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# • RfCBI/fD DEc 21991 SPOKANECOUNTYAIR

## I'Ot.t.unoN C:O!'/T!WtAUffiOI!rJY



### SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY

IN THE MATTER OF ) ) KArsER ALUMINUM & CHEMICAL ) CORPORATION, TRENTW'OOO WORKS ) ) 

### SPOKANE, WASHINGTON ) 

# ------------------' ORDER NO. 91-Qj 

### ALTERNATE OPACITY LIMIT

I. INTRODUCTION 

### A. Pursuant to RCW 70,94.331.(2)(c) an industry or the air pollutioncontrolauthorityhavingjurisdiction

### maychoose, subject 

### tosubmittingappropriatedatathatthe industryhas quantified, to have any limit on the opacity of emissions from a source whose 

### emissionstandard is stated interms of a weight of particulateper 

### unit volume of air (e.g., grains per dry standard cubic foot) be based on the applicable particulate emission standard for that 

### source, such that any violation of the opacity limit accurately indicates a violation of the applicable particulate emission standard. An 

### opacity limit established pursuant to RCW 70.94.331(2)(c) is re.fet:red to as an, alte.rnate opacity li.mit in 

### this Order. Any alternate opacity limit that would result in increasing- air contaminant emissions in any nonattainment area shall only be qranted if equal or greater emission reductions are 

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provided for by the same source obtaining the revised opacity 

### limit. B. On March 1, 1990the Spokane countyAir Pollution Control Authority ("SCAPCA") Board of Directors adopted Order No. 90-2. order No. 90-2 establishes an alternate opacity limit for the melter and holder furnaces at Kaiser AlWIIimnn & Chemical 

### Corporation's Trentwood Works in Spokane county, Washington.
c. Since the adoption of Order No. 90-2 the United States Congress and the Washington legislature have enacted sweeping changes to state and federal air pollution control legislation. These changes compel certain revisions to order No. 90-2. 

### D. The current particulate emission standard for the Trentwood melter and holder furnaces is o.l.O grains per dry standard cubic foot, pursuant to WAC 173-400-060 and SCAPc;A Regulation II, S 4.01B. Through a series of tests Kaiser represented that emissions from a Trentwood melter or holder furnace with an average opacity of 24 percent during a one hour period will not exceed the grain loading limit. Kaiser also represented that the hourly average opacity of melte.r and holder furnace emissionsdoes not exceed J.O percentmore than 4 percentof the time. E. SCAPCA has detennined that the alternate opacity limit established by this Order will not allow any increase in actual or allowable eiiiissions from the Trentwood Works melter and holder furnaces.



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F. SCAPCA has determined that the requirements of RCW 70.911..331(2) (c) have been met. 

### G. Kaiser sublnitted an Environmental Checklist on the alternate opacity limit. Prior to the date of this Order SCAPCA, 

### in its capacity as lead agency, issued a determination of nonsignificance on the proposed Order. H. On December 12, 1991 the SCAPCA Board and theWashington 

### Department of Ecologyheld a jointpublic hearing on the adoption o:t: this Order, and an its inclusion within the proposed State Implell!Emtation Plan fol:' the Spokane County PM-10 Non-Attainment 

### Area. Notice of the hearing was published in the Spokane Spokesman-Reviewmora than JO days priorto thehearing, andmailed. 

### to the Regional Adlllinistrator c:t: the Environmental ProtectiQn Agency.

II.. ORDER 

### Based on the above information and findings, it is hereby ORDERED: l. 

### Withinthreemonths o:t: 

### the dateofadoption ofthis Order KaiseJ:' shall develop and, upon approval of the Control Officer, implement an operation and maintenance plan for minimizing air pollution frOlll the Trentwood melter and holder furnaces. At a minimum, the operation and maintananoe plan shall addrass procedures for startup, upset conditions (including failure of opacity monitors), timely access for SCAPCA compliance personnel, segregation of scrap material and procedures for calcul-ation of



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two years and subject to review and approval by the Control Officer. Biennial updates shall include any measures adopted pursuant to Paragraph S(e)

### (iii) of this order. 

### 2. At all times, including during startup, shutdown, maintenanceand upset conditions, Kaiser shallmaintain and operate each melter and holder furnace at the Trentwood Works in a manner consistent

### with good airpollution control practice for minimizing 

### emissions. 3. Within 24 months of thedateuponwhichEPA approves this order as part of the Washington state Implenentation Plan Kaiser 

### shall installandcommenceoperationofcontinuousopacitymonitors


### on each melter and holder furnace stack. SUchmonitors shallmeet EPA 

### Performance Specification 1, 40 CFR Part 60, Appendix B (1990). 4. The average opacity from any melter or holder furnace stack atthe TrentwoodWorks shall not exceed 24 percent during any 60 minute operating interval. 5. The average hourly opacity from the melter and holder stacks at the Trentwood Works shall not exceed 10 percent during
more than 4 percent of the operating Hours in a month. For

-purposes of this order an OperatingHour means any 60 minute period

in which charging, melting, fluxing, skimming, holding or dischargingprocesses are occurring in a furnace. compliance shall be determined by dividing the total number of Operating Hours in Which a me1ter or holder recorded an average opacity rate of greater than 10 percent by the aggregate**n~r** of Operating Hours 'in a oa1endar month, and multiplying this fraction by 100.



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of greater than 10 

### percent by the aqqregata. number of Operating Hours in that mo'nth, ami

### multiplying this fraction by 100. 

### 6. In additiontothe other restrictions contained in this order, the average opacity from anymelter orholder furnace stack at the Trentwood Works shall not exceed 40 percent during any JO 

### minuteoperating interval. 7. COlllpliancewith

### the opacity limitdescribed inparagraph 5 shal.l be d&tE!l:lllined using the opacity monitors described in paragraph 3. Compliance With the opacity limit described in paragraph 6 shall be determinedby visual ol:lservations recorded by 

### certified smoke readers, using the certification and observation procedures set :forth in 40 CFR 

### Part 60, Appendix A, Method 9 

### {1990). Compliancewiththe opacity limit described irt 

### paragraph 4 shall be determinedby either of thesemethods.
a. Bythel.5thdayoreachmonthKaisershallmailtoBCAPCA
a summary of the opacity values for the preceding month. Each report shall include.the following information: a) The total number of OperatingHours for eachmelter and holder furnace for themonth; b) The number of operatingHours during which each furnace exceeded an average opacityof 10 percent; c) Thenumber of 60 minuteoperatingintervalsduringwhich each furnace had an average**o~city** 

### above 24 percent; d) The ntllilber of hours for each furnace that the opacity monitor was not operational;

-5-i) The time, duration, magnitude and furnace(s) 

### involved; ii) The probable cause or causes; 

### iii) Actions planned to prevent any recurrence. 

### The reporting requirements of this paragraph shall terminate 

### when Kaiser**co~ences** 

### reportingpermit deviations under the terms of an air operating permit issued to theTrentwood works. 9. The alternate opacity limit established by this order applies solely to Trentwood works melter and holder furnaces in existence on the effective date of this order. Forthose emissions units 

### it supersedes the opacity limits prescribed by WAC 173-400- 040(1), SCAPCA Regulation 1, S 6.02(A), and SCAPCA Order No. 90-2. SCAPCAreserves therighttodetermineReasonablyAvailable Control Technology (RACT) for Trentwoodremelt furnaces as provided inRCW ch. 70.94 and SCAPCA regulations, and to revise this order if necessary to incorporate any additional restrictions imposed as a result of that determination. 10. SCAPCA or Ecology shall enforce this order pursuant to ch. 70.94 RCW. Upon approval of this order by EPA as part of the Washington State Implementation Plan, it shall be enforceable in accordance with the federal Clean Air Act. 11. The alternate opacitylimit described inthis order shall take effect, for each furnace, upon fulfillment of three conditions: (1) submission to and appToval by the Control Officer of a**rep<:~rt** demonstrating that the opacity monitor installed on that furnace meets the performance specifications set forth in 40



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conditions: (1) submissionto and approval bythe Control Officer of a report demonstrating that the opacity monitor installed en 

### that furnace meets the performance specifications set forth in 40 CFR Part 60, Appenclix B, Performance specification 1. (1990); 

### (2) approvalbythecontrol O:fficer of a qualityassuranceplan for the opacity monitor; and (3) commencement of continuous operation 

### of the monitor. SCAPCA shall use Recommended Quality Assurance PJ:ocedures For opacitycontinuous EmissionMonitorin9 systems {EPA J40Jl-S6-0lO) 

### as a guidelille for approving the 'QA plan. The 

### Control Officer shall act on any submittal received under this 

### paragraph within 30 

### days of its submission. Compliance with 

### this condition may be demonstrated separately for each furnace. 12. 

### order No. 90-2 

### is 

### revoked, effective immediately, DATED this 1 1991, 

### SPOKANECOUNTY AIRPOLLUTIONCONTROL AUTHORITY BOARD OF DIRECTORS



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