Support Document 

For the Air Operating Permit Issued to 

Alcoa Wenatchee Works 

6200 Malaga/Alcoa Hwy 

Malaga, WA 98828-9728 

by 

State of Washington 

Department of Ecology 

300 Desmond Drive 

P.O. Box 47600 

Olympia, WA 98504-7600 

 Page 1 of 25 March 2010 
Table of Contents 

INTRODUCTION 

FACILITY AND PROCESS DESCRIPTIONS 

3 

3 

PERIODIC MONITORING 6 

SPECIFIC PERMIT CONDITIONS 7 

A) Aluminum Plant Emission Standards 7 

B) Plant Wide Operation and Maintenance 7 

C) Opacity Permit Conditions 8 

D) Compliance with Particulate Matter Requirements 9 

E) SO2 Permit Conditions 12 

F) Ambient and Forage Fluoride Conditions 13 

G) Other parameters not required by MACT 

H) Potroom Operation and Maintenance 14 

 I) MACT 15 

J) IEUs 17 

K) Corrective Action 17 

L) Best Available Retrofit Technology (BART) 18 

M) Greenhouse Gas 

APPENDIX A ORDERS 20 

APPENDIX B EMISSION UNIT NUMBERS 21 

APPENDIX C DATA TABLES 25

 Page 2 of 25 March 2010 
Introduction 

This document, the support document, summarizes the legal and factual basis for the 

permit conditions in the air operating permit issued by the Washington State 

Department of Ecology to the source. Unlike the air operating permit, this document 

is not legally enforceable. This support document summarizes the emitting processes 

at the facility, air emissions, permitting and compliance history, the statutory or 

regulatory provisions that relate to the facility, and the steps taken to provide 

opportunities for public review of the permit. The Permittee is obligated to follow 

the terms of the permit. Any errors or omissions in the summaries provided here do 

not excuse the Permittee from the requirements of the permit. This Operating Permit 

Support Document fulfills the operating permit rule “Statement of Basis” requirement 

and explains particular portions of the air operating permit for Alcoa Wenatchee Works, 

a primary aluminum smelter, located near Malaga, WA. 

This document is not part of the air operating permit for Alcoa Wenatchee Works. 

Nothing in this document is enforceable against the permittee, unless otherwise made 

enforceable by permit or order. 

Facility and Process Descriptions 

Alcoa, Wenatchee Works is located in Wenatchee, Washington. This facility is capable 

of producing 243,000 tons per year of primary aluminum that is sold as aluminum 

foundry ingot, pig or sow. In July of 2001, the smelter was temporarily curtailed due in 

part to high electrical energy costs. 

The process of aluminum reduction requires the electrolytic decomposition of alumina 

into two chemical components (Hall-Heroult process) which are metallic aluminum and 

gaseous oxygen. In order to accomplish this, alumina must be brought into a liquid 

phase allowing electrical direct current to pass through it. The process uses cryolite, a 

fluorinated compound of sodium and aluminum, which melts at approximately 1000o

C. 

Cryolite has the capability, in the molten state, to hold up to 8% alumina in solution. 

Molten aluminum, which is released during the electrolysis, has a slightly higher specific 

gravity than molten cryolite at the cell operating temperature, and therefore settles to the 

bottom of the cell forming a molten aluminum metal pad. The electrolytic cell consists of 

a steel shell lined with insulating materials and having an electrically conductive bottom 

made of carbon connected to the negative polarity of the power source. Suspended from 

above and immersed into the cryolite-alumina melt are carbon anodes connected to the 

positive side of the electric cell. When the electric current flows from the anode to the 

cathode, alumina is split into metallic aluminum which spreads over the cell bottom and 

into oxygen which evolves at the inner surface of the carbon anode. The oxygen burns 

and thereby releases a blend of gasses, primarily carbon dioxide, carbon monoxide, and 

 Page 3 of 25 March 2010 
some sulfur dioxide. The generation of sulfur dioxide is due to the sulfur content of the 

anode material. Hydrogen fluoride also evolves from the cryolite bath due to the high 

operating temperatures of the cells and the presence of moisture in the alumina. 

For the production of aluminum, there are four basic cell designs. Two are designated as 

“prebake” and two as “Soderberg”. The Alcoa, Inc. smelter at Wenatchee operates 

center-worked prebake (CWPB) cells. Prebake cells utilize carbon anodes, made from 

petroleum coke and coal tar pitch, which have been pre-formed into blocks, baked, and 

secured onto copper rods prior to being introduced into a cell. Pressing, baking and 

rodding take place on-site in the green carbon, carbon baking, and anode rodding 

processes respectively. In center-worked pots, the crust overlying the molten bath is 

broken and ore is fed by means of a puncher-feeder device located along the cell’s 

centerline between the two rows of anodes. The individual cells are arranged in 

“potlines” which are rows of cells connected electrically in series. 

Air pollution control systems employed at Alcoa include the following: 

For potlines, primary emission control systems capture pot fumes. The systems 

consist of hoods and movable shields around each pot, and a system of ducts and 

fans which draw the fume from each pot to a centralized treatment system. The 

treatment system consists of two types of alumina dry scrubbers (referred to as 

either A-398 fluidized bed or alumina injection system) which use alumina to 

react with and remove hydrogen fluoride in the gas stream. The resulting 

aluminum fluoride is removed, along with other particulate matter, by a system of 

fabric filter containing baghouses prior to venting the treated gasses to the 

atmosphere. The aluminum fluoride particulate is recycled in the potroom 

process. 

For anode bake ovens, a dry alumina scrubber system, with fluidized bed alumina 

reactors and baghouses (A-446), treats bake oven gasses in a fashion similar to the 

A-398 system described above. Bake oven gasses consist of combustion products 

from natural gas and from volatile matter that is driven off the baking anodes and 

burned in the ovens, particulate matter from the packing coke surrounding the 

baking anodes, and fluoride present in spent anodes (anodes removed from the pot 

cells are crushed and returned to the anode mix). The alumina used in the scrubber 

is recycled as feedstock in the potrooms. 

For the green mill, a dry coke injection scrubber system (Procedair) is used for 

collecting and treating organic vapors and particulates in the carbon plant. In the 

green mill, petroleum coke and coal tar pitch are heated, mixed and pressed 

into anodes. Carbon particles and organic vapors are generated by these 

processes. The coke scrubber adsorbs volatile material onto calcined 

petroleum coke which is injected into the ductwork and waste gas streams, and a 

baghouse captures the resulting particles. The coke fines and adsorbed organic 

 Page 4 of 25 March 2010 
vapors collected by the baghouse are recycled back into the anode forming 

process. 

Numerous ancillary processes in the plant are equipped with dust collectors. 

In addition to physical control systems, operating practices and maintenance are 

important factors in emissions, especially in the potrooms, where pollutants not 

captured by the primary emission system are released without treatment through 

roof vents 

Compliance Performance 

The potroom, anode baking and green mill gas treatment systems are all in compliance 

with and meet the Primary MACT and applicable state requirements. 

There have been two non-compliances with the AOP up to the date of this renewal 

submission. 

In a letter dated February 2, 2007 Ecology issued a Notice of Violation to Alcoa based 

on monthly air reports submitted by Wenatchee Works. The following excursions 

where noted: 

Date AOP 

Unit 

Parameter Limit Measured Basis of Limit 

2005, 

4th

Quarter 

D.5 Particulate 0.005 

gr/dscf 

0.0075 

gr/dscf 

Order 02AQIS-3459 

and AOP 000068-0 

2006, 

2nd 

Quarter 

D.5 Particulate 0.005 

gr/dscf 

0.0064 

gr/dscf 

Order 02AQIS-3459 

and AOP 000068-0 

Alcoa subsequently submitted two WAC 173-400-107 reports claiming that the excess 

emissions where unavoidable and could not have been prevented through carefully 

planning or improved design. Ecology accepted that the first instance met the burden 

of proof based on the fact that the potline had recently been started from an absolutely 

cold condition, and that initial emissions can be higher than during normal operations. 

The second instance (2006, 2nd quarter) was determined to have not met the burden of 

proof and a fine of $22,750 was assessed and paid by Alcoa. The cause of the second 

exceedance was determined to be due to an increase in the fineness of alumina shipped 

to Wenatchee. To reduce emissions Wenatchee conducted a complete bag changeout 

with finer mesh bags (cost over $250,000) and adjusted pulse rates accordingly. 

Emissions have consistently been less than half the limit since the second exceedance 

 Page 5 of 25 March 2010 
On January 23rd, 2007 Alcoa exceeded their parametric limit for salt addition to a 

melting furnace. Parametric limits are set under Secondary Aluminum MACT (40 

CFR Part 63 Subpart RRR) and Condition G.9 of the permit. The excess salt was 

calculated to have NOT cause an exceedance of an emissions limit. This parametric 

exceedance was reported to Ecology by phone, in the next monthly air emissions 

report, and in the next semi-annual Secondary Aluminum MACT report. The cause 

was determined to be operator error, and new procedural controls were instituted. 

There has not been a reoccurance of this incident. 

Periodic Monitoring 

EPA periodic monitoring guidance lists the following factors to be considered in arriving 

at appropriate periodic monitoring methodology. These factors were considered when 

monitoring, recordkeeping or reporting requirements were not specified in the 

underlying applicable requirement. 

1. Likelihood of violating the applicable requirement (i.e. margin of compliance):

When considering this criterion, Ecology evaluated available source test data 

(Appendix C) and the operation and maintenance procedures currently in 

place at the Alcoa Wenatchee Works. When the unit consistently performs 

well below the standard and the facility has a good O & M history, periodic 

monitoring may be less frequent or may rely on preventative measures (see 

functional integrity discussion in B) below. 

2. Necessity of add-on controls for the unit to meet the emission limit: This 

criterion allows for the consideration of relative risk in the determination of 

appropriate periodic monitoring. Those sources that present the largest risk 

to the environment in the event of a failure of add-on controls, require frequent 

source testing as well as continuous evaluation of surrogate performance 

measures and O & M measures. Also considered are the presence of precedures 

or processes that shut down the unit if the control systems are not operating 

3. Variability of emissions from the unit over time: Units which perform 

consistently require less frequent source testing than those where emissions 

vary widely 

4. The type of monitoring, process, maintenance, or control equipment data

already available for the emission unit: Careful consideration is given to 

the type of control device in use and the demonstrated ability of the company 

to operate and maintain the device effectively. Control devices such as 

baghouses can be monitored visually and still provide a high degree of 

certainty that the unit is functioning appropriately. Therefore source 

testing can be done less frequently if the company has a history of compliance 

 Page 6 of 25 March 2010 
with operation and maintenance requirements. The addition of functional 

integrity inspections for all units covered by the AOP requires weekly visual 

checks of the control equipment and follow-up corrective action whenever 

visible emissions, leaks in the duct work, excess vibration, inappropriate 

pressure drop are observed. This requirement focuses on early detection 

and prevention of problems 

5. Technical and economic considerations associated with the range of possible

monitoring methods: Ecology considered the cost versus the benefit of 

source testing, including, for many sources, the cost of installation of access 

ports. For a number of small baghouses at the Alcoa Wenatchee Works, the 

following cost factors weighed against the inclusion of periodic source 

testing; 

• Routine source testing and installation of access to these units would cost 

an estimated total of more than $600,000 over the 5-year permit. 

• Source testing produces very few compliance data points; 

inspection/correction and parametric monitoring assure much closer 

attention and yield much more frequent and useful data. 

• For very small units, the added cost of this source testing is not justified 

when compared to the relative environmental risk if the unit is actually 

not meeting standards. For the largest units, where the environmental 

risk of not meeting the standard is much larger (in terms of mass or 

concentration), periodic stack testing is required. 

• Once the technology is installed, good O & M becomes the most crucial 

component of ongoing compliance with the limits. 

• Even without routine source testing, Ecology retains the authority to 

require source testing on a case-by-case basis. 

Comments on Specific Permit Conditions 

A) Aluminum Plant Emission Standards: 

All aluminum plants are required to meet the emission standards of WAC 173-

415-030 and -060. WAC 173-415-030 states that “specific emission standards 

listed in this chapter will take precedence over the general emission standards of 

chapter 173-400 WAC. The requirements of Condition I.1 for visible emissions, 

Condition I.3 for fugitive emissions and Conditions I.6 and I.7 for SO2, take 

precedence over the requirements of WAC 173-400-040(1), WAC 173-400--

040(3)(a) and WAC 173-400-040(6), respectively. 

B) Facility Wide Requirement Number I.11. Plant-wide Operation and 

Maintenance: 

 Page 7 of 25 March 2010 
WAC 173-415-030(6) requires aluminum plants to maintain the facility and 

operate and maintain air pollution control equipment consistent with good air 

pollution control practice. Determination of whether acceptable operating and 

maintenance procedures are being used will be based on information such as, but 

not limited to, monitoring results, the presence of visible emissions, review of 

operating and maintenance procedures, and inspection of the source. 

Alcoa Wenatchee Works has a systematic operation and maintenance (O & M) 

program in place that has consistently produced good results, as evidenced by 

low emissions and satisfactory findings during regulatory inspections. The 

program consists of inspections of dust collectors in each work area, with 

inspection records maintained; a preventive maintenance program, with records 

kept; and corrective action initiated promptly. 

In addition to these broad O & M requirements, this permit includes a requirement 

to visually inspect all baghouses on a weekly basis. This weekly functional 

integrity inspection includes a check for visible emissions, leaks in ductwork and 

housing, excessive vibrations, pressure drop, and sight glass readings when 

available. (Currently, all baghouses covered by this AOP have had sightglass 

apparatus installed). In this permit, functional integrity inspections are used as an 

indicator of compliance with particulate limits, opacity and O & M requirements 

for baghouses. Baghouses that are properly operated and maintained produce no 

visible emissions and easily meet a grain loading standard of 0.005 gr/dscf. 

Traditionally, O & M compliance has been demonstrated through observation of 

visible emissions and routine maintenance activities. Weekly inspection and 

documentation of additional operational conditions improves the company’s ability 

to identify and correct problems long before an emission standard is violated. 

Because of this, the company will be required to invest in corrective action earlier 

than it would if the permit relied solely on visible emission observation or stack 

testing to demonstrate compliance. Corrective action will be initiated whenever 

visible emissions (or other findings from the functional integrity inspection, such as 

significant changes in site glass readings or excess vibration) are observed. Records 

of inspections and corrective actions will be maintained. In addition, stack tests for 

particulate matter are also required of the largest baghouses. 

Some visible emissions may be observed from baghouses during routine 

cleaning cycles. These emissions are of short duration and are not expected to 

exceed the most stringent opacity limits. These low intensity short term 

emissions are considered to be normal operations and are not subject to the 

opacity and particulate permit requirements to initiate corrective action when 

visible emissions are observed. 

Additional potroom operation & maintenance is described in H) below. 

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C) Opacity Permit Conditions: 

For dust collector systems with baghouses, both the facility-wide O&M and 

functional integrity inspection requirements described above apply. As 

described above, baghouses which are properly maintained easily meet the 

opacity limits. The requirements for corrective action when visible emissions 

are observed are a more effective compliance strategy than occasional opacity 

readings. Therefore, no routine opacity monitoring is proposed, although 

Ecology retains the ability to require opacity readings upon request. Problems 

with operating practices are enforceable through the general requirement to 

operate and maintain facilities in a manner consistent with good air pollution 

control practice and through the functional integrity requirements 

For emission units without control devices that may produce visible emissions (e.g. 

potroom roof vents), routine opacity readings using the approved method (EPA 

Method 9) are impractical due to the configuration of the vents, the absense of 

accessible locations with appropriate viewing angle, and/or effects of weather. 

Opacity levels from these sources are generally minimal when good operation and 

maintenance practices are being used. These practices are covered by O & M 

conditions (see H below) and Alcoa Wenatchee Works has historically operated 

these sources consistent with good air pollution control practice. 

D) Compliance with Particulate Matter Requirements: 

Condition A.5. The particulate emissions from the dry coke scrubber on the green 

mill are limited to 0.005 gr/dscf. Test results show emissions to be 1/10 of the 

allowable and total less than 1 T/yr. A source test is required once every 5 years 

and upon Ecology’s request. Ecology determined that more frequent stack testing 

is not necessary to evaluate compliance based on the margin of compliance, low 

variability of the test results, and the weekly inspection requirement described in 

B) above. 

Condition A.9. The particulate emissions from the coke handling (DC2) dust 

collector are limited to 0.1 gr/dscf. Test results from 2008 were 0.0029 gr/dscf. 

Ecology assumes that 0.005 gr/dscf is easily achievable and that the unit is in 

continuous operation. Under these assumptions, the unit, while still a very small 

source, would emit more than 0.75 tons/year (the IEU threshold). In addition, the 

design of the baghouse is similar to other units where source tests have 

demonstrated that 0.005 gr/dscf is easily achievable. A source test is required once 

every five years and upon Ecology’s request. More frequent source testing is not 

necessary due to the small size of the source, the requirement for weekly 

inspections and the history of good operation and maintenance at the Alcoa 

 Page 9 of 25 March 2010 
facility. 

Condition B.1. Anode bake oven gasses emitted from the control system are 

subject to the 0.1 gr/dscf standard contained in WAC 173-400-050 (1). Three 

source tests are required per year, consistent with the schedule and methods for 

MACT testing for total fluoride (TF) and particulate organic matter (POM). 

Test results show that particulate emissions are less than 1 % of the limit. 

Periodic monitoring per B), above, also applies. 

Conditions C.1 and C.3. The butt crusher baghouse and the butt blast 

baghouse are limited to 0.005 gr/dscf. Test results show emissions to be less 

than 1/10 of the allowable limit and total less than 0.5 T/yr combined if the units 

are in use 24 hours/day, 7 days/week. No periodic source testing is required 

for these baghouses because of their small size and very low emission rates. 

Weekly functional integrity inspections are sufficient to demonstrate compliance 

with these conditions 

Condition C.5. The particulate emissions from the anode cleaning equipment 

baghouse are limited to 0.005 gr/dscf. Test results show emissions to be 1/10 of 

the allowable limit and total less than 1 T/yr. A source test is required once 

every 5 years and upon Ecology’s request. Ecology determined that more 

frequent stack testing is not necessary to evaluate compliance based on the 

margin of compliance, the low variability of the test results, and the weekly 

inspection requirement described in B) above. 

Condition C.8. The particulate emissions from the Lectromelt baghouse are 

limited to 0.005 gr/dscf. Test results show average particulate emissions from 

this unit are 82% of the standard. Average actual emissions from the Lectromelt 

baghouse are less than 1 T/year and maximum emissions if the unit is in use 24 

hours/day, 7 days/week would be about 1.1 T/year. No periodic source testing is 

required for this baghouse because it is a small unit, especially when compared to 

the emissions from the potroom. Weekly functional integrity inspections are 

sufficient to demonstrate compliance with this condition. 

Condition D.1. Potline operations are covered by a particulate matter standard of 

15 pounds per ton of aluminum produced, found in WAC 173-415-030(2). 

Compliance is determined by adding particulate levels determined through source 

tests conducted on the primary control systems to those determined through testing 

at the potroom roof monitors. Quarterly source tests are conducted for the 

primary control system. Method 14 equipment has been installed in Rooms 6 and 

Room 20. These rooms are representative of all potrooms at the facility. Monthly 

particulate sampling of the roof monitor is conducted in all operating rooms with 

Method 14 installed. The facility-wide and potroom O&M requirements require 

 Page 10 of 25 March 2010 
periodic monitoring. The facility routinely operates well below the 15#/T limit 

and could not exceed that particulate limit when complying with the TF standard 

in Condition D.15. Test results for the grain loading standard in the potline 5 

primary control system are consistently below the 0.005 limit (60% of the 

standard at 0.0032) 

Condition D.3. The particulate emissions from the cruce cleaning facility are 

limited to 0.005 gr/dscf. Test results show emissions to be less than 1/5 of the 

allowable, and total less than 1/2 T/yr. A source test is required once every 5 years, 

and upon Ecology’s request. Ecology determined that more frequent stack 

testing is not necessary to evaluate compliance based on the margin of compliance, 

the test results and the weekly inspections described in B) above. 

Condition D.5. Particulate emissions from the Potline 5 primary control system 

baghouse are limited to 0.005 gr/dscf. Test results show emissions to be 

consistently less than the standard (averaging 0.0032 gr/dscf). As discussed 

above in the compliance review section, one anomalous period occurred 

between late 2005 and early 2006 where more variable and finer alumina supply 

resulted in excursions above the limit (0.0075 and 0.0064 gr/dscf). This 

problem was robustly corrected with a complete changeout and installation of 

finer mesh bags, and adjustments in the pulse timing and bag pressure drop. 

The most recent 4 quarter average (through June 30, 2008) is 0.0013 gr/dscf, 

with no single test above 0.0016 gr/dscf. Ecology considered the size of the 

source, the variability of the data and the margin of compliance and determined 

that frequent (quarterly) monitoring is necessary. Weekly functional integrity 

inspections are also required 

Condition E.1. The particulate emissions from the spent potliner (SPL) 

processing baghouse are limited to 0.005 gr/dscf. Test results show emissions to 

be about 1/10 of the allowable, and total less than 1/2 T/yr. A source test is 

required once every 5 years, and upon Ecology’s request. Ecology determined 

that more frequent stack testing is not necessary to evaluate compliance based on 

the margin of compliance, the test results and the weekly inspections described in 

B) above. 

Condition F.1. Particulate emissions from Boiler 1 and 2 are limited to 0.1 

gr/dscf. There are no test results for this unit nor any flow data. Emission 

estimates are based on natural gas use and EPA published emission factors for 

small industrial boilers (AP-42, Compilation of Air Pollutant Emission Factors). 

Estimated emissions of 2.4 tons PM/year are conservative and more likely to be 

about 1T/year because the boilers are used primarily in the winter. No source 

testing is required, however, the permittee is required to monitor the usage of 

natural gas and to annually recalculate emissions using the above mentioned 

 Page 11 of 25 March 2010 
emission factors. In addition, the permittee must conduct a weekly inspection of 

the boiler house. 

Condition G.1. Ingot plant stacks 1, 2, 3, 4, 11 and 12 are limited to 0.1 gr/dscf. 

Test results from Furnace 3 conducted in November 2005 showed emissions of 

0.0508 gr/sdcf with an average 10,454 acfm airflow. Test results from Furnace 2 

conducted May 2008 show emissions of 0.0155 gr/dscf with an average 6,164 

airflow. These test results can be extrapolated to the other furnaces since they are 

all of the same design (fixed hearth reverbatory furnaces) and are operated the 

same. Hourly emissions rates measured during those same tests were 2.6 lbs/hr 

for Furnace 3 (11.4 TPY) and 0.5 lbs/hr for Furnace 2 (2.2 TPY) All testing was 

conducted over a full furnace cycle, which includes charging, melting, skimming, 

alloying, fluxing and pouring. No source testing is required here since source 

testing under Secondary MACT requirements (Condition G.3), for particulate, are 

more stringent. Nevertheless, the permittee is still required to conduct a weekly 

functional integrity inspection of the ingot plant. 

Conditions H.5 and H.7. The particulate emissions for the alumina railcar 

unloading dust collector and the bath crusher dust collector are limited to 0.1 

gr/dscf. Tests conducted in May of 2008 showed results of 0.0010 gr/dscf and 

0.0018 gr/dscf respectively. Alcoa uses the same type cloth bag in all it’s 

baghouses. All of the baghouses throughout the plant handle similar materials. 

Therefore, Ecology initially assumed that 0.005 gr/dscf was easily achievable and 

that these units would be in continuous operation. Under these assumptions, these 

units, while still very small sources, would emit more than 0.75 tons/year each (the 

IEU threshold). Because both units have a fairly high flow, a source test is 

required once every five years and upon Ecology’s request. More frequent source 

testing is not necessary due to the low level of likely emissions from these sources, 

the requirement for weekly inspections and the history of good operation and 

maintenance at the Alcoa facility. 

Small Baghouse Units

Monitoring requirements for other baghouse units include the O&M and 

functional integrity requirements described above. 

Routine source testing of units OH-6, OH-8, OH-15 and OH-30 (Conditions H 9, 

H.11, H.13 and H.15) is not proposed. The material handled by these baghouses 

is alumina and Alcoa uses the same bag material in all units. Similar performance 

is expected from baghouses with similar characteristics and proper O&M. Data 

from the source tests that have been conducted show emissions below any 

allowable limits. 

 Page 12 of 25 March 2010 
E) Conditions I.6 and I.7. SO2 Permit Conditions: 

Chapter 173-415 WAC limits sulfur dioxide emissions from aluminum smelters to 

60 lb per ton of aluminum produced on a monthly maximum basis, and also limits 

emissions to no more than 1,000 ppm SO2. Smelters presently control SO2

emissions by limiting sulfur content in raw materials, particularly petroleum coke. 

The permit requires Alcoa Wenatchee Works to determine SO2 emissions by 

mass balance calculation or alternatively by source testing. The equation used for 

the mass balance calculation to determine compliance with the 60 lb SO2/ton Al 

limit is as follows: 

SO2/ton Al = (ΣCx0.9SC+ΣPxSp+ΣGxSg) x 40 / Al 

where C, P, and G are the coke, pitch, and fuel oil usage during the month from 

each shipment, in tons; SC, SP, and Sg are the sulfur concentration of each 

shipment of coke, pitch or natural gas respectively, expressed as a percentage; and 

Al is the aluminum production for the month. 

The factor of 40 derives from converting tons of raw materials to pounds (2,000 

lbs/ton), converting the percentage of sulfur in raw materials to a decimal fraction 

(100), and converting the weight of sulfur to the weight of SO2 (1 lb sulfur 

combines to make 2 lbs SO2). 2000/100 X 2 = 40 

Using a worst-case analysis, Ecology determined that Alcoa Wenatchee Works 

would be incapable of violating the 1,000 ppm SO2 standard, with the possible 

exception of an extreme upset condition. Therefore, no routine monitoring for 

this standard is proposed. 

F) Condition I.10. Ambient and Forage Fluoride Standards and Monitoring: 

Order No. 02AQIS-3459 describes prior monitoring and modeling of ambient and 

forage fluoride near the plant. Based on the findings stated in the order, ambient 

fluoride standards are consistently met and no monitoring is required, as long as 

gaseous fluoride emissions from the facility have not exceeded 327 lbs/day at any 

time during the preceding 12 month period. Based on the findings stated in the 

order, forage standards are consistently met and no monitoring is required, as long 

as an annual vegetation survey is conducted and a survey is conducted to certify 

that no livestock is raised for commercial production within a five mile radius of 

the plant. The requirements of this order are state only conditions in the permit. 

G) Conditions for other parameters not required by MACT 

 Condition A.1. Benzene plus toluene are limited to a combined total of 1 ppm 

 Page 13 of 25 March 2010 
from the green mill liquid pitch vent (67 A). The emissions from the liquid pitch 

tank are treated by an oil scrubber followed by a charcoal filter. Either unit has 

the capability of reducing emissions below the 1 ppm limit. The charcoal filter 

is capable of operating for a year without maintenance but Alcoa procedures 

require that it be checked every six months. The scrubber system operation is 

checked weekly and corrective action is taken if the pressure on the liquid pitch 

pump falls outside an operating range of 70-100 pounds. Source tests have 

shown emissions to be in compliance. The average combined emissions of 

benzene and toluene were less than half the standard (Appendix C). Weekly 

inspections and observation of operating parameters in condition A.3 constitute 

periodic monitoring for this emission unit and further source testing is not 

necessary. 

Condition A.4. VOC from the liquid pitch scrubber vent is limited to 1 ppm 

above background levels. Tests at 174 points showed no exceedances. Testing 

annually or upon Ecology’s request is adequate periodic monitoring for this unit. 

Condition A.7. MACT established the dry coke scrubber as preferred technology 

for control of POMs from the green mill. Ecology added a POMs emission 

standard of 0.70 lb/hr when approving the notice of construction for the dry 

scrubber Source tests have shown emissions to be less than 40% of the allowable. 

The source test required every 5 years and the MACT requirements for 

parametric monitoring specified in condition A.12, fulfill the requirement for 

periodic monitoring for POMs. 

H) Condition D.2. Potroom Operation & Maintenance: 

WAC 173-415-030(6) requires owners and operators to operate and maintain 

facilities and equipment in a manner consistent with good air pollution control 

practice. WAC 173-415-030(1)(b) requires owners and operators of center 

worked prebake pots to design the primary emission control system “so that the 

control of fluoride emissions will be equivalent to a total fluoride collection 

efficiency of ninety five percent”. Potroom practices and integrity of pot shields 

are the major factors determining collection efficiency. Further, once pot gasses 

are collected, the alumina dry scrubber systems are very effective in removing 

fluoride and particulates. Except during startup, secondary emissions monitoring 

will be the sole monitoring requirement for potroom O&M if emissions do not 

exceed 1.7 lbs TF/ton of aluminum produced. This level is below the 1.9 lbs TF/T 

aluminum produces, required by MACT. This is 10% below the MACT level 

which was based on the emissions of the best operating plants. In addition, Alcoa 

has demonstrated that in order to achieve the 1.7 lbs TF/ton standard, they must 

consistently maintain a collection efficiency of greater than 95%. Due to Alcoa 

Wenatchee Works’ good operating record and early compliance with MACT 

 Page 14 of 25 March 2010 
standards, Ecology has determined that more prescriptive O&M requirements, 

such as ongoing monitoring of collection efficiency, are not necessary to assure 

good O&M at this facility. If 1.7 lbs/ton is exceeded, additional monitoring and 

action is required. Actions required include a root cause analysis for the first 

exceedence and weekly inspections of potroom operations for the second 

exceedence. If 1.7 lbs TF/ton is exceeded more than 6 times, the company will be 

considered out of compliance with the O & M requirement of Condition D.2. 

Because roof emissions are monitored using a Method 14 manifold only in Rooms 

6 and 20 and by continuous emissions monitors (CEMs) in all potrooms, 

determination of secondary emissions would be determined by correlation 

between Method 14 data and CEM data. 

During startup, the provisions of the Startup Shutdown and Malfunction (SSM) 

plan will apply. 

I) MACT 

In October, 1997, USEPA promulgated National Emission Standards for 

Hazardous Air Pollutants (NESHAPS) representing Maximum Achievable 

Control Technology (MACT) for the primary aluminum industry. These rules are 

contained in the Code of Federal Regulations at 40CFR Part 63, Subchapter LL. 

Hazardous air pollutants (HAPs) for this industry include total fluoride (TF) and 

polycyclic organic matter, (POM). 

The MACT standards for primary aluminum were subcategorized into major 

process areas (potlines, paste plants, and bake ovens) that produce emissions of 

either or both of these HAPs. Potlines were further subcataegorized by the type of 

reduction cell employed. Alcoa Wenatchee Works is listed in the federal 

regulations as being within the center-worked prebake one (CWPB1) 

subcategory. 

In prebake plants, including CWPB1 plants, potlines produce fluoride in both 

gaseous and particulate form. Total fluoride standards address both gaseous and 

particulate forms of fluoride. MACT standards for prebake potlines address 

only total fluoride because POMs are driven off from the anode material 

during the anode baking process and are not of concern in prebake plant potline 

emissions. Paste production plants (or “green mill” as it is known at Alcoa 

Wenatchee Works), produce POM emissions but fluoride emissions are not 

significant. Incoming coal tar pitch, used to manufacture green anodes, contains 

substantial quantities of volatile polycyclic hydrocarbons which escape during 

the melting, mixing and pressing processes within the carbon plant. MACT 

standards for paste plants require a specific technology for POM emission 

control. Dry coke scrubbers are the preferred technology although other 

 Page 15 of 25 March 2010 
technologies may be used if equivalency is demonstrated. Alcoa Wenatchee 

Works has already installed a dry coke scrubber. Numerical POM limits are 

not included in the MACT standards. Anode bake ovens produce both 

fluoride and POM emissions. At Alcoa Wenatchee Works, these are collected 

and treated in an existing dry alumina scrubber system. 

Alcoa Wenatchee Works has taken a proactive approach to implementing MACT 

requirements and are in compliance with MACT emission standards. Ecology has 

included the MACT requirements in the Draft Air Operating Permit. 

On March 23, 2000, the USEPA promulgated National Emission Standards for 

Hazardous Air Pollutants (NESHAPS) representing Maximum Achievable 

Control Technology (MACT) for the secondary aluminum industry. These rules 

are contained in the Code of Federal Regulations at 40 CFR Part 63, Subpart RRR. 

Hazardous air pollutants (HAPs) for this industry include organic HAPs, 

inorganic gaseous HAPs (hydrogen chloride, hydrogen fluoride and chlorine) and 

particulate HAP metals. These MACT standards apply to secondary aluminum 

production facilities using clean charge, aluminum scrap, foundry returns or 

molten metal as the raw material and performing, among other things, one or 

more of the following processes: furnace operations such as melting, holding, 

refining, fluxing or alloying; in-line fluxing; or dross cooling. 

The facility was required to demonstrate compliance with the secondary MACT 

requirements for the existing sources by March 24, 2003. Due to the plant 

curtailment, data from sister Alcoa plants with similar operations was used to 

preliminarily demonstrate the capability to meet the compliance requirements. 

The facility demonstrated compliance within 180 days of start-up. 

On September 14, 2004, EPA promulgated the final National Emission 

Standards for Hazardous Air Pollutants (NESHAPS) representing Maximum 

Achievable Control Technology (MACT) for industrial, commercial, and 

institutional boiler and process heaters (Boiler MACT) that established 

standards and certain exemptions from this source category. Subsequent to 

promulgation, the U. S. District Court for the District of Columbia vacated 

the Boiler MACT Rule in July 2007. The rules were contained in the Code 

of Federal Regulations at 40 CFR Part 63, Subpart DDDDD. There are 

currently no standards or exemptions for emission units previously identified 

as being in the industrial, commercial, and institutional boiler and process 

heaters source category. These circumstances have created a situation that 

was not contemplated or addressed by either the CAA or the Subpart A 

regulations of 40 CFR Part 63. 

 Page 16 of 25 March 2010 
At the time of renewal. it was unclear what actions (if any) Alcoa 

Wenatchee Works was to take in response to, the absence of final regulations 

from USEPA, the absence of any direct requests for information from 

Ecology, and the court’s vacature of the Boiler MACT. 

In an effort to ensure that a complete title V renewal applications was filed, 

Alcoa Wenatchee Works prepared a listing of all boilers and process heaters 

(regardless of size) that may be subject to either a State case-by-case 

“Equivalent Emission Limitation by Permit” determination pursuant to 

(112(j)) and/or the future Boiler MACT standards. In addition, information 

indicating that the listed fuel burning emission units may be subject to future 

applicable requirements is hereby included as part of the renewal. This 

information is listed below. 

Unit ID Description Capacity 

(MMBtu/hr) 

Fuel Type 

BH-1, BH-2 Boilers 30 MM Btu/hr Natural gas, diesel upon 

gas curtailment only 

IP-16 Moisture drying 

oven 

2.5 MM Btu/hr Natural gas 

Neither Ecology nor USEPA have established a NESHAP for industrial, 

commercial, and institutional boiler and process heaters located at Alcoa 

Wenatchee Works. 

J) Insignificant Emission Units 

Monitoring, recordkeeping, and reporting has not specifically been required by 

Ecology for insignificant emission units per WAC 173-401-530(2)(c). Therefore 

no monitoring, recordkeeping, or reporting requirements for insignificant 

emission units are included in the permit. In the event that monitoring, 

recordkeeping, and reporting requirements are imposed pursuant to WAC 173-

401-530, an IEU would no longer qualify for the exemption from operating 

permit testing, monitoring, reporting and recordkeeping requirements. 

One additional IEU, a forging quench exhaust, was added during the 2008 AOP 

renewal process. The forging furnace is already listed as an IEU as FF-6 

“Blacksmiths Gas-Fired Forge”. This furnace has a small exhaust outside the 

building. The forging quench sits beside the furnace, and was not listed 

previously because it was not exhausted outside the building. A small hood and 

exhaust will soon be installed to vent fumes that occur when quenching hot 

forgings into the special oil bath of the quench. The purpose of this exhaust is to 

 Page 17 of 25 March 2010 
protect maintenance shop employees who use the quench. Emissions will be 

well under the 2 TPY VOC threshold for IEU noted in WAC 173-401-530 (4) 

(d). Emissions can be easily calculated based on annual quench replentishment 

volumes. 

K) Corrective Action 

There is a requirement to initiate corrective action in many conditions of the 

permit. Initiating corrective action can include, but is not limited to, preparing a 

work order, ordering parts, shutting down the unit, or completing the repair. 

L) Best Available Retrofit Technology (BART) 

In 1999, US Environment Protection Agency (USEPA) published regulations 

to address visibility impairment referred to as regional haze (64 FR 35714, 

July 1, 1999). The regional haze rule promulgated by USEPA requires States 

to develop and submit implementation plans (SIPs) to address regional haze 

visibility impairment in 156 Federally-protected parks and wilderness areas. 

It also requires the installation of Best Available Retrofit Technology 

(BART) for certain large stationary sources that were put in place between 

August 7, 1962 and August 7 1977, which have the potential to emit 250 tons 

or more of a visibility-impairing air pollutant, and whose operations fall 

within one or more of 26 specifically listed source categories found to be 

emitting “any air pollutant which may reasonably be anticipated to cause or 

contribute to any impairment of visibility in any such area.’’ Primary 

Aluminum Ore Reduction Plants are one of the 26 specifically listed source 

categories and emission units at the Alcoa Inc., Wenatchee Works were put 

in place between August 7, 1962 and August 7 1977 and have the potential to 

emit 250 tons or more of a visibility-impairing air pollutant. 

An analysis was performed to assess the visibility impacts of sulfur dioxide 

(SO2), particulate matter (PM) and nitrogen oxides (NOx) emissions from 

Alcoa’s BART-eligible sources to determine if they may reasonably be 

anticipated to cause or contribute to impairment of visibility in any of the 

federally mandated Class I areas within 300 kilometers of the Alcoa 

Wenatchee Works facility. The impact analysis was performed by the 

permitee pursuant to procedures and protocols approved by the Washington 

Department of Ecology (WDOE). 

The change in light extinction relative to the natural background due to SO2, 

NOx and PM10 from the Alcoa Wenatchee Works BART eligible sources 

was computed base on the 2003-2005 emission. The predicted impacts on 

 Page 18 of 25 March 2010 
 Page 19 of 25 March 2010 

the worst 98th percentile day during the three annual periods were 0.379 

deciview, which is well below the 0.5 threshold established by WDOE. 

Therefore, the conclusion from the modeling analysis is that the Alcoa 

Wenatchee facility is not subject to BART controls.

M) Greenhouse Gas 

There are currently no rules governing greenhouse gasses. Alcoa will 

comply with all greenhouse gas applicable requirements that result from rules 

that become effective in the future. 
APPENDIX A 

ORDERS 

Orders applicable to Alcoa Wenatchee Works include: 

02AQIS-3459 

 Page 20 of 25 March 2010 
 Page 21 of 25 March 2010 

APPENDIX B 

PROCESS EMISSION SUBJECT TO SPECIFIC 

REQUIREMENTS IN ADDITION TO 

GENERALLY APPLICABLE 

REQUIREMENTS 

EMISSION UNITS SUBJECT TO ONLY 

GENERALLY APPLICABLE 

REQUIREMENTS 

IEUs 

Green Mill, Process #2 GM – 3 Pitch Storage Tank Scrubber GM – 5B Bldg. 52 Coke Storage GM – 1 Pitch Railcar 

Unloading 

GM -17 Dry Coke Scrubber which includes: 

GM – 13 Mixer Vents 1, 2, 3, 4, 5, 6, 7, 8, & 9; 

GM – 14 Conveyor beneath Mixers; GM – 15 

Conveyor to Anode Forming; and GM – 16 

Anode Forming 

GM – 6 Green Anode Reject Storage GM – 2 Pitch Tank 

Relief Valve 

GM – 7 Butt Storage GM – 4 Hot Oil Boiler, 

Storage Tank, & Pumps 

GM – 9 Ball Mill 

Baghouse 

GM – 10 Bldg. 54 – Dust collector for Coke 

Storage 

GM – 8 Skipped Number GM – 5A Railcar Coke 

Unloading 

GM – 11 DS8 Coke Fines 

Baghouse 

GM – 12 M2 Coke Scales 

Baghouse 

GM –18 bldg 55 DC 

Anode Baking, Process #3 BF – 1 Anode Storage 

Lanes 

BF – 2 Anode Transfer 

to Furnace 

BF – 10 A446 Reactor # 1 Stacks (BF – 4 

Anode Bake) 

BF – 14 446M Alumina 

Storage Baghouse 

BF – 11 A446 Reactor # 2 Stacks (BF – 4 

Anode Bake) 

BF – 8 Bldg. 58 

Baghouse for Anode 

Cleaning 

BF – 12 A446 Reactor # 3 Stacks (BF – 4 

Anode Bake) 

BF – 9 Bldg. 62 

Baghouse for Anode 

Cleaning and Kempe 

Machine 

BF – 13 A446 Reactor # 4 Stacks (BF – 4 

Anode Bake) 

AA – 1 Anode Stub 

Hole Vacuum 

Anode Assembly/Rodding, 

Process #4 

AA – 2 Iron Induction 

Furnace 

AA – 3 Butt Crusher Baghouse AA – 5 Rod Straightening 

Press No. 1 

AA – 4 Butt Blast Baghouse AA – 7 Magnetic 

Separator 

AA – 9 Welded Stub 

Repair/Replacement and 

Portable Welding Filter 

AA – 8 Butt Tank 

Baghouse 

AA – 10 Anode Cleaning 32T Baghouse 

AA – 11 Induction Furnace Baghouse which 

includes: AA – 12 Iron Induction Furnace and 

AA – 13 Rod Brushing 

Potlines, Process #5 PL – 0 Potroom Roof Vents which include: 

PL – 1 Anode Insertion and Repositioning; 

PL – 2 Bath Material Addition: PL – 3 Alumina 

Hopper Filling Stations and Pot Alumina 

Addition; PL – 4 Pot Tapping; PL – 5 Anode 

Setting; PL – 6 Bath Crust Breaking; PL – 7 

Aluminum Tapping; PL – 8 Bath Tapping; 

PC – 1 Water Cooling of Pots; PC – 2 Bath 

Material to Bath Recycle; PC – 3 Spent Potliner 

Removal; PC – 10 New Pot Start-up; 

PL – 9 Floor Sweepings 
PROCESS EMISSION SUBJECT TO SPECIFIC 

REQUIREMENTS IN ADDITION TO 

GENERALLY APPLICABLE 

REQUIREMENTS 

EMISSION UNITS SUBJECT TO ONLY 

GENERALLY APPLICABLE 

REQUIREMENTS 

IEUs 

PR – 1,2,3 A398 Reactor for Lines 1, 2, and 

3 which includes: PL – 12 Pot Fumes from 

Lines 1,2, and 3 and PC – 11 Fugitives from 

Pot Bake-in 

PR – 4 A398 Reactor for Line 4 

PR – 5 Dry Scrubber for Line 5 which 

includes: PL – 10 Pot Fumes from Line 5 and 

PC – 11 Fugitives from Pot Bake 

CC – 1 Crucible Cleaning Machine Baghouse 

Pot Rebuild, Process #6 SPL – 1 SPL Processing Baghouse – Bldg. 

52M 

CM – 2 Kent Mill 

Baghouse 

CM – 5 Potliner Mixer 

Baghouse 

CM – 6 Seam Mix 

Transfer 

Boiler House, Process #7 BH – 1 Natural Gas Boiler # 1 BH – 3 Condensate 

Return Tank 

BH – 2 Natural Gas Boiler # 2 BH – 4 Steam Vents on 

Boilerhouse Roof 

Ingot Plant, Process #8 IP – 1 Furnace 1 Exhaust IP – 5 “C” Machine Treatment Unit IP – 6 “C” Machine 

Pour and Skim 

IP – 2 Furnace 2 Exhaust IP – 8 Crucible Heaters (Natural Gas Burn) IP – 7 “C” Machine 

Cooling 

IP – 3 Furnace 3 Exhaust IP – 10 “A” Machine Natural Gas Preheat IP – 9 “A” Aluminum 

Pour and Skim 

IP – 4 Furnace 4 Exhaust IP – 15 Free-standing Mold Heaters IP – 13 “A” Water 

Cooling, North Stack 

IP – 11 Furnace 11 Exhaust IP – 17 “D” Machine Natural Gas Preheat IP – 14 “A” Water 

Cooling, South Stack 

IP – 12 Furnace 5 & 6 Exhaust IP – 18 Skipped Number IP – 16 moisture drying oven 

IP – 21 “D” Machine Treatment Unit IP – 19 “D” Machine 

Pour and Skim 

IP – 22 Skipped Number IP – 20 “D” Cooling Fan 

IP – 26 Crucible Heaters (Natural Gas Burn) IP – 23 Skipped 

Number 

IP – 24 Skipped 

Number 

IP – 25 Dross Cooling 

IP – 27 “A” Machine 

Mold Cooling Spray 

IP – 28 “C” Machine 

Mold Cooling Spray 

IP – 29 “C” Machine 

Ingot Cooling Spray 

IP – 30 Aspirated Mold 

Coating 

IP – 31“D” Machine 

Mold Cooling Spray 

IP – 32 Dross Storage 

Room 

 Page 22 of 25 March 2010 
PROCESS EMISSION SUBJECT TO SPECIFIC 

REQUIREMENTS IN ADDITION TO 

GENERALLY APPLICABLE 

REQUIREMENTS 

E EMISSION UNITS SUBJECT TO ONLY 

GENERALLY APPLICABLE 

REQUIREMENTS 

 IEUs 

Maintenance Plant, 

Process #9 

BS – 1 Mixer 

MS – 2 Plasma Torch 

Vent 

FF – 1 Machining 

Evacuation Vent 

FF – 2 Parts Cleaning 

Window Vent 

FF – 3 New Machining 

Evacuation Vent 

FF – 4 Metal Saw 

Evacuation Vent 

FF – 5 Steam Cleaning 

FF – 6 Blacksmith’s 

Gas-fired Forge 

FF – 7 Grinder with Dry 

Filter 

FF – 8 Electrician’s 

Work Area Vent 

FF – 9 Welding, 

Machining Evacuation 

Vent 

FF – 10 Machining 

Evacuation Vent 

FF – 11 Welding 

Window Vent 

FF – 12 25 Safe-T 

Kleen Stations 

FF – 13 Metal Sawing 

Evacuation Vent 

FF – 14 Preheat 

Furnace 

FF – 15 Sander with 

Dry Filter 

FF – 16 Saw with Dry 

Filter 

FF-17 Blacksmith Forge 

Quench 

AS – 1 Auto Tailpipe 

Hose 

AS – 2 Steam Cleaner 

CS – 1 Wood Cutting 

CS – 2 Paint Booth with 

Dry Filters 

CS – 3 Wood Sanding 

Ore Handling, Process 

#10 

OH – 2 43E Baghouse for Alumina Railcar 

Unloading, Conveyor 41, Bldg. 43D 

OH – 1 43M 

OH – 15 161-730 Dust Collector for Tanks 

A160 W and E 

OH – 3 43R Dust 

Collector for Tank 43R 

OH – 6 160T-710 Dust Collector for Tank 160T-B 

OH – 7 160T-720 Dust 

Collector for Airslide 

ASO42-1 

OH-8 160T-730 dust Collector for Tank 160T-A 

OH – 9 160M-720 Dust 

Collector for Airslide 

AS-160T-1 

OH – 10 160M-720, 

Dust Collector for AS 

160M and F (Airslides) 

OH – 11 160R-710 

Dust Collector for Tank 

160R 

 Page 23 of 25 March 2010 
PROCESS EMISSION SUBJECT TO SPECIFIC 

REQUIREMENTS IN ADDITION TO 

GENERALLY APPLICABLE 

REQUIREMENTS 

EMISSION UNITS SUBJECT TO ONLY 

GENERALLY APPLICABLE 

REQUIREMENTS 

IEUs 

OH – 12 160R-720 

Dust Collector for AS 

160R (Airslides)

OH – 13 161-710 Dust 

Collector for 160RN, 

161, and 162 

OH – 14 161-720 Dust 

Collector for AS 163RE 

and 160RN (Airslides) 

OH – 18 21RDust 

Collector for Tank 21M 

and Airslide AS-042-1 

OH-19 21 R Dust 

Collector for 21R tank 

north 

OH – 20 19A Dust 

Collector for Airslide 

AS-19M-2 

OH – 21 19C Dust 

Collector for Tank 19C 

OH – 22 19MS Dust 

Collector for Tank 

19MS 

OH – 24,25,26,27,28 

42A710-E Dust 

Collector for Airslide 

AS-042-2 

OH – 29 19T-710 Dust 

Collector for Tank AL 

19T, Airslides AS19C-1 

and AS19C-2 

OH – 30 19T-720 Dust Collector for Tank AL 19T 

OH – 31 19T-730 Dust 

Collector for Airslides 

AS19T-1 and 19T-3 

OH – 32 17R Dust 

Collector for Tank 17R 

OH – 42 21R (Center) 

Dust Collector 

OH – 43 21R (South) 

Dust Collector 

OH-45 5 D DC 

OH-46 9 D DC 

BR –1 40A (Bath Crusher) Dust Collector for 

Bath Storage and Conveyor, Mill Hopper, 

Conveyor 41, Rotary Breaker, and Tanks A-E 

BR-2 Bath Recovery 

Transfer System 

Miscellaneous BL-1 solvent (caustic) wash 

BL-2 fume hoods (7) 

BL-3 Atomic absorption 

Units (2) 

BL-4 Flammables storage 

cabinet 

 Page 24 of 25 March 2010 
APPENDIX C 

DATA TABLES 

 Page 25 of 25 March 2010