• • RfCBI/fD 

DEc 21991 

SPOKANE COUNTY AIR I'Ot.t.unoN 

C:O!'/T!Wt AUffiOI!rJY 

SPOKANE COUNTY AIR POLLUTION CONTROL AUTHORITY 

IN THE MATTER OF ) 

) 

KArsER ALUMINUM & CHEMICAL ) 

CORPORATION, TRENTW'OOO WORKS ) 

) 

SPOKANE, WASHINGTON ) 

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ORDER NO. 91-Qj 

ALTERNATE OPACITY LIMIT 

I. INTRODUCTION 

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

pollution control authority having jurisdiction may choose, subject 

to submitting appropriate data that the industry has quantified, to 

have any limit on the opacity of emissions from a source whose 

emission standard is stated in terms of a weight of particulate per 

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, 1990 the Spokane county Air 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 mel ter 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 emissions does not exceed J.O percent more than 4 percent of 

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 the Washington 

Department of Ecology held a joint public 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-Review mora than JO days prior to the hearing, and mailed. 

to the Regional Adlllinistrator c:t: the Environmental ProtectiQn 

Agency. 

II.. ORDER 

Based on the above information and findings, it is hereby 

ORDERED: 

l. Within three months o:t: the date of adoption of this 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, 

maintenance and upset conditions, Kaiser shall maintain and operate 

each melter and holder furnace at the Trentwood Works in a manner 

consistent with good air pollution control practice for minimizing 

emissions. 

3. Within 24 months of the date upon which EPA approves this 

order as part of the Washington state Implenentation Plan Kaiser 

shall install and commence operation of continuous opacity monitors 

on each melter and holder furnace stack. SUch monitors shall meet 

EPA Performance Specification 1, 40 CFR Part 60, Appendix B (1990). 

4. The average opacity from any melter or holder furnace 

stack at the Trentwood Works 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 Operating Hour means any 60 minute period 

in which charging, melting, fluxing, skimming, holding or 

discharging processes 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 addition to the other restrictions contained in this 

order, the average opacity from any melter or holder furnace stack 

at the Trentwood Works shall not exceed 40 percent during any JO 

minute operating interval. 

7. COlllpliance with the opacity limit described in paragraph 

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 determined by 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). Compliance with the opacity limit described irt paragraph 

4 shall be determined by either of these methods. 

a. By the l.5th day or each month Kaiser shall mail to BCAPCA 

a summary of the opacity values for the preceding month. Each 

report shall include. the following information: 

a) The total number of Operating Hours for each melter and 

holder furnace for the month; 

b) The number of operating Hours during which each furnace 

exceeded an average opacity of 10 percent; 

c) The number of 60 minute operating intervals during which 

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; 

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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 reporting permit deviations under the terms 

of an air operating permit issued to the Trentwood 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. For those 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. 

SCAPCA reserves the right to determine Reasonably Available Control 

Technology (RACT) for Trentwood remelt furnaces as provided in RCW 

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 opacity limit described in this 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) submission to and approval by the 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) approval by the control O:fficer of a quality assurance plan for 

the opacity monitor; and (3) commencement of continuous operation 

of the monitor. SCAPCA shall use Recommended Quality Assurance 

PJ:ocedures For opacity continuous Emission Monitorin9 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, 

SPOKANE COUNTY AIR POLLUTION CONTROL 

AUTHORITY BOARD OF DIRECTORS 

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