaverage of the combined total pounds of PM per day and the3-month average of the combined total pounds of PM per tonof aluminum produced from the bake oven baghouse and thepotlines (per Conditions D6 and D7) in the respective monthlyair monitoring report submitted to Ecology. Intalco shallcomply with Conditions H1, H14, and B5.Order No. 02AQIS-3967WAC 173-400-050(1);WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).B 2 TF Emissions of TF from the bake ovens whenadded to the total TF emissions from the primaryand secondary potline control systems shall notexceed the TF limits in Conditions D11 and D12.Intalco shall determine and demonstrate compliance with theTF limits by conducting a source test on the bake ovenbaghouse 3 times per year using Alcoa Methods 4075A and4046A. Intalco shall report the monthly average of thecombined total pounds of TF per day and the 3-monthaverage of the combined total pounds of TF per ton ofaluminum produced from the bake oven baghouse and thepotlines (per Conditions D11and D12) in the respectivemonthly air monitoring report submitted to Ecology.Intalco shall comply with Conditions H1, H14, and B5.Order No. 02AQIS-3967B3 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and B5. See Condition H3.a.B4 SO2 SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with condition H 1, H 8 and B5. Defined in Conditon H8.B5 FunctionalIntregrityInspection Intalco shall comply with Condition H4.a. Defined in Conditon H4.a.II A BAKED CARBON187 Bake OvenBaghouse (100,000acfm)Page # 7 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityB6 TF Shall not exceed 0.20 lb/ton of green anodeplaced in the anode bake furnaces.Intalco shall conduct source tests in accordance with theapproved test plan at the exhaust stack using Alcoa Method4075ATF/4076TF. Intalco shall compute and record theannual average of all valid test runs ( a minimum of three testruns) each year to determine compliance, using equation 2in 40CFR63.847(e)(3). Intalco shall submit test results eachyear in accordance with Condition H14.40CFR 63.843(c)(1), 847(d),848(c), 849, 850(a)(5) and b,40CFR 63.7(b) and (g)B7 POM Shall not exceed 0.18 lb/ton of green anodeplaced in the anode bake furnaces.Intalco shall conduct source tests in accordance with theapproved test plan at the exhaust of module A-446 usingAlcoa Method 4075ATF/4076TF. Intalco shall compute andrecord the annual average of all valid test runs ( a minimumof three test runs) each year to determine compliance, usingequation 2 in 40CFR63.847(e)(4). Intalco shall submit testresults each year in accordance with Condition H14.40CFR 63.843(c)(2) 847(d),848(c), 850(a)(5) and b, 40CFR63.7(b) and (g)B8 ParametricMonitoringOperate, calibrate, and maintain a continuousparameter monitoring system including, at aminimum, alumina flow and air flow. Submit forapproval the average ore flow rate into eachreactor which shall be maintained. Submit forapproval the average air flow rate from thebaking furnace which shall be maintained.Intalco shall inspect each control device to ensure the controldevice is operating properly and record the results of eachinspection. Intalco shall monitor and maintain a log of orefeed and air flow rates. Intalco shall maintain records onsiteand make them available to Ecology upon request. Intalcoshall submit a semiannual summary report of the parametricmonitoring inspection results to Ecology.40CFR63.848(f) and40CFR63.847(h)B9 VisibleEmissions (VE)Visually inspect the exhaust stack of eachcontrol device for evidence of any VE indicatingabnormal operation.Intalco shall conduct daily VE inspections (EPA RM 9 is notrequired) and record the results.40CFR63.848(g)B 10 CorrectiveActionIntalco shall intitiate the corrective actionprocedures identified in the startup, shutdownand malfunction (SSM) plan (per Condition B14)within 1 hour if a monitoring device measures anoperating parameter outside the limit(s)established pursuant to § 63.847(h) or if VEindicating abnormal operation are observed fromthe exhaust stack of a control device during adaily inspection. Intalco shall comply withCondition B13 (SSM plan). Failure to inititatethe corrective action within 1 hour or to take thenecessary corrective actions to remedy theproblem is a violation.Intalco shall maintain records of all instances of failure toinitiate corrective action procedures within 1 hour or to takenecessary corrective actions to remedy the problem.40CFR63.848(h)187 Bake OvenBaghouse (100,000acfm)Conditions B6 through B 15 incorporate MACT requirements published at FR52384 October 7, 1997II B BAKED CARBON (continued)Page # 8 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityB 11 Exceedances If the limit for a given operating parameterassociated with monitoring a specific controldevice is exceeded six times in any semiannualreporting period, then any subsequentexceedance in that reporting period is aviolation. For the purpose of determining thenumber of exceedances, no more than oneexceedance shall be attributed in any given 24-hr. period.Intalco shall record all exceedences of the limits for operatingparameters.40CFR63.848(i)B 12 Green anodematerial weightIntalco shall operate and maintain a monitoringdevice to determine the daily weight of greenanode material by measuring the weight of allanodes or by monitoring the number of greenanodes placed in the furnace and determiningan average weight from measurements of arepresentative sample of anodes.Intalco shall record the monthly average weight of anodesplaced in each furnace in tons, to calculate the daily weight ofanodes placed in each furnace in tons. Per approvedParameter Monitoring Plan.40CFR63.848(j)B 13 Accuracy andcalibrationAll monitoring devices required by condition B8must be certified by Intalco to meet the accuracyrequirements and must be calibrated inaccordance with manufacturer’s instructions.Intalco shall submit any changes to monitoring devices thataffect their accuracy to Ecology for review and approval.40CFR63.848(k)B 14 ExcessEmissionsReportIntalco shall submit an excess emission report semiannuallycontaining information specified in 40CFR63.10(e)(3)(v), ifmeasured emissions exceed the applicable standard unlessquarterly reports are required as a result of excessemissions.40CFR63.850(d) and40CFR63.10(e)(3)(v)B 15 FileMaintenanceIntalco shall maintain files of all information, reports andnotifications required by 40CFR63.10(b) and 40CFR63Subpart LL in accordance with 40CFR63.850(e) for aminimum of 5 years.40CFR63.850(e) and40CFR63.10(b)B16 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and B19. Same authority as for ConditionA1B17 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and B19. See Condition H3.a.B18 SO2 SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with condition H 1 and H8. See Condition H8.B19 FunctionalIntegrityInspection Intalco shall comply with condition H4.c. See Condition H4.cII B BAKED CARBON (continued)187 Bake OvenBaghouse (100,000acfm)251 Anode BakeBuilding Roof VentsPage # 9 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityC1 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.c and C5. See Condition H2.cC2 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and C5. See Condition H3.a.C3 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.c and C5. See Condition H2.cC4 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and C5. See Condition H3.a.198 RodshopBaghouse (West),199 RodshopBaghouse (East),C5 FunctionalIntegrityInspection Intalco shall comply with condition H4.a. See Condition H4.aC6 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and C8. Same authority as for ConditionA1C7 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and C8. See Condition H3.a.C8 FunctionalIntegrityInspection Intalco shall comply with condition H4.c. See Condition H4.c198 RodshopBaghouse (West)(50,000 acfm)199 RodshopBaghouse (East)(50,000 acfm)II C ANODE RODDING253 Rod Shop BuildingRoof Vents NorthPage # 10 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD1 AluminumProductionNet potline production of aluminum shall belimited to <307,000 tons of aluminum percalendar year. Net production of aluminum is thetotal mass of molten metal produced fromtapping all pots in all operating potlines,measured at the casthouse scales and the rodshop scales.Intalco shall maintain a record of the daily net production ofaluminum and report the average daily net aluminumproduction in the monthly air monitoring report that issubmitted to Ecology per Condition H14.Order No. DE 02AQIS-3967Intalco shall maintain a record of the data collected for theparameters below, compute the monthly average, and reportthe monthly average (unless another average is noted below)for each parameter in the respective monthly air monitoringreport submitted to Ecology per Condition H14:· Number of pots operated per day (potdays)· Percent sulfur in pitch (Intalco shall analyze eachincoming load or batch of pitch for sulfur content using theprocedures in ASTM D4239 or other ASTM sulfur methods)Order No. DE 02AQIS-3967· Percent sulfur in coke (Intalco shall analyze eachincoming load or batch of coke for sulfur content using theprocedures in ASTM D4239 or other ASTM sulfur methods)· Percent sulfur in baked anode as a weekly compositeof anode core samples. Current Efficiency· Carbon consumption ratio as a daily averagecomputed monthly· Amperes of current· Average number of days per pot to complete a potrelining· Total pounds of aluminum sent to cast house per dayD3 “Water Off”(periods whenthe secondarycontrol systemroof scrubbersare turned offdue to potentialfreezingconditions)emission limitsand conditionsare coveredunder WAC173-415-030(6).All of the limits and conditions in Conditions D1through D26 were developed for “water on”conditions. Water Off emission limits andconditions are covered under WAC 173-415-030(6) until Ecology issues an order with newconditions. Intalco shall follow the proceduresspecified in the current version of the StartupShutdown and Malfunction Plan to determinewhen shutdown is necessary, and when the roofscrubbing system can be safely started again.During these periods where the scrubberscontinue to operate, but conditions prohibit saferoof access, Intalco will not conduct sourcetesting of the roof scrubbers.Intalco shall notify Ecology that the roof scrubbers are goingto be shut off. Intalco shall use all tests conducted over thecalendar month to demonstrate compliance. For potlineswhere less than the required three tests were completed inthe calendar month according to the schedules specified inthe approved Air Monitoring Plan per Condition H15, datafrom the preceding 24 months shall be substituted. Theaverage and standard deviation of all roof scrubber tests shallbe computed from the data set of each potline. The averageplus two standard deviations will be used for all tests thatcould not be run. Intalco shall report the average of all actualtests run during the compliance period and the valuesobtained from the average and standard deviations describedabove as the roof emissions for each potline in the respectivemonthly air monitoring report submitted to Ecology.Order No. DE 02AQIS-3967D2 OperationalLimitsThe 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 (poundsof carbon consumed per pound of Aluminumproduced).Order No. DE 02AQIS-3967II D POTLINESPotlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Page # 11 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/P tRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD4 PM Emissions of PM from potrooms shall notexceed 0.1 grains/dscf.Intalco shall determine and demonstrate PM compliance withthe the PM limit of 0.1 grains/dscf by complying with the themonitoring, recordkeeping, and reporting requirements inCondition D6 and Intalco shall comply with Conditions D17,D18, and D19.WAC 400-050(1)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).D5 PM The total emissions of PM to the atmospherefrom the reduction process (potlines) shall bereduced to the lowest level consistent withreasonably available control technology (RACT).Emissions of PM shall not exceed fifteen (15)pounds of PM per ton of aluminum produced ona daily basis.Intalco shall determine PM emissions and demonstratecompliance with the the PM limit of 15 lb/ton of Al producedby complying with the 6.0 lb PM/ton Al limit and themonitoring, recordkeeping, and reporting requirements inCondition D7. A demonstration of compliance with the 6.0lbPM/ton Al limit in Condition D7 will be considered ademonstration of compliance with this less stringent15lbPM/ton Al limit. Intalco shall comply with Conditions D17,D18, and D19.WAC 415-030(2)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).D7 PM Emissions of PM shall not exceed a combinedtotal of 6.0 pounds per ton of aluminum(calculated on a three month average) producedfrom the potlines (primary and secondary controlsystems) and the bake ovens.II D POTLINES (continued)D6 Emissions of PM shall not exceed a combinedtotal of 5050 pounds per day (calculated on amonthly average) from the potlines (primary andsecondary control systems) and the bake ovens.PMPotlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Intalco shall determine PM emissions and demonstratecompliance with the PM limits in Conditions D4 through D7 bysource testing the primary control systems of potlines A, B,and C (4 cells per month per potline [2 cells from each of 2baghouse centers]) using Alcoa Method B-54 or another EPAapproved method for a minimum of 24 hours and by samplingthe secondary control systems of potlines A, B, and C usingAlcoa Method B-54b (three roof scrubbers simultaneouslythree times per month per potline). Intalco shall report theresults of the source tests conducted in compliance withConditions D4 through D7 in the respective monthly airmonitoring report submitted to Ecology per condition H14.Intalco shall comply with Conditions D17, D18, D19, and H14.Order No. DE 02AQIS-3967Page # 12 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD8 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H3.a, D17, D18, andD19.See Condition H3.a.Intalco shall determine representative TF emissions from thepotline primary control system by conducting a minimum ofthree pairs of source tests on each operating primary controlsystem per year (40 CFR 63.847(b)(1)) using Alcoa Method4075A. To meet this requirement Intalco shall conductsource tests on a minimum of 8 cells in each potline in a 12month period (4 cells from each of the 2 CDs in Potline A and2 cells from each of the 4 CDs in Potline B and in Potline C)[40 CFR 63.847(b)(7))]. Intalco shall calculate the totalprimary TF emissions from each potline by multiplying theaverage representative emissions per stack (determined bysource testing) by the number of stacks per potline.Intalco shall determine representative TF emissions from thepotline secondary control system by conducting a minimum ofthree source tests simultaneously on three wet scrubbers peroperating potline each month using Alcoa Method B-54b.Intalco shall determine the total secondary TF emissions bymultiplying the average representative emissions per wetscrubber (determinedby source testing) by the number of wet scrubbers perpotline. Intalco shall demonstrate compliance with the TFlimits in Conditions D9 and D10 by summing the total TFemissions from the primary control systems and the total TFemissions from the secondary control systems of each potlineand comparing the sum to the respective limits. Intalco shallreport the results of the source tests conducted in compliancewith Conditions D9 and D10 in the respective monthly airmonitoring 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 inaccordance with the approved Air Monitoring Plan perCondition H15.Potlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Emissions of TF shall not exceed a combinedtotal of 1,350 pounds per day (calculated on aone month average) from the potlines (primaryand secondary control systems) and the bakeovens.II D POTLINES (continued)D9Order No. DE 02AQIS-3967Total Fluoride(TF)Page # 13 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD10 TF Emissions of TF shall not exceed a combinedtotal of 1.6 pounds per ton of aluminum(calculated on a three month average) producedfrom the potlines (primary and secondary controlsystems) and the bake ovens.Intalco shall determine TF emissions and demonstratecompliance with the the TF limit of 1.6 lb/ton of Al producedby complying with the the monitoring, recordkeeping, andreporting requirements in Condition D9. Intalco shall complywith Conditions D17, D18, and D19.Order No. DE 02AQIS-3967D11 Sulfur dioxide(SO2)SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with Condition H8. See Condition H8.D12 SO2Emissions of SO2shall not exceed 37, 780pounds per day (calculated on a one monthaverage).Intalco shall determine the SO2emitted by using the followingformula: SO2 emissions in lbs./day = (carbon consumptionratio)x(% sulfur in baked anodes/100)x (2 lb sulfur dioxide perlb sulfur)x(2000 pounds Aluminum per ton)x (Tons ofAluminum per day).Carbon consumption ratio (pounds of carbon consumed perpounds of Aluminum produced)Intalco shall report the monthly average of pounds of SO2per day in the respective monthly air monitoring reportsubmitted to Ecology per Condition H14. Intalco shallmaintain records of production data used to develop carbonconsumption ratio and tons of aluminum produced. Intalcoshall provide the records to Ecology upon request. Intalcoshall comply with Condition H7.D13 SO2Emissions of SO2shall not exceed 44.8 poundsper ton of aluminum produced (calculated on athree month average).Intalco shall determine the SO2emitted by using the formulain Condition D12. Intalco shall report the three month averageof the pounds of SO2 per ton of aluminum in the respectivemonthly air monitoring report submitted to Ecology perCondition H14.II D POTLINES (continued)Potlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Order No. DE 02AQIS-3967Page # 14 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD14 Carbonmonoxide (CO)Emissions of CO shall not exceed 236,150pounds per day (calculated on a one monthaverage).Intalco shall calculate CO emissions based on currentefficiency 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 ofmeasured CO emissions to calculated CO emissions(Intalco's self reported empirical value). Intalco shall reportthe monthly average of pounds of CO per day in the monthlyair monitoring report submitted to Ecology per Condition H14.D15 CO Emissions of CO shall not exceed 280 poundsper ton of aluminum produced (calculated on athree month average).Intalco shall determine CO emissions and demonstratecompliance with the 280 lb CO/ton Al limit by using themethod described in Condition D14. Intalco shall report thethree month average of the pounds of CO per ton ofaluminum in the monthly air monitoring report submitted toEcology per Condition H14.D16 Nitrogen oxides(NOx)Emissions of NOx shall not exceed 590 poundsper day (calculated on a one month average).Intalco shall determine the NOx emitted by using the AP-42emission factor of 140 lbs. of NOx per million cubic feet ofnatural gas consumed (as in a large natural gas combustionboiler unit). Intalco shall report the monthly average ofpounds of NOx per day in the monthly air monitoring reportsubmitted to Ecology per Condition H14.D17 Primary ControlSystemFunctionalIntegrityInspection Intalco shall comply with Condition H4.d.D18 SecondaryControl SystemFunctionalIntegrityInspection Intalco shall comply with Condition H4.e.Potlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).II D POTLINES (Continued)Order No. DE 02AQIS-3967Page # 15 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityIntalco shall comply with Condition H1 by: D26.a)Maintaining sufficient draft in the pots to capture direct potemissions. Intalco shall demonstrate compliance by meetingthe parametric monitoring requirements in Condition D22.D26.b) Maintaining flow of fresh alumina into the inlet flow ofeach potline baghouse. Intalco shall demonstrate complianceby meeting the parametric monitoring requirements inCondition D22. D26.c) Maintaining records of sight glassreadings and making those records available to Ecology uponrequest. D26.d) Checking flows on a minimum of fourbaghouse cells each month. During this process, Intalco shallreadjust the damper position, remeasure the flow, and markthe correct damper position on the stack if the flow from abaghouse cell exceeds the established maximum flow rate forthat cell. Intalco shall provide records of these inspections toEcology upon request.D26.e) Conducting weekly inspections to assure that only onehood at a time is open for anode change and tappingoperations and that only two hoods are open in any 20 potsection during line breaks for all shifts and for all potlines. IfIntalco observes that these practices are not being followed,Intalco shall take corrective action. Corrective action shallinclude, at a minimum, closing the extra open hoodsimmediately. Intalco shall provide records of these pot hoodinspections to Ecology upon request.. D26.f) Maintainingsufficient flow of recycle water to the wet roof scrubbers.Intalco shall demonstrate compliance by meeting theparametric monitoring requirements of Condition 29. D26.g)Complying with the functional integrity inspectionrequirements in Conditions D17 and D18. D26.h) Conductingsemi-annual "limited root cause analyses". These analysesconsist of gathering Intalco staff (environmental manager,operator(s) with extensive knowledge of current potroomhood and wet scrubber conditions, potroom source testingstaff, and staff who conduct the procedures which generate,mreview, and report emissions data in the monthly airmonitoring reports submitted to Ecology) to evaluate trends inthe emissions data and to determine measures to minimizeemissions. Intalco shall submit a summary of the findings ofthe "limited root cause analysis" and anymeasuresimplemented to minimize emissions in the subsequentmonth's air monitoring report. Intalco shall include a bar chartof "Potline Emissions" for each of the respective pollutantsillustrating the contributions from dry and wet scrubbers foreach operating potline for that month and the previous 24months to illustrate trends in the emissions data.II D POTLINES (Continued)Potroom O&MOrder No. DE 02AQIS-3967D19 Potroom O&MPotlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Page # 16 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD20 TF Emissions of TF shall not exceed 1.6 lbs/ton ofAl produced from each potline.Intalco shall determine emissions of TF and demonstratecompliance with the 1.6 lb/ton of aluminum produced TF limitby complying with the monitoring, recordkeeping, andreporting requirements of Condition D9. Intalco shalldetermine compliance by averaging all valid source tests ofpotline primary control systems conducted less than one yearbefore the compliance date for the reporting period, and allvalid source tests conducted on the potline secondary controlsystem collected during the compliance period (40 CFR63.848(a)).40CFR 63.843(a)(1)(iv), 847(d),848(a), 40CFR63.849, 40CFR63.7(b) and (g)D21 Audit Materials Intalco shall request performance audit materials45 days prior to each performance test.40CFR 63.7(c)(4)(i)D22 ParametricMonitoringIntalco shall operate, calibrate, and maintain acontinuous parameter monitoring systemincluding, at a minimum, alumina flow, air flow,and water flow.Intalco shall maintain alumina flow, air flow, andwater flow rates per the approved parametricmonitoring plan.Intalco shall submit proposed changes to approvedparametric monitoring plan for alumina flow and air flow ratesprior to making changes in parametric limits.Intalco shall maintain records of air flow and alumina flowrates.Intalco shall report exceedances of parametric limits semiannually.Intalco shall comply with Condition D24.40CFR63.848(f) and40CFR63.847(h)D23 VE Visually inspect the exhaust stack(s) of eachcontrol device for evidence of any VE indicatingabnormal operation.Intalco shall conduct daily VE inspections (Method 9 is notrequired) and maintain records of the inspections.40CFR63.848(g)D24 CorrectiveActionIntalco shall intitiate the corrective actionprocedures identified in the current version ofthe SSM plan within 1 hour if a monitoringdevice measures an operating parameteroutside the limit(s) established pursuant to §63.847(h) or if VE indicating abnormal operationare observed from the exhaust stack of a controldevice during a daily inspection. Intalco shallcomply with the SSM plan. Failure to inititate thecorrective action within 1 hour or to take thenecessary corrective actions to remedy theproblem is a violation.Intalco shall maintain records of all instances of failure toinitiate corrective action procedures within 1 hour or to takenecessary corrective actions to remedy the problem.40CFR63.848(h)II D POTLINES (Continued)Potlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).Conditions D20 through D29 incorporate MACT requirements published at FR52384, October 7, 1997Page # 17 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityD25 Exceedances If the limit for a given operating parameterassociated with monitoring a specific controldevice is exceeded six times in any semiannualreporting period, then any subsequentexceedance in that reporting period is aviolation. For the purpose of determining thenumber of exceedances, no more than oneexceedance shall be attributed to any given 24-hr. period.Intalco shall record all exceedences of the limits for operatingparameters.40CFR63.848(i)D26 Weight ofAluminumProducedOperate and maintain a monitoring device todetermine the daily weight of aluminumproduced.Intalco shall record the tons of aluminum produced daily foreach potline.40CFR63.848(j)D27 Accuracy andcalibrationAll monitoring devices required by condition D29[40CFR 63.848] must be certified by Intalco tomeet the accuracy requirements and must becalibrated in accordance with manufacturer’sinstructions.Intalco shall submit any changes to recommended accuracyrequirements to Ecology for review and approval.40CFR63.848(k)D28 ExcessEmissionsReportsIntalco shall submit an excess emission report semiannually,containing information specified in 40CFR63.10(e)(3)(v), ifmeasured emissions exceed the applicable standards. Intalcoshall submit quarterly reports if excess emissions areobserved during the quarter.40CFR63.850(d) and40CFR63.10(e)(3)D29 FileMaintenanceIntalco shall maintain files of all information, reports andnotifications required by 40CFR63.10(b) and 40CFR63Subpart LL in accordance with 40CFR63.850(e) for aminimum of 5 years.40CFR63.850(e) and40CFR63.10(b)Potlines A, B, and Cprimary (6 baghousecenters with varyingnumbers of individualstacks (emission units181-186) combined flow= 1.75 million scfm) andsecondary controlsystems (159 baghousestacks (emission units22-180) combined flow= 16 million scfm).II D POTLINES (Continued)Conditions D20 through D29 incorporate MACT requirements published at FR52384, October 7, 1997Page # 18 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 1 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.d, and E4. See Condition H2.dE 2 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and E4. See Condition H3.aE3 SO2 SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen base on the average ofany period of 60 consecutive minutesIntalco shall comply with condition H 1 and H8. See Condition H8.E4 FunctionalIntegrityInspection Intalco shall comply with condition H4.f See Condition H4.fE5 Carbonmonoxide (CO)Emissions of CO shall not exceed 100 ppm ofCO on a dry basis corrected to 3% oxygen fromthe remelt furnace stack. CO mass emissionrate shall not exceed 5.5 tons for any 12 monthperiod or 0.47 tons for any single month from theremelt furnace stack.CO levels shall be controlled by limiting natural gasconsumption and the quantities of aluminum scrap remelted(per Conditions E12 and E13) until new limits areestablished. CO limits and monitoring requirements will bedetermined based on the results of performance testing onthe modified system and will be established in a new orderissued by Ecology.Order DE 04AQIS-1070E6 PM PM emissions shall not exceed a concentrationof 0.1 grains/dscfPM levels shall be controlled by limiting natural gasconsumption and the quantities of aluminum scrap remelted(per Conditions E12 and E13) until new limits are established.WAC 400-173-050(1); 173-401-615(1)(b) (PeriodicMonitoring); WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).E7 PM PM emissions shall not exceed 2.5 tons for anytwelve month period, or 0.22 tons for any singlemonth from the remelt furnace stack.E8 PM10(particulate witha meanaerodynamicdiameter of lessthan or equal totenmicrometers)PM10emissions shall not exceed 1.5 tons of PMfor any twelve month period, or 0.13 tons ofPM10 for any single month from the remeltfurnace stack.217 Remelt FurnaceHolding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 19(153,000 acfm)Order DE 04AQIS-1070Intalco shall report all PM as PM10. PM levels shall becontrolled by limiting natural gas consumption and thequantities of aluminum scrap remelted (per Conditions E12and E13) until new limits are established. PM limits andmonitoring requirements will be determined based on theresults of performance testing on the modified system andwill be established in a new order issued by Ecology. Intalcohas opted to report all PM as PM10 and to comply with thePM10 limit in Condition E8. Should Intalco decide toestablish emission factors for PM and PM10 and to report PMand PM10 separately, Intalco shall develop a source test planwhich describes how the emission factors will be derived.Intalco shall submit the source test plan to Ecology for reviewand approval. Intalco may use the Ecology approvedemission factors to report separate emission rates for PMand PM10. When reporting PM and PM10 derived from theapproved emission factors, Intalco shall comply with therespective PM and PM10 limits in Conditions E7 and E8.II E METAL PRODUCTSPage # 19 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityIntalco shall determine and demonstrate compliance withopacity limits by: a). Conducting weekly visible emissiontests using EPA RM 9 per 40 CFR Part 60 until the COM isoperational. b). Increasing the opacity monitoring (conductedper Condition 5.a) to three times per week if the opacity limitsin Condition 1.f are exceeded more than once in any 7 dayperiod. c). Installing a continuous opacity monitor (COM) onthe remelt furnace stack by August 01, 2004. d). Maintainingthe COM in compliance with EPA Performance Specification1 per 40 CFR Part 60, Appendix B. If Intalco shuts down allcasthouse operations prior to August 01, 2004, Intalco shallinstall the COM before startup of remelt operations.e). Takingcorrective action if opacity exceeds any of the opacity limits.Corrective actions include but are not limited to: (a) adjustingflue 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 preventfuture occurrences.f). Reporting all opacity exceedances,noncompliance with the requirements defined in a) through e)above, and the corrective actions taken in the respectivemonthly air monitoring report submitted to Ecology.E10 Nitrogen oxides(NOx)New NOx limits and monitoring requirements willbe determined based on the results ofperformance testing on the modified system andwill be established in a new order issued byEcology.Intalco shall control NOx levels by limiting natural gasconsumption and the quantities of aluminum scrap remelted(per Conditions E12 and E13) until new NOx limits areestablished.Order DE 04AQIS-1070E11 Modifications ofthe remeltfurnaceIntalco shall complete the modifications on theremelt furnace system recommended in theEngineering Study submitted to Ecology onNovember 26, 2003 by August 01, 2004.Intalco shall complete the modifications recommended in theengineering study submitted to Ecology on November 26,2003 by August 01, 2004.Order DE 04AQIS-1070E12 Natural GasConsumptionIntalco shall not use more than 75,000 MMBtu ofnatural gas/year in the remelt furnace. This is aninterim limit until source testing on the modifiedremelt furnace demonstrates (to Ecology'ssatisfaction) that restrictions on consumption ofnatural gas are not necessary to meet theemission limits in Conditions E5 through E8 andE10.Intalco shall monitor, electronically record, and maintainrecords of the total number of cubic feet of natural gasconsumed by the remelt furnace each month. Intalco shallprovide the electronic records to Ecology upon request.Order DE 04AQIS-1070E9217 Remelt Furnace(continued)Opacity shall not exceed: E7.a) an average of 5% for any 60 minute period and; E7.b) 20 % formore than 3 minutes in any 1 hour period, orE7.c) 5 % for more than 6 consecutive minutesin any 60 minute period.II E METAL PRODUCTS (continued)Order DE 04AQIS-1070OpacityPage # 20 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE13 RemeltedAluminumScrapIntalco shall not remelt more than 45,640 tons ofscrap per year in the remelt furnace. This is aninterim limit until source testing on the modifiedremelt furnace demonstrates (to Ecology'ssatisfaction) that restrictions on the amount ofscrap melted are not necessary to meet theemission limits in Conditions to meet theemission limits in Conditions E5 through E8 andE10.Intalco shall monitor, record electronically, and maintainrecords of the total number of tons of aluminum produced bythe remelt furnace per month. Intalco shall provide theelectronic records to Ecology upon request.Order DE 04AQIS-1070E14 O&M Manual Intalco shall develop an O&M manual for theremelt furnace by October 29, 2004, follow it andupdate it as necessary for all associatedequipment and work practices that may affectemissions 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, includingperiods of abnormal operation and upset, Intalco personnel,to the extent practicable, maintain the remelt furnace, andoperate and maintain air pollution control equipmentassociated with the remelt furnace in a manner consistentwith good air pollution control practice. Emissions that resultfrom a failure to follow the requirements of the manual maybe considered proof that the equipment was not properlyoperated and maintained. Intalco shall follow the O&Mmanual and update the manual as necessary to include anychanges in operation of the remelt furnace and activitiesrelated to its operation.Order DE 04AQIS-1070E15 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof the remelt furnace system that, at a minimum, includes avisual check for visible emissions. Intalco shall record theobservations of the parameters assessed in the inspectionlog. Any time visible emissions are present, Intalco shall takecorrective action as soon as practical but within 24 hours.Intalco shall record the results of corrective actions taken inthe inspection log.Order DE 04AQIS-1070217 Remelt Furnace(continued)II E METAL PRODUCTS (continued)Page # 21 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 16 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.f and E20 See Condition H2.f.E 17 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and E20 See Condition H3.a.E18 SO2 SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with condition H 1 and H8. WAC 173-400-040 (6)E 19 NOx Emissions of NOx shall not exceed 83 ppmcorrected to 3% oxygen at 1500 – 1600 Deg. FIntalco shall conduct a source test on each MHD furnace atstartup and on alternating MHD furnaces once every fiveyears during full operation using EPA RM 7E for NOx and RM3A for Oxygen as per 40 CFR Part 60, Appendix A, oranother EPA approved method. Intalco shall comply withCondition E20 and H14.DE 02AQIS-3967E 20 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof 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 02AQIS-3967220a, 220b, 221a,221b MHD HoldingFurnaces (51,000acfm)II E METAL PRODUCTS (continued)Page # 22 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 21 Dross storage Intalco shall limit storage of dross to only thecasthouse building extension.Intalco shall comply with Condition E23.E 22 Opacity Opacity shall not exceed 5% for more than sixminutes 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 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof the system that, at a minimum, includes a visual check forvisible emissions. Intalco shall record the observations of theparameters assessed in the inspection log. Any time visibleemissions are present, Intalco shall take corrective action assoon as practical but within 24 hours. Intalco shall record theresults of corrective actions taken in the inspection log.E 24 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall determine and demonstrate compliance with theemission limit by using natural gas consumption to calculateparticulate emissions. Intalco shall calculate worst-caseparticulate emissions by using an AP-42 emission factor (7.6pounds PM10/1e+6 cubic feet of natural gas from Section 1.4,Small Industrial Boilers) for particulate generated from naturalgas combustion, the volume of natural gas combusted by thefurnace, and the furnace design excess air settings. Intalcoshall report the PM emissions from the furnace in therespective monthly air monitoring report submitted toEcology. Intalco shall comply with Conditions H1 and E28.WAC 173-400-050 (1) & WAC173-401-615(2)(a)(Recordkeeping); and WAC 173-401-630(1) (GeneralCompliance Requirements).E 25 Opacity Opacity shall not exceed 5% for more than sixminutes in anysixtyminuteperiod.Intalco shall comply with Conditions H1, H3.b, and E28. DE 02AQIS-3967E 26 SO2 SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with condition H 1 and H8. WAC 173-400-040 (6)E 27 NOx Emissions of NOx shall not exceed 83 ppmcorrected to 3% oxygenIntalco shall conduct an annual source test on the furnaceduring full operation using EPA RM 7E for NOx and RM 3Afor Oxygen as per 40 CFR Part 60, Appendix A, or anotherEPA approved method. Intalco shall comply with ConditionE27 and H14. Intalco can reduce the frequency of sourcetesting to once every 5 years if condition H6 is met.DE 02AQIS-3967E28 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof the furnace that, at a minimum, includes a visual check forvisible emissions. Intalco shall record the observations of theparameters assessed in the inspection log. Any time visibleemissions are present, Intalco shall take corrective action assoon as practical but within 24 hours. Intalco shall record theresults of corrective actions taken in the inspection log.DE 02AQIS-3967Order No. 02AQIS-3967271 Inert Dross Coolingand Handling System314 HomogenizationFurnaceII E METAL PRODUCTS (continued)Page # 23 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 29 PM Emissions of PM shall not exceed 0.005grains/dscf.Intalco shall conduct a source test upon Ecology’s requestusing EPA RM 5 per 40 CFR 60, Appendix A, or another EPAapproved method. Intalco shall comply with Conditions H1,E31, and H14.DE 02AQIS-3967E 30 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and E31. See Condition H3.a.E 31 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof the baghouse, that, at a minimum, includes a visual checkof the following parameters: visible emissions, leaks inductwork and housing, excess vibration, and pressure drop.Intalco shall record the observations of the parametersassessed in the inspection log. Any time visible emissionsare present, Intalco shall take corrective action as soon aspractical but within 24 hours. Intalco shall record the resultsof corrective actions taken in the inspection log.DE 02AQIS-3967Remelt Furnace 217;Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, and 19; and theMHD Holding Furnaces:220a, 220b, 221a, 221bE 32 PM and HCL For a group 1 furnace that is not amelting/holding furnace processing only cleancharge, emissions of PM shall not exceed: 0.20kg of PM per Mg (0.40 lb of PM per ton) offeed/charge. For a group 1 furnace that is not amelting/holding furnace processing purchasedscrap charge, emissions of HCl shall not exceed:0.20 kg of HCl per Mg (0.40 lb of HCl per ton) offeed/charge.40CFR 63.1505(i)(1); 40CFR63.1505(i)(4); 40CFR63.1505(i)(6); 40CFR63.1505(k)(4); 40 CFR Part63.1511(a); 40 CFR Part63.1510(c);40 CFR Part63.1510(d); 40 CFR Part63.1510(e); 40 CFR Part63.1510(f); 40 CFR Part63.1510(u); 40 CFR Part63.1513(b)E 33 Dioxin/Furan(D/F)For a group 1 furnace that is not amelting/holding furnace processing purchasedscrap charge, Intalco must not exceed: 15 μg ofD/F TEQ per Mg.40CFR63.1505(i)(3);40CFR63.1505(k)(4); 40 CFRPart 63.1510(u)E34 ScrapInspectionProgramIntalco shall comply with the Scrap InspectionProgram outlined in Intalco's OM&M plan.Intalco shall comply with the Scrap Inspection Programoutlined in Intalco's OM&M plan.40CFR 63.1510(p)Remelt Furnace 217315 Dross/SiliconStorage Baghouse(55,000 acfm)II E METAL PRODUCTS (continued)Intalco shall determine compliance with the PM, HCl, and D/Femission limits for individual furnaces. Intalco shall submit asite-specific test plan meeting the requirements of 40 CFR63.6 and conduct a performance test once every five yearsusing the procedures in the approved site specific test plan todemonstrate compliance with applicable emission limits.Intalco shall use equation 7 in 40 CFR Part 63.1513(b) todetermine 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 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 35 Solid ReactiveFluxIntalco shall use solid reactive flux in the holdingfurnaces only.Intalco shall measure and record the weight and time of solidreactive flux addition to the holding furnaces40CFR 63.1506(n)Intalco must, for each group 1 furnace (includinga group 1 furnace that is part of a secondaryaluminum processing unit) without add-on airpollution control devices: 1) Maintain the totalreactive chlorine flux injection rate for eachoperating cycle or time period used in theperformance test at or below the average rateestablished during the performance test. 2)Operate each furnace in accordance with thework practice/pollution prevention measuresdocumented in the OM&M plan and within theparameter values or ranges established in thecurrent version of the OM&M plan.Intalco must, for each group 1 furnace (including a group 1furnace that is part of a secondary aluminum processing unit)without add-on air pollution control devices: 1) Maintain thetotal reactive chlorine flux injection rate for each operatingcycle or time period used in the performance test at or belowthe average rate established during the performance test. 2)Operate each furnace in accordance with the workpractice/pollution prevention measures documented in theOM&M plan and within the parameter values or rangesestablished in the current version of the OM&M plan.3) Operate each group 1 melting/holding furnacesubject to the emission standards in§63.1505(i)(2) using only clean charge as thefeedstock.3) Operate each group 1 melting/holding furnace subject tothe emission standards in §63.1505(i)(2) using only cleancharge as the feedstock.E37 Clean chargecertification forGroup 1furnace subjectto the emissionstandards in§63.1505(i)(2)using only cleancharge asfeedstockIntalco shall submit a certification of compliance with theapplicable operational standard for clean charge materials in§63.1506(n)(3) for each 6-month reporting period. Eachcertification must contain the information in§63.1516(b)(2)(iv).II E METAL PRODUCTS (continued)E 36 Operation andMaintenance ofGroup 1Furnaceswithout Add-OnControl Devices40CFR63.1506(n)Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, and 19Page # 25 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 38 PM For an in-line fluxer that uses reactive fluxmaterial, Intalco shall not exceed: 0.005 kg ofPM per Mg (0.01 lb of PM per ton) offeed/charge.40CFR 63.1505(j)(2); 40 CFRPart 63.1510(u)E 39 HCl For an in-line fluxer that uses reactive fluxmaterial, Intalco must not exceed: 0.02 kg ofHCl per Mg (0.04 lb of HCl per ton) offeed/charge.40CFR63.1505(j)(1)E 40 Inline FluxerComplianceIntalco shall determine compliance with the PMand HCl emission limits for in-line fluxers.Intalco shall measure the rate of reactive gas flux addition tothe in-line fluxer and assume that all reactive flux added tothe in-line fluxer is emitted as HCl.40CFR63.1512(h)(2)E41 Reactive FluxUseIntalco shall use reactive gas flux in the in-linefluxers only.Intalco shall record and report any reactive gas flux used in inline fluxers.E42 Chlorine FluxInjection RateIntalco shall continuously measure and record the weight ofgaseous 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 gaseousreactive flux in the in-line fluxers.40 CFR Part 63.1512(o)II E METAL PRODUCTS (continued)Intalco shall assume that all chlorine added to the in-linefluxers is converted to HCl and 1000 pounds of PM areassumed to be emitted for every ton of chlorine gas added tothe in-line fluxers (per Compilation of Air Pollutant EmissionFactors, AP-42, fifth Edition, Volume 1 (Stationary Point andArea Sources) Section 12.8: Secondary AluminumOperations.)" Intalco shall comply with procedures andconditions in the approved OM&M Plan to demonstratecompliance with applicable emission limits.6 In-fluxers in CastingPits 1-6Page # 26 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityIntalco must provide and maintain easily visiblelabels posted at each group 1 furnace, group 2furnace and in-line fluxer as described in 40CFR 63.1515(b)(3) that identifies the applicableemission 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 calendarmonth to confirm that posted labels as required by theoperational standard in §63.1506(b) are intact and legible.40CFR63.1506(b);40CFR63.1510(c);40CFR63.1512(r)(1) The type of affected source or emission unit(e.g., group 1 furnace, group 2 furnace, in-linefluxer).(2) The applicable operational standard(s) andcontrol method(s) (work practice or controldevice). This includes, but is not limited to, thetype of charge to be used for a furnace (e.g.,clean scrap only, all scrap, etc.), flux materialsand addition practices, and the applicableoperating parameter ranges and requirementsas incorporated in the OM&M plan.For each affected source or emission unitsubject to an emission limit in kg/Mg (lb/ton) offeed/charge, Intalco shall: (1) Install and operatea device that measures and records orotherwise determine the weight of feed/charge(or throughput) for each operating cycle or timeperiod used in the performance test (except asprovided in paragraph (3) of this Requirement);(2) Operate each weight measurement systemor other weight determination procedure inaccordance with the current version of theOM&M plan; (3) Intalco may choose to measureand record aluminum production weight from anaffected source or emission unit rather thanfeed/charge weight to an affected source oremission unit, provided that (i) The aluminumproduction weight, rather than feed/chargeweight is measured and recorded for allemission units within a SAPU; and (ii) Allcalculations to demonstrate compliance with theemission limits for SAPUs are based onaluminumFor each affected source or emission unit subject to anemission limit in kg/Mg (lb/ton) or ug/Mg (gr/ton) offeed/charge Intalco must install, calibrate, operate, andmaintain a device to measure and record the total weight offeed/charge to, or the aluminum production from, the affectedsource or emission unit over the same operating cycle or timeperiod used in the performance test. Feed/charge oraluminum production within SAPUs must be measured andrecorded on an emission unit-by-emission unit basis. (1) Theaccuracy of the weight measurement device or proceduremust be +/-1 percent of the weight being measured. Theowner or operator may apply to the permitting agency forapproval to use a device of alternative accuracy if theaccuracy cannot be achieved as a result of equipment layoutor charging practices. A device of alternative accuracy willnot be approved unless the owner or operator providesassurance through data and information that the affectedsource will meet the relevant emission standard.production weight rather than feed/chargeweight.(2) Intalco must verify the calibration of the weightmeasurement device in accordance with the schedulespecified by the manufacturer, or if no calibration schedule isspecified, at least once every 6 months.E44 ProductionWeight40CFR63.1506(d) and 1510(e)E 43 LabelingRemelt Furnace 217,Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 19 MHDFurnaces 6 In-fluxersin Casting Pits 1-6II E METAL PRODUCTS (continued)Page # 27 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 45 CorrectiveActionIntalco shall take corrective action, when a processparameter deviates from the value or range establishedduring the performance test and incorporated in the currentapproved OM&M plan, as expeditiously as practicable inaccordance with good air pollution control practices forminimizing emissions. Corrective actions taken must includethe follow-up actions necessary to return the process orcontrol device parameter level(s) to the value or range ofvalues established during the performance test and steps toprevent the likely recurrence of the cause of a deviation.Intalco shall comply with the corrective action procedures inthe current Ecology approved OM&M Plan.40CFR63.1506(p)E 46 Operation,Maintenance,and Monitoring(OM&M) PlanIntalco shall comply with the provisions of the currentapproved OM&M plan and update the OM&M plan asnecessary for each affected source and emission unit.40CFR63.1510(b)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 theperformance test. 2) Intalco shall assure that the accuracy ofthe weight measurement device is +/-1 percent of the weightbeing measured by using the following. a) solid flux vendorcertification that the weight of solid flux in each package hasbeen measured to an accuracy of +/- 1% as an alternativemeasurement system (Ecology approved). and b) a reactivegas flux flow monitor with an accuracy of +/-1% of the fullscale 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 weightmeasurement device in accordance with the schedulespecified by the manufacturer, or if no calibration is specified,at least once every six months. 4) Intalco shall, for eachoperating cycle or time period used in the performance test,calculate and record the gaseous or solid reactive fluxinjection rate using the procedure in 40 CFR Part 63.1512(o)or an EPA approved alternative as authorized in 40 CFR63.1510(j)(5)).5) Intalco shall record, for each 15-minute block period duringeach operating cycle or time period used in the performancetest during which reactive fluxing occurs, the time, weight,and type of flux for each addition of: (i) Gaseous or solidreactive flux other than chlorine; and (ii) Solid reactive flux.II E METAL PRODUCTS (continued)Weightmeasurementdevice (thiscondition doesnot apply to theremelt furnace).Intalco shall operate and maintain a device tocontinuously measure and record the weight ofgaseous or solid reactive flux injected to eachaffected source or emission unit.40CFR63.1510(j)E 47Remelt Furnace 217,Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 19 6 In-fluxersin Casting Pits 1-6Page # 28 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE 48 Test Methods Intalco shall use following EPA methods (from appendix A of40 CFR part 60) or EPA approved alternatives to determinecompliance with the applicable emission limits or standards:(1) Method 1 for sample and velocity traverses. (2) Method 2for velocity and volumetric flow rate. (3) Method 3 for gasanalysis.(4) Method 4 for moisture content of the stack gas.(5) Method 5 for the concentration of PM. ( 6) Method 9 forvisible emission observations. (7) Method 23 for theconcentration of dioxins and furans. (8) Method 25A for theconcentration of THC (see definition in the glossary), aspropane.40CFR63.1511(c) 40CFR63.1511(d)E 49 ComplianceInformationIf the group 1 furnace processes only cleancharge, Intalco must conduct emission tests tosimultaneously measure emissions of PM andHCl at the furnace exhaust outlet. Each testmust be conducted while the group 1 furnace(including a melting/holding furnace) processesonly clean charge. Intalco may choose todetermine the rate of reactive flux addition to thegroup 1 furnace and assume, for the purposesof demonstrating compliance with the SAPUemission limit, that all reactive flux added to thegroup 1 furnace is emitted. Under thesecircumstances, the owner or operator is notrequired to conduct an emission test for HCl.Intalco shall demonstrate compliance in accordance with thesite specific monitoring plan submitted per §63.1510(o).40CFR63.1512(e)(2)E 50 Startup,Shutdown, andMalfunctionReportsIntalco shall record and report if an action taken during astartup, shutdown, or malfunction is not consistent with theprocedures in the current version of the SS&M Plan asdescribed in §63.6(e)(3).40 CFR Part 63.1516(a)II E METAL PRODUCTS (continued)Remelt Furnace 217,Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 196 In-fluxers in CastingPits 1-6PE=Page # 29 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityIntalco shall submit semiannial reports within 60 days afterthe end of each 6-month reporting period. Each report shallcontain the information specified in 40 CFR 63.10(c). Whenno deviations of parmaeters have occured, Intalco shallsubmit a report stating that no excess emissions occcurredduring the reporting period. Intalco shall sumit an excessemissions report if any of the following occur during a 6-month reporting period: 1) An excursion of a compliantprocess or operating parameter value or range (e.g. totalreactive chlorine flux injection rate, definition of acceptablescrap, or other approved operating parameter). 2) An actiontaken during a startup, shutdown, or malfunction was notconsistent with the procedures in the plan as described in§63.6(e)(3). 3) An affected source was not operatedaccording to the requirements of this subpart. Intalco shallsubmit semiannual reports within 60 days after the end ofeach 6-month period. Intalco shall submit the informationspecified in §63.10(c). When no deviationsof parametershave occurred, Intalco shallstate in the semiannual report that no excess emissionsoccurred during the reporting period.E52 (in-linefluxers are notsubject to thiscondition)Certifications Intalco shall include in each report each of thesecertifications, as applicable: (iv) For each group 1 holdingfurnace: ``Each group 1 furnace without add-on air pollutioncontrol devices subject to emission limits in Sec.63.1505(i)(2) processed only clean charge during thisreporting period." (v) For each group 2 furnace: ``Only cleancharge materials were processed in any group 2 furnaceduring this reporting period, and no fluxing was performed orall fluxing performed was conducted using only nonreactive,non-HAP-containing/non-HAP-generating fluxing gases oragents, except for cover fluxes, during this reporting period.''40 CFR Part 63.1516(b)(2)(iv)and (v)E53 (in-linefluxers are notsubject to thiscondition)PerformancetestsIntalco shall submit the results of any performance testconducted during the reporting period, including onecomplete report documenting test methods and procedures,process operation, and monitoring parameter ranges orvalues for each test method used for a particular type ofemission point tested.40 CFR Part 63.1516(b)(3)Remelt Furnace 217,Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 196 In-fluxers in CastingPits 1-6SemiannualReports andExcessEmissionsReports40 CFR Part 63.1516(b)(1); 40CFR 63.10©; 40 CFR63.10(e)(3)E 51II E METAL PRODUCTS (continued)Page # 30 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityE54 AnnualComplianceCertificationIntalco shall certify continuing compliance based upon thefollowing conditions:(1) Any period of excess emissions, asdefined in 40CFR Part 63.1516(b)(1), that occurred duringthe year were reported as required by this subpart; and (2) Allmonitoring, recordkeeping, and reporting requirements weremet during the year in an annual compliance certificationsubmitted to Ecology no later than January 31 of the followingyear.40 CFR Part 63.1516(c)E55 Records Intalco shall maintain records in accordance with §63.10(b)for at least 5 years.40 CFR Part 63.1517 (a); 40CFR Part 63.1517 (b)(5); 40CFR Part 63.1517 (b)(7);40CFR Part 63.1517 (b)(8);40CFR Part 63.1517 (b)(9);40CFR Part 63.1517 (b)(13);40CFR Part 63.1517 (b)(15);40CFR Part 63.1517 (b)(16);40CFR Part 63.1517 (b)(17); 40CFR Part 63.10(b)Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityF1 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.e and F23. See Condition H2.eF2 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a and F23. See Condition H3.aF3 SO2SO2 concentration shall not exceed 1000 ppmcorrected to 7% oxygen based on the averageof any period of 60 consecutive minutes.Intalco shall comply with condition H 1, H 8 and F23. WAC 173-400-040 (6)F4 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.e and F23. See Condition H2.eF5 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F24. See Condition H3.a.F6 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g and F24. See Condition H2.gF7 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3, and F24. See Condition H3.a.207 Annex Paste PlantBaghouse Stack (5,550acfm)II E METAL PRODUCTS (continued)195 Primary WTP KilnWet Scrubber (2,700acfm)Remelt Furnace 217,Holding Furnaces: 4, 5,7, 8, 10, 11, 13, 14, 16,17, 18, 196 In-fluxers in CastingPits 1-6II F ANCILLARY208 Ladle CleaningBaghouse (14,100acfm)Page # 31 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityF8 PM Emissions of PM shall not exceed 5.0 tons ofPM per year.Order DE02AQIS-3967F9 PM Emissions of PM shall not exceed 0.01 grainsper dscf.Order DE02AQIS-3967F10 Opacity Opacity shall not exceed 5% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.b, and F12. Order DE02AQIS-3967F11 TF Emissions of TF shall not exceed 2.7 tons peryear.Intalco shall conduct source tests once every 5 years andupon Ecology’s request using EPA RM 5/13B as per 40 CFR60, Appendix A, or another EPA approved method. Intalcoshall comply with condition F12.Order DE02AQIS-3967F12 FunctionalIntegrityInspection Intalco shall conduct a weekly functional integrity inspectionof the baghouse, that, at a minimum, includes a visual checkof the following parameters: visible emissions, leaks inductwork and housing, excess vibration, and pressure drop.Intalco shall record the observations of the parametersassessed in the inspection log. Any time visible emissionsare present, Intalco shall take corrective action as soon aspractical but within 24 hours. Intalco shall record the resultsof corrective actions taken in the inspection log.Order DE02AQIS-3967209 Autogenous MillBaghouse(45,000 acfm)II F ANCILLARY (continued)Intalco shall conduct a source once every 5 years and uponEcology’s request using EPA RM 5 per 40 CFR 60, AppendixA, or another EPA approved method. Intalco shall include theresults of the source test in the respective monthly airmonitoring report submitted to Ecology. Intalco shall complywith Condition F12.Page # 32 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityF13 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and F24. WAC 173-400-060 & WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).F14 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F24. See Condition H3.a.F15 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and F24. Same Authority as ConditionF13.F16 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F24. See Condition H3.a.F17 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and F24. Same Authority as ConditionF13.F18 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F24. See Condition H3.a.F19 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g and F24. See Condition H2.gF20 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F24. See Condition H3.a.F21 PM Emissions of PM shall not exceed 0.1grains/dscf.Intalco shall comply with Conditions H1, H2.g, and F25. Same Authority as ConditionF13.F22 Opacity Opacity shall not exceed 20% for more than sixminutes in any sixty minute period.Intalco shall comply with Conditions H1, H3.a, and F25. See Condition H3.a.195 Primary WasteTreatment Plant(PWTP) Kiln WetScrubberF23Intalco shall comply with Condition H4.g See Condition H4.gEmission Units #'s:207, 208, 209, 210,214, 216, 229 and 274F24Intalco shall comply with Condition H4.a See Condition H4.aEmission Unit #: 280 F25Intalco shall comply with condition H4.c. See Condition H4.c308 Paint Shop G1 VOC Recordkeeping Intalco shall track VOC usage through purchase records orother methods approved by Ecology. Intalco shall reportannual VOC usage in the December Air Monitoring Reportsubmitted to Ecology.WAC 173-415-060(2)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).216 Alumina Ore ShipUnloading BaghouseStack (15,000 acfm)229 Brick CrushingFacility Baghouse Stack(20,000 acfm)280 Annex CathodeAssembly Area RoofVents274 Alumina Silo #4Truck LoaderBaghouse Stack (5,000acfm)FunctionalIntegrityII F ANCILLARY (continued)Inspection214 Alumina Ore Silo#4 Rail Car UnloaderBaghouse Stack(19,600 acfm)II G MAINTENANCEPage # 33 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityAll emission units andcontrol systems onIntalco’s facilityH1 Operation andMaintenance(O&M)At all times, including periods of abnormaloperation and upset, Intalco shall, to the extentpracticable, maintain the facility, and operateand maintain air pollution control equipment in amanner consistent with good air pollution controlpractice. Determination of whether acceptableoperating and maintenance procedures arebeing used will be based on informationavailable to Ecology which may include, but isnot limited to, monitoring results, opacityobservations, visible emission observations,inspections of the source, and reviews todetermine that the plant is following its O & Mprocedures.Intalco shall comply with applicable PM and Opacitymonitoring requirements in the respective unit specificconditions and the applicable Functional Integrity Inspectionrequirements in Condition H4 for the affected emission unitor emission control.WAC 173-415-030(6)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).H2.a Intalco shall conduct a source test annually and uponEcology’s request using EPA RM 5 per 40 CFR 60, AppendixA, or another EPA approved method. Intalco shall submit theresults of the source test in the respective monthly airmonitoring report submitted to Ecology per Condition H14.WAC 173-400-060 [effective3/22/91; approved into the SIPon 8/20/93]WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).H2.b Intalco shall conduct a source test once every two yearsand upon Ecology’s request using EPA RM 5 per 40 CFR 60,Appendix A, or another EPA approved method . Intalco shallsubmit the results of the source test in the respective monthlyair monitoring report submitted to Ecology per Condition H14.Order DE 02AQIS-3967WAC 173-400-050 (1) [effective3/22/91; approved into the SIPon 8/20/93]WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).H2.c Intalco shall conduct a source test once every two yearsand upon Ecology’s request using EPA RM 5 per 40 CFR 60,Appendix A, or another EPA approved method . Intalco shallsubmit the results of the source test in the respective monthlyair monitoring report submitted to Ecology per Condition H14.Same authority as for ConditionH2.a.H2.d Intalco shall conduct a source test every two years onalternating holding furnaces during full operation and uponEcology’s request using EPA RM 5 per 40 CFR 60, AppendixA, or another EPA approved method. Intalco shall submit theresults of the source tests in the respective monthly airmonitoring report submitted to Ecology per Condition H14.Same authority as for ConditionH2.a.Emission units that aresubject to grainloadingrequirmentsPMII H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)H2 PM Limit (see individual emission unit for thelimit).Page # 34 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityH2.e Intalco shall conduct a source test once every 5 yearsand upon Ecology’s request using EPA RM 5 per 40 CFR 60,Appendix A, or another EPA approved method. Intalco shallsubmit the results of the source test in the respective monthlyair monitoring report submitted to Ecology per Condition H14.Same authority as for ConditionH2.a.H2.f Intalco shall conduct a source test on each MHD furnaceafter each furnace is put back into operation and thenconduct source tests once every five years on alternatingMHD furnaces during full operation and upon Ecology’srequest using EPA RM 5 per 40 CFR 60, Appendix A, oranother EPA approved method. Intalco shall submit theresults of the source tests in the respective monthly airmonitoring report submitted to Ecology per Condition H14.Same authority as for ConditionH2.a.H2.g Intalco shall conduct a source test upon Ecology’srequest using EPA RM 5 per 40 CFR 60, Appendix A, oranother EPA approved method. Intalco shall submit theresults of the source test in the respective monthly airmonitoring report submitted to Ecology per Condition H14.Same authority as for ConditionH2.a.Opacity shall not exceed an average of 20% formore than six consecutive minutes in any sixtyminute period.H3.a Intalco shall conduct source tests upon Ecology’srequest using EPA RM 9 per 40 CFR 60, Appendix A, oranother EPA approved method. If visible emissions areobserved at any time, Intalco shall comply with Condition H5.WAC 173-415-030 (3)[approved into the SIP on2/19/91; state rule effective3/22/91]WAC 173-400-040(1)WAC 173-401-615(1)(b) (PeriodicMonitoring), WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).Opacity shall not exceed an average of 5% formore than six consecutive minutes in any sixtyminute period.H3.b Intalco shall conduct source tests upon Ecology’srequest using EPA RM 9 per 40 CFR 60, Appendix A, oranother EPA approved method. If visible emissions areobserved at any time, Intalco shall comply with Condition H5.Order No. 02AQIS-3967H4.a Intalco shall conduct a weekly functional integrityinspection of the baghouse, that, at a minimum, includes avisual check of the following parameters: visible emissions,leaks in ductwork and housing, excess vibration, andpressure drop. Intalco shall comply with Condition H5.WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).H4.b Intalco shall continuously monitor coke and air flow inaccordance with 40 CFR 63.848(f)(1) and conduct a dailyvisible emission check and a weekly functional integrityinspection that, at a minimum, includes a visual check of thefollowing parameters: visible emissions, leaks, pump outletpressure, and amperage to recirculation pumps. Intalco shallcomply with Condition H5.Order No. 02AQIS-3967H4.c Intalco shall conduct a weekly functional integrityinspection of the vents that, at a minimum, includes a visualcheck of visible emissions. Intalco shall comply withCondition H5.Same authority as ConditionH4.aOpacityEmission units subjectto an opacity limitH3PM (continued)II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)Emission units that aresubject to grainloadingrequirmentsH2 (continued)Emission units that aresubject to a functionalintegrity inspectionH4 FunctionalIntegrity (FI)InspectionPage # 35 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityH4.d Intalco shall conduct a daily functional integrityinspection of the potroom baghouses that, at a minimum,includes a visual check of the following parameters: visibleemissions, leaks in ductwork and housing, excess vibration,pressure drop, and sight glass readings. Intalco shall complywith Condition H5.Order No. 02AQIS-3967H4.e Intalco shall conduct a weekly functional integrityinspection of all the pot hoods. During that inspection, Intalcoshall classify the condition of each hood as good, fair, orpoor. Intalco shall direct hood repair crews to begin the repairprocess for the poor condition hoods during their first shiftafter the inspection. Hoods classified as fair shall be repairedwithin 15 days. Intalco shall conduct a daily functionalintegrity inspection of the potroom wet scrubbers that, at aminimum, includes a visual check of the followingparameters: visible emissions (per 40 CFR 63.848(g)Primary Aluminum MACT), processing adequate volumes ofwater and air (per Condition 40 CFR 60.848(f)(5)(PrimaryAluminum MACT)). Intalco shall comply with Condition H5.Order No. 02AQIS-3967H4.f Intalco shall conduct a weekly functional integrityinspection of the furnaces that, at a minimum, includes avisual check of visible emissions. Intalco shall comply withCondition H5.Same authority as ConditionH4.aH4.g Intalco shall conduct a weekly functional integrityinspection of the PWTP kiln wet scrubber that, at a minimum,includes a visual check of the following parameters: visibleemissions, processing adequate volumes of water and air.Intalco shall comply with Condition H5.Same authority as ConditionH4.aH4.h Intalco shall conduct a weekly functional integrityinspection of the baghouse that , at a minimum, includes avisual check of the following parameters: visible emissions,leaks in ductwork and housing, and excess vibration. Intalcoshall comply with Condition H5.Same authority as ConditionH4.aII H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)Emission units subjectto a functional integrityinspectionH4 (continued) FI (continued) Inspection (continued)Page # 36 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityAll emission units andcontrol systems subjectto an opacity limit andthose subject tofunctional integrityinspections.H5 RecordingInspections andtakingCorrectiveactionsRecording Inspections and taking CorrectiveactionsIntalco shall record the observations and readings of theparameters assessed (e.g., amperage to recirculation pumpson the PFTS) in the emission unit’s inspection log. If visibleemissions are present or another problem is observed,Intalco shall take corrective action as soon as practical butwithin 24 hours. Intalco shall record the results of correctiveactions taken in the inspection log. Taking a corrective actionshall include but not be limited to preparing a work order,ordering parts, shutting down the unit, or completing therepair that eliminates the respective problem. Correctiveactions shall be taken by employees or contractorsdesignated byIntalco.WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).Emission units subjectto source testingrequirments todetermine compliancewith an emission limit.H6 MonitoringFrequencyReductionMonitoring Frequency Reduction Intalco can reduce monitoring frequencies to the frequenciesdefined in the respective unit specific conditions if each ofthree consecutive source tests demonstrates that theemission rate is < 75% of the applicable limit. Intalco shallresume the original source testing frequency any time asource test demonstrates emissions have increased above75% of the applicable limit. Intalco shall submit a letternotifying Ecology that the monitoring frequency will bereduced. The notification shall demonstrate the justificationfor the reduced monitoring frequency and schedule. Intalcoshall submit the notification to Ecology within 60 days afterthe last source test used to make the demonstration.WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).a. Intalco shall conduct source tests upon Ecology’s requestusing EPA RM 6 per 40 CFR 60, Appendix A, or another EPAapproved method. b. Intalco shall determine total facility-wideSO2 emissions by summing the SO2 generated from thepotlines and the anode bake ovens. Intalco shall calculateSO2 emissions from the potlines, anode bake ovens, andpaste plant by using the mass balance calculation inCondition D16 (using the daily aluminum production rate andaverage sulfur content for the month being evaluated).Intalco shall assume, in the mass balance calculation, that100% of the sulfur in coke and raw materials converts toSO2. Intalco shall calculate the SO2 generated by natural gascombustion using an Ecology approved emission factor asdescribed in Condition H13.WAC 173-415-030(5)(a)WAC 173-400-040(6)WAC 173-401-615(1)(b) (PeriodicMonitoring), WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).c. Intalco shall report the aluminum production; SO2emissions in pounds per ton of aluminum produced, the sulfurcontent of the coke and pitch, raw material usage,representative raw material sulfur analysis and anyexceedences of the SO2limits in the monthly air monitoringreports submitted to Ecology. d. Intalco shall maintainelectronic records of aluminum production, SO2 emissions inpounds per ton of aluminum produced, the sulfur content ofthe coke and pitch, raw material usage, and representativeraw material sulfur analysis of raw material usage for aminimum of 5 years.247 Plantwide SulfurDioxide Emissions(generation points arethe aluminum reductionpots, anode bakeovens, green carbonheaters and mixers,emergency generators,and natural gascombustion units)II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)SO2H7 Total emissions of SO2from all emissions unitsshall not exceed thirty grams of sulfur dioxideper kilogram of aluminum produced on amonthly average (sixty pounds per ton ofaluminum produced).Page # 37 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityAll emission unitssubject to the 1000ppm limit in WAC 173-400-040(6) and WAC173-415-030(5)(b)H8 SO2Intalco shall not cause or permit the emission ofa gas containing sulfur dioxide in excess of onethousand parts per million corrected to drystandard conditions for an hourly average.Intalco shall conduct source tests upon Ecology’s requestusing EPA RM 6 per 40 CFR 60, Appendix A, or another EPAapproved method. Intalco shall comply with condition H7.WAC 173-415-030(5)(b)WAC 173-400-040(6)WAC 173-401-615(1)(b) (PeriodicMonitoring), WAC 173-401-615(2)(a) (Recordkeeping); andWAC 173-401-630(1) (GeneralCompliance Requirements).Intalco shall:a. Intalco shall continue to monitor ambient fluoride at themonitoring station identified as station #2 continuously for 24hours a day every day of the year in accordance with theFluoride Ambient Monitoring procedures outlined in Intalco’sapproved Air Monitoring Plan. Station #2 is located atLatitude 48 degrees 50 minutes 44 seconds and Longitude122 degrees 41 minutes 35 seconds (approximately 1.05miles East Northeast of the center of the potlines). Intalco willkeep stations 1 and 5 in place. Ambient fluoride monitoring isnot required at stations 1 and 5.b. . Intalco shall continue monitoring ambient fluoride at theambient monitoring station for a minimum period of 60 daysafter a shutdown of all potlines.c.Intalco shall report the data collected from the ambientmonitoring station in the respective monthly air reportssubmitted to Ecology. Intalco shall report the ambient data ina format that will allow a comparison of the data to theambient fluoride standards in WAC 173-481-110 (2)(a)through 2(e).d. . Intalco shall determine the mass of gaseous fluorideemitted per day (pounds/day) from the facility (averaged on amonthly basis). Intalco shall report the average pounds ofgaseous fluoride emitted from the facility per day in therespective monthly air monitoring report submitted toEcology.e. Intalco shall follow the approved forage sampling andanalysis plan in Intalco’s approved Air Monitoring Plan.f. Intalco shall continue forage monitoring (per ConditionH9.e) through the end of the growing season if a shutdownoccurs during the growing season.g. Intalco shall report the forage data collected (in accordancewith the Forage Sampling Plan in Intalco’s approved AirMonitoring Plan) in the respective monthly air monitoringreports submitted to Ecology. Intalco shall report the data ina format that will allow a comparison of the forage data to theforage standards in WAC 173-481-100 (2)(a) through 2(c).II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)H9 Fluorideemissions.(State Only)The emissions of gaseous fluoride and theforage fluoride content shall not exceed therespective ambient and forage fluoridestandards in WAC 173-481-110 (2) (a) through(e) and WAC 173-481-100 (2)(a) through 2(c).Order No.DE 03AQIS-5550WAC 173-415-030(1)(a) andWAC 173-481.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, 316Page # 38 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of Authorityh. Intalco shall maintain electronic records of the datacollected for compliance with the conditions above for aminimum of 5 years.i. Ecology may impose additional requirements if Intalco’sgaseous fluoride or forage monitoring results exceed thestandards in WAC 173-481.j. Intalco shall develop and submit to Ecology a draft AirMonitoring Plan containing the procedures for ambientfluoride and forage fluoride content monitoring outlined in theconditions H9.a - H9.h above for review within 60 days ofissuance of this order. Ecology shall provide comment andapprove a plan that meets the requirements of this orderwithin 60 days of receipt of the plan. Intalco shall implementall requirements of the plan within 60 days of Ecology’sapproval. Prior to implementing any changes to theprocedures outlined in the approved Air Monitoring Plan,Intalco shall submit a written request and receive Ecology’sapproval for the changes. Intalco shall develop and submit toEcology an updated Air Monitoring Plan containing theprocedures for ambient fluoride and fluoride foragemonitoring outlined in the conditions above within 60 days ofissuance of this order for review and approval. Intalco shallimplement all requirements of the plan within 60 days ofEcology’s approval. Prior to implementing any changes tothe procedures outlined in the approved AirMonitoring Plan. Intalco shall submit a written request andreceive Ecology’s approval for the changes.235 Plantwide Usageof VOC ContainingProductsH10 VOC Recordkeeping and Reporting Intalco shall track VOC usage through purchase records.Intalco shall report VOC usage annually in the December AirMonitoring Report per Condition H14.WAC-173-415-060(2)239 (Fugitive Dust fromVehicle Traffic on PavedRoads); 240, 295, and 296(Landfill FugitiveEmissions); 252 (AnodeBlock Hole Blower);257a&b (Crust RecoveryDischarge to Truck fromBins 1& 2);259a&b (CarbonRecovery Discharge toTruck from Bins 1 & 2);275 (AluminumFluoride/Anthracite RailcarUnloading Fugitive Dust);276 (Coke Unloading andTransfer Fugitive Dust);306 (Alumina Ore ShipUnloader Clamshell); 312(Rod Shop InductionFurnace (East))313 (Rod Shop InductionFurnace (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 Fluorideemissions.(State Only)continuedFor each of the emission units identified in column 1 of thiscondition, Intalco shall comply with the reasonable availablecontrol technology (RACT) requirements identified in Intalco'sAir Monitoring Plan per Condition H15. H11.a For emissionunit number 306 (Alumina Ore Ship Unloader Clamshell),Intalco shall limit alumina ore unloading activities to periodswhen sustained winds are less than 35 mph averaged over aperiod of 30 minutes.H11 FugitiveEmissionsIntalco shall use RACT to prevent fugitiveemissions.WAC 173-415-030(4)WAC 173-400-040(3)(a)Order No.DE 03AQIS-5550WAC 173-415-030(1)(a) andWAC 173-481.II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)Page # 39 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004Emission Unit Condition No. Pollutant/ParameterRequirement Monitoring, Reporting and Record-keeping Basis of AuthorityH12 Natural GasConsumptionIntalco shall maintain electronic records of daily natural gasconsumption. Intalco shall report natural gas usage in themonthly Air Monitoring Report per Condition H14.WAC 173-400-040(3)(a)H13 SO2 SO2emissions from natural gas combustionshall not contribute to an exceedance of thefacility wide SO2limit in condition H7.Intalco shall include SO2emissions from natural gascombustion to demonstrate compliance with the SO2limit inCondition H7. Intalco shall use an Ecology approved naturalgas emission factor for SO2emissions.WAC 173-415-030(5)(a)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).All emission unitshaving reportingrequirementsH14 Monthly AirMonitoringReportIntalco shall submit a monthly air monitoring report whichcontains the respective results of the monitoring required inthe conditions of this permit. The report shall be submittedwithin 30 days of the end of each calendar month. Intalcoshall report the data in a format that will allow a comparison ofall the data to the respective emission limits. The format shallinclude a table which summarizes the required source testsconducted during that month and the dates when they werecompleted. Intalco shall submit the results of source tests toEcology in the air monitoring report for the month that theresults are received by Intalco. Ecology will review the formatof the first monthly report submitted after final issuance ofthis AOP and propose recommendations for revisions ifnecessary.WAC 173-415-060(1)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).All emission units withmonitoringrequirementsH15 Air MonitoringPlanIntalco shall update their Air Monitoring Plan (Plan) to includethe sampling and source testing procedures and testingfrequencies that will be used to determine and demonstratecompliance with the emission limits (including ambientfluoride and fluoride content in forage and Primary andSecondary MACT) in the respective conditions of this AOP.The Plan shall include a section which identifies the individualsources of fugitive emissions (identified in Condition H11)and the RACT procedures that will be used to assurecompliance with WAC173-415-030(4). Intalco shall submitthe Plan to Ecology within 90 days of final issuance of thisAOP for review and approval. Ecology shall approve the planwithin 60 days of receipt of the Plan.WAC 173-415-060(1)WAC 173-401-615(1)(b)(Periodic Monitoring), WAC 173-401-615(2)(a) (Recordkeeping);and WAC 173-401-630(1)(General ComplianceRequirements).II H FACILITY-WIDE GENERALLY APPLICABLE REQUIREMENTS (continued)241 Plantwide NaturalGas CombustionEmissionsPage # 40 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004III.1. Duty to complyWAC 173-401-620(2)(a)III.2. Need to halt orreduce activitynot a defenseWAC 173-401-620(2)(b)III.3. Permit actionsWAC 173-401-620(2)(c)III.4. Property rightsWAC 173-401-620(2)(d)III.5. Duty to ProvideInformationWAC 173-401-620(2)(e)III.6. Permit feesWAC 173-401-620(2)(f)III.7 EmissionsTradingWAC 173-401-620(2)(g)III.8 SeverabilityClauseWAC 401-620(2)(h)III.9 Permit AppealsWAC 173-401-620(2)(i)III.10 PermitContinuationWAC 173-401-620(2)(j)III.11 FederallyEnforceableRequirementsWAC 173-401-625III.13 Tampering andFalse StatementsWAC 173-400-105(7) and (8)and 40 CFR 70.11(a)The permittee shall furnish to the permitting authority, within a reasonable time, any information that the permitting authoritymay request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or todetermine compliance with the permit. Upon request, the permittee shall also furnish to the permitting authority copies ofrecords required to be kept by the permit or, for information claimed to be confidential, the permittee may furnish such recordsdirectly to the EPA Administrator along with a claim of confidentiality. Permitting authorities shall maintain confidentialityof suchinformation 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 atimely 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 PERMITThe permittee must comply with all conditions of this chapter 401 permit. Any permit noncompliance constitutes a violation ofchapter 70.94 RCW and, for federally enforceable provisions, a violation of the FCAA. Such violations are grounds forenforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewalapplication.It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce thepermitted 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 thepermittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes oranticipated 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, andother 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 boardandserving it on the permitting authority within thirty days of receipt pursuant to RCW 43.21B.310. This provision for appeal inthissection 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, shallnot expire until the renewal permit has been issued or denied if a timely and complete application has been submitted.Reopening forCauseIII.12All terms and conditions of this permit, including any provisions designed to limit potential to emit, are enforceable by EPA andcitizens 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 beenforceable.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. Suchreopening shall be completed not later than 18 months after promulgation of the applicable requirement. No such reopening isrequired if the effective date of the requirement is later than the date on which the permit is due to expire, unless the originalpermit 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. Uponapproval 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 affectonly 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 thispermit. No person shall render inaccurate any monitoring device or method required under this permit.WAC 173-401-730Page # 41 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004IV.1 MonitoringRecordsWAC 173-401-615(2)(a) andWAC 173-400-105IV.2 InspectionChecklistsWAC 173-401-615(1)(b)IV.3 Changes atSourceWAC 173-401-615(2)(b)IV.4 RecordsRetentionWAC 173-401-615(2)(c)IV.5 Recording ofPermit DeviationWAC 173-401-615(3)(b)IV.6 CertificationsWAC 173-401-520IV.7 Monthly ReportsWAC 173-401-615(3)(a) andWAC 173-415-060IV.8 PermitDeviations/Excess EmissionsWAC 173-401-615(3)(b) andWAC 173-400-107IV.9 EmissionInventoryWAC 173-415-080 and WAC173-400-105(1)IV.10 ComplianceRequirements/CertificationWAC 173-401-510(2)(h)(iii),WAC 173-401-600, WAC 173-401-630(3), and WAC 173-401-630 (5)A. The permittee shall continue to comply with applicable requirements with which the permittee is in compliance; B.Thepermittee shall meet applicable requirements that will become effective during the permit period. C. The permittee shall submitareport to the Department of Ecology and to Region 10 of EPA within 105 days after the close of the calendar year, and everyyear thereafter, certifying compliance with the terms and conditions contained in this permit for the previous calendar year.Theinitial compliance certification shall cover the period from when the permit is effective to the end of the calendar year. Thecertification shall describe the following: i.the permit term or condition that is the basis of the certification; ii.the compliancestatus; 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 certificationperiod. Determination of continuous or intermittent compliance shall be based on compliance during the entire annualcertificationperiod. The PermitteeIV.11Reporting Terms & ConditionsThe permittee shall keep records of any periodic and continuous monitoring required by this permit. These records shall includethe following, where applicable: (i) The date, place as defined in the permit, and time of sampling or measurements; (ii) Thedate(s) analyses were performed; (iii) The company or entity that performed the analyses; (iv) The analytical techniques ormethods used; (v) The results of such analyses; and (vi) The operating conditions existing at the time of sampling ormeasurement.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, submittinga report “promptly” means the following: (1) if the deviation presents a potential threat to human health or safety, the reportshallbe 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 demonstrationsthat 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 ofmonitoring sample, measurement, report, or application. Support information includes all calibration and maintenance recordsand 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, thefollowing information: (i) The person conducting the inspection; (ii) The date/time of the inspection; (iii) Location of theinspection; (iv) The observations made during the inspection; (v) Corrective actions taken if any; (vi) The date and timecorrective action was initiated and completed.The permittee shall keep records describing changes made at the source that result in emissions of a regulated air pollutantsubject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from thosechanges.All reports, renewal applications, and compliance certifications required by this permit shall be submitted to: Department ofEcology, 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, 1200Sixth 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 underChapter 173-401 WAC shall state that, based on information and belief formed after reasonable inquiry, the statements andinformation 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 laterthan 105 days after the end of the calendar year. The permittee shall maintain records of information necessary to substantiateany reported emissions.Report AddressRecordkeeping Terms & ConditionsSECTION IV: GENERAL TERMS AND CONDITIONS OF THE PERMITPage # 42 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004IV.12 AsbestosWAC 173-400-075IV.13 Concealment andMaskingWAC 173-400-040(7)IV.14 Inspection andEntryWAC 173-401-630(2)IV. 15 Application andIssuance of aRenewal PermitWAC 173-401-710(1)&(2)IV.17 InsignificantEmission UnitsWAC 173-401-530(2)(b)IV.18 ProvidingAdditional DataWAC 173-415-060(2)IV.19 Section 112(j)Industrial Boilerand ProcessHeater Phase IIMACTApplication40 CFR 63.50(c) and WAC 173-400-075(5)Pursuant to WAC 173-401-640(2), the Department of Ecology has determined that the requirements listed below do not apply to thefacility, as of the date of permit issuance, for the reasons specified.Pursuant 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 of the date of permitissuance. 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 emission unit or activitydesignated under WAC 173-401-530.SECTION V: PERMIT SHIELD/ INAPPLICABLE REQUIREMENTSFor Ecology to evaluate a plant's emissions or emission control program, each primary aluminum plant shall furnish other datarequested by Ecology.IV.16 StratosphericOzone ProtectionThe 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 formaintenance, service, repair or disposal must comply with the required practices pursuant to § 82.156; ii. Equipment usedduring the maintenance, service, repair or disposal must comply with the standards for recycling and recovery equipmentpursuant to § 82.158; iii. Persons performing maintenance, service, repair or disposal of appliances must be certified by anapproved 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 repairrequirements pursuant to § 82.156; Owners/operators of appliances normally containing 50 or more pounds or refrigerantpurchased and added to such appliances pursuant to § 82.166."; B. Permittee may switch from anyThe 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 CFR Section 82 and RCW70.94.970 (the RCW is a stateonly requirement)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. Theapplication need only cover those emission points and hazardous air pollutants that would be subject to control under the MACTstandard 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 CFRPart 82, Subpart G, without a permit revision but shall not switch to a substitute listed as unacceptable pursuant to suchprogram. [40 CFR 82.174]; C. Any certified technician employed by Permittee shall keep a copy of their certification at theirplace of employment. [40 CFR 82.166(1)]; D. The Permittee shall not willfully release any regulated refrigerant and shall userefrigerant extraction equipment to recover regulated refrigerant that would otherwise be released into the atmosphere. [RCW7070.94.970(2), 970(4)] State Only; E. Compliance with this term and condition will be demonstrated by using a certifiedcontractor or employee.The permittee shall submit a complete permit renewal application to Ecology no later than six months, but no earlier than 18months, prior to the expiration date of the existing permit. Permits being renewed are subject to the same proceduralrequirements, 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 otherwiseviolate provisions in this permit.Inspection and entry. The permittee shall allow the permitting authority or an authorized representative to perform the followingupon presentation of credentials and other documents as may be required by law:(a) Enter upon the permittee's premiseswhere a chapter 401 source is located or emissions-related activity is conducted, or where records must be kept under theconditions of the permit; (b) Have access to and copy, at reasonable times, any records that must be kept under the conditionsof 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 orapplicable requirements.The permittee shall comply with 40 CFR Part 61, subpart M (asbestos NESHAP) and WAC 173-400-075 when conducting anyrenovation or demolition at the facility.Other Terms & Conditions of the PermitPage # 43 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004WAC 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 waste fuel, within themeaning 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 "emission units in a Chapter 401source," per WAC 173-401-200(4), and motor vehicles are not "emission units," as defined inWAC 73-401-200(11).The facility’s operations do not include open burning.Not applicable because there are no "agricultural operations," as defined in WAC 173-430-020(1), at IntalcoThe facility’s emission units are not “solid fuel burning devices” as defined in WAC 173-433-030(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 October23, 1974 and was not modified or reconstructedafter 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 subject to operating permitprogram from registration requirements of WAC173-400-100 through104.Not applicable because WAC173-400-101(7) exempts sources subject to operating permitprogram from registration requirements of WAC173-400-100 through104.Not applicable because WAC173-400-104(4) exempts sources subject to intermin operatingpermit 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 subject to operating permitprogram from registration requirements of WAC173-400-100 through104. (see SIP)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 CreditsFacility was not regulated by a local air authority.WAC 173-406 Acid Rain RegulationNot applicable because Intalco in not an "affected source" within the meaning of WAC 173-406-101(9).WAC173-400-210 Emission requirementsThe facility does not perform work on motor vehicle emission systems.Intalco 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 modified or reconstructed,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 reportingThe 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 categoriesAlcoa is not in an affected CountyFacility is not a significant contributor to the non-attainment status of any designated PM-10non-attainment area.RCW 70.94.531 Transportation demand managementINAPPLICABLE REQUIREMENTSRegulatory CitationReason for InapplicabilityRCW 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 burningWAC173-400-040(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 defined in WAC 173-400-030.WAC173-040-102 Scope of registration and reportingWAC173-400-103 Emission estimatesThe facility does not have and has not used emission reduction credits.WAC173-400-100 Registration of sourcesNone of the listed categories are found at Intalco.Page # 44 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004gr grainHAP hazardous air pollutantMACT maximum available control technologyIEU insignificant emission unitkg kilogramlbs poundsgeneral terms and conditionsg/m3grams per cubic meterFCAA Federal Clean Air Actgpm gallons per minutegt&cdscf dry standard cubic footEPA Environmental Protection Agencydioxins and furansCO 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 petroleum products. Thisactivity 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 Source" within the meaningof 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 meaning of FCAA section183(e)(1)©, and because EPA has not promulgated any rules under section 183(e) thatregulated 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. Condition H15 of the AOPrequires 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 surfacecoating of metal parts or products.WAC 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 foran alternative emissionreduction method. Subsection (2) The facility does not have a gas-fired incinerator used tocomply 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 thissubsection.Regulatory CitationReason for InapplicabilityINAPPLICABLE REQUIREMENTS (continued)million British thermal unitsD/FSECTION VI: ABBREVIATIONSNSPS new source performance standardsPM particulate matterNOx nitrogen oxidesμg/m3micrograms per cubic meterMMBTUPM10particulate 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 Codesulfur dioxidetpy tons per yearSO2VOC 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 compoundsPage # 45 of 45Alcoa Intalco Works Final Air Operating PermitApril 15, 2004