OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

 

Eastern Region

2146 NE 4th, #104

Bend, OR 97701

Telephone (541) 388-6146

 

Issued in accordance with the provisions of ORS 468A.040

and based on the land use compatibility findings included in the permit record.

 

 

ISSUED TO:

INFORMATION RELIED UPON:

   

Northwest Aluminum Company

Application Number:

021407

3313 West Second Street

Received:

5/2/05

The Dalles, OR 97058

  
   

PLANT SITE LOCATION:

LAND USE COMPATIBILITY STATEMENT:

   

3313 W. Second Street

Issued by:

City of The Dalles and Wasco County

The Dalles, OR 97058

Dated:

12/07/1989 and 08/30/1994

 

ISSUED BY THE DEPARTEMENT OF ENVIRONMENTAL QUALITY

 

____________________________________________________

____________________

Linda Hayes-Gorman, Eastern Region Air Quality Manager

Date

 

 

Nature of Business:

SIC

  

Primary Aluminum Production

3334

Secondary Metals Smelting and Refining

3341

 

 

RESPONSIBLE OFFICIAL  FACILITY CONTACT PERSON

 

Name:

Gene Davis

Name:

Galen May

Title:

CEO

Title:

Environmental Specialist

or

 

Phone:

(541) 298-0859

Name:

Mac Seyhanly

  

Title:

General Manager

  

or

   

Name

James Shaver

  

Title

NWAS Operations Manager

  

 

TABLE OF CONTENTS

 

LIST OF ABBREVIATIONS THAT MAY BE USED IN THIS PERMIT  3

PERMITTED ACTIVITIES  4

EMISSIONS UNIT (EU) AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION  4

EMISSION LIMITS AND STANDARDS  7

PLANT SITE EMISSION LIMITS  16

NESHAP COMPLIANCE PROVISIONS  16

RECORDKEEPING REQUIREMENTS  38

REPORTING REQUIREMENTS  43

NON-APPLICABLE REQUIREMENTS  49

GENERAL CONDITIONS  51

ATTACHMENT A: CROSS-REFERENCE FROM NEW RULE NUMBERS TO OLD RULE NUMBERS (EFFECTIVE MARCH 24, 2003)  56

ATTACHMENT B: 40 CFR PART 63 GENERAL PROVISIONS INCORPORATED BY REFERENCE  57

ATTACHMENT C: PRIMARY ALUMINUM PRODUCTION NESHAP AND COMPLIANCE ASSURANCE MONITORING  59

ATTACHMENT D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR  62

ATTACHMENT E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR  67

 

LIST OF ABBREVIATIONS THAT MAY BE USED IN THIS PERMIT

 

 

 

ACDP  Air Contaminant Discharge Permit

Act  Federal Clean Air Act

ASTM  American Society of Testing and Materials

Btu  British thermal unit

CFR  Code of Federal Regulations

CO  Carbon Monoxide

CPMS  Continuous parameter monitoring system

DEQ  Department of Environmental Quality

dscf  Dry standard cubic feet

EF  Emission factor

EPA  US Environmental Protection Agency

EU  Emissions Unit

FCAA  Federal Clean Air Act

FSA  Fuel sampling and analysis

gr/dscf  Grain per dry standard cubic feet (1 pound = 7000 grains)

HAP  Hazardous Air Pollutant as defined by OAR 340-244-0040

HCFC  Halogenated Chloro-Fluoro-Carbons

ID  Identification number or label

I&M  Inspection and maintenance

NA  Not applicable

NOx  Nitrogen oxides

O2  Oxygen

OAR  Oregon Administrative Rules

ODEQ  Oregon Department of Environmental Quality

ORS  Oregon Revised Statutes

O&M  Operation and maintenance

Pb  Lead

PCD  Pollution Control Device

PM  Particulate matter

PM10  Particulate matter less than 10 microns in size

ppm  Parts per million

PSEL  Plant Site Emission Limit

psia  pounds per square inch, actual

SERP  Source emissions reduction plan

SO2  Sulfur dioxide

ST  Source test

VE  Visible emissions

VMT  Vehicle miles traveled

VOC  Volatile organic compounds

 

Modified EPA Method 9: As used in this permit “Modified EPA Method 9” is defined as follows:

 

Opacity must be measured in accordance with EPA Method 9. For all standards, the minimum observation period must be six minutes, though longer periods may be required by a specific rule or permit condition. Aggregate times (e.g., 3 minutes in any one hour) consist of the total duration of all readings during the observation period that are equal to or greater than the opacity percentage in the standard, whether or not the readings are consecutive. Each EPA Method 9 reading represents 15 seconds of time. [See also the definition of “Opacity” in OAR 340-208-0010]

 

PERMITTED ACTIVITIES

 

1.  Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air contaminants from those processes and activities directly related to or associated with air contaminant source(s) in accordance with the requirements, limitations, and conditions of this permit. [OAR 340-218-0010 and 340-218-0120(2)]

 

2.  All conditions in this permit are federally enforceable except as specified below:

 

2.a.  Conditions 4, 5, 64, G4, and G8 (OAR 340-248-0005 through 340-248-0180) are only enforceable by the state. [OAR 340-218-0060]

2.b.  Attachment 1 of this permit provides a cross-reference for SIP and Title V program rules that have been renumbered in the current Oregon Administrative Rules. [OAR 340-218-0060 and 340-218-0070]

 

EMISSIONS UNIT (EU) AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION

 

3.  The emissions units regulated by this permit are the following [OAR 340-218-0040(3)]:

 

Emission Unit Description

EU ID

Pollution Control Device/Practice Description

PCD ID

40 CFR Part 63 NESHAP Applicability

2 Pot lines (150 pots/line), 5 Pot rooms (60 pots/pot room)

A-1.11 through A-1.5

Secondary Roof System

A-1a.1 through A- 1.a.5

Subpart LL

  

Dry Scrubber Baghouse

A-1b.1

Subpart LL

  

Wet SO2 Scrubber using 20% NaOH solution

A-1b.2

Subpart LL

Paste Plant Mixing System (non-VOC)

A-2a and A-2b

Dry Coke Scrubber

A-2a

Subpart LL

  

Internal Room Dust Collector Baghouse

A-2b

No

Casthouse Casting Tables

A-3a

None

NA

No

Casthouse Casting Tables

B-3c

None

NA

No

 

Natural Gas Furnaces/Boilers:

Emission Unit Description

EU ID

Pollution Control Device/Practice Description

PCD ID

40 CFR Part 63 NESHAP Applicability

3 Holding Furnaces

A-3a.1, A-3a.2, and A-3a.3

Pollution prevention work practices identified in O&M plan

NA

Subpart RRR (Group 1 furnaces if non-clean charge, Group 2 furnaces if clean charge)

Liquid Metal Transfer Furnace

A-3a.4

None

NA

Subpart RRR (Group 2 furnace)

1 Remelt Furnace

A-3a.5

Pollution prevention work practices identified in O&M plan

NA

Subpart RRR (Group 2 furnaces)

1 Homogenizing Furnace

A-3b.1

Process Control

NA

Subpart RRR (Group 2 furnace)

1 R&D Induction Furnace

B-3b

None

NA

Subpart RRR (Group 2 furnace)

2 Tilt Holding Furnaces with in-line non-reactive degassing units

B-3c.1 and, B-3c.2

See emissions unit B-4a

See emissions unit B-4a

Subpart RRR (Group 2 furnaces)

1 Horizontal rotary furnace (future installation)

B-3c.3

See emissions unit B-4a

See emissions unit B-4a

Subpart RRR (Group 1 furnace if non-clean charge, Group 2 furnace if clean charge)

4 Homogenizing Furnaces

B-3d.1 through B-3d.4

Process Control

NA

Subpart RRR (Group 2 furnaces)

1 Dowtherm Boiler

A-2c

Process control

NA

No

4 Induction Furnaces

B-4a.1 through B-4a.4

2 to 4 baghouses (future installation)

B-4a.c1 through B-4a.c4

Subpart RRR (Group 2 furnaces)

 

Materials Handling:

Emission Unit Description

EU ID

Pollution Control Device/Practice Description

PCD ID

40 CFR Part 63 NESHAP Applicability

Alumina Ore Unloading Building

A-4a

Baghouse (2)

A-4a.1 and A-4a.2

No

6 Alumina Ore Handling Silos

A-4b.1 through A-4b.6

Baghouse (6)

A-4a.1 through A-4b.6

No

Aluminum Fluoride Unloading Tank

A-4f

Baghouse (1)

A-4f

No

Dross Handling/storage building

A-4g

Work practices

NA

No

Aluminum scrap shredder

B-5

None

NA

Subpart RRR

 

Carbon Materials Handling:

Emission Unit Description

EU ID

Pollution Control Device/Practice Description

PCD ID

40 CFR Part 63 NESHAP Applicability

Coke Crushing

A-2d

Dust Collector Baghouse

A-2b

No

Coke Unloading Building

A-4c

Work Practice

NA

No

Pitch Unloading Building

A-4d

Work Practice

NA

No

 

Aggregate Insignificant Activities:

Emission Unit Description

EU ID

Pollution Control Device/Practice Description

PCD ID

40 CFR Part 63 NESHAP Applicability

Roads

NA

None

NA

No

Briquette Storage Pad

A-4e

Covered

NA

No

Solid Waste Handling Area

A-4h

None

NA

No

Propane Heating

A-1

Secondary Roof System/Dry Scrubber Baghouse/Wet SO2 Scrubber

A-1a.1 through A-1a.5 and A-1b.1 and A-1b.2

No

Paste Plant Mixing System (VOC only)

A-2a and A-2b

None

NA

No

 

3.a.  All emissions units associated with the primary aluminum production facility are not currently operating with the exception that the three holding furnaces in the primary casthouse (A-3.a.1, A-3.a.2, and A-3.a.3) may be used for secondary aluminum production without reactive fluxing.

3.b.  The permittee must notify the Department at least 30 days in advance of restarting the primary aluminum production operations.

3.c.  The permittee plans to install a horizontal rotary furnace (emissions unit B-3c.3) at the NWA Specialties facility. The new furnace will have a baghouse control device. The permittee must submit a notice of construction completion (form R1004) within 30 days after commencing operation of the furnace.

3.d.  The permittee plans to install baghouses on the 4 induction furnaces (emissions unit B-4a) at NWA Specialties. This will be phased project that will include an initial study to evaluate effective baghouse systems. The final system will consist of 2 to 4 baghouses and also control emissions from the existing tilt holding furnaces (emissions units B-3c.1 and B-3c.2).

3.d.i.  The permittee must provide notice of the initial pilot plant source test to the Department at least 15 days before the test.

3.d.ii.  The permittee must submit plans to the Department for the final proposed project and the plans must be approved in accordance with OAR 340-218-0190 before installing the final system.

 

EMISSION LIMITS AND STANDARDS

 

The following tables and conditions contain the applicable requirements along with the testing, monitoring, and recordkeeping requirements for the emissions units to which those requirements apply.

 

Primary and Secondary Aluminum Facilities

 

Applicable Requirement

Condition Number

Pollutant/

Parameter

Limit/Standard

Averaging Time

Testing Condition

Monitoring Condition

340-208-0300

4

Air contaminants

Not cause a nuisance

NA

NA

64

340-208-0450

5

PM >250m

No observable deposition off site

NA

NA

64

340-222-0040(6)

6

fuels

natural gas/propane only

NA

NA

63

340-208-0210(2)

7

fugitive dust

minimize fugitives

NA

NA

64 and 65

4/13/92 ACDP Condition 13.g

8

PCD down time

monitor downtime

NA

NA

66

340-236-0.150(1)(f)

9

PCD collection efficiency

monitor collection efficiency

defined by the test method

47

67

4/13/92 ACDP Condition 10

10

SERP

implement SERP

NA

NA

68

340-260-0040 and 40 CFR part 82, subpart B

11

ozone depleting substances

mvac servicing

NA

NA

69

40 CFR part 68

12

Risk management

Risk management plan

NA

NA

12

40 CFR part 63 general provisions

 

General

See Attachment C and 40 CFR Part 63, subpart A

NA

NA

NA

 

4.  The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by Department personnel. [OAR 340-208-0300] This condition is enforceable only by the State.

 

5.  The permittee must not cause or permit the emission of any particulate matter larger than 250 microns in size at sufficient duration or quantity, as to create an observable deposition upon the real property of another person. The Department will verify that the deposition exists and will notify the permittee that the deposition must be controlled. [OAR 340-208-0450] This condition is enforceable only by the State.

 

6.  The permittee shall not use any residual fuel oil, distillate fuel oil, or coal. [OAR 340-222-0040(6)]

 

7.  The permittee shall not allow or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or demolished; or any equipment to be operated, without taking reasonable precautions to prevent particulate matter from becoming airborne. Such reasonable precautions shall include, but not be limited to the following: [OAR 340-208-0210(2)]

 

7.a.  Storing collected material from air pollution control equipment in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer;

7.b.  Controlling cell room doors and windows to aid the roof fans in circulating cool air and collecting fugitive emissions; and

7.c.  Keeping all doors in the cell rooms, courtyard and main doors closed, except for vehicular movement.

 

8.  The permittee shall monitor the occurrence and length of down time for all pollution control devices. [4/13/92 ACDP 33-0001, Condition 13.g]

 

9.  The permittee shall monitor changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes. [OAR 340-236-0150(1)(f)]

 

10.  In the event an Air Pollution Alert, Warning, or Emergency Episode is declared in The Dalles area by the Department, the permittee shall take the action appropriate to the episode condition as required by OAR 340-206-0050. The permittee shall take such action when the permittee first becomes aware of such a declaration whether through news media, direct contact with the Department, or from other sources. [4/13/92 ACDP 33-0001, Condition 10]

 

The permittee shall take the actions listed below when an air pollution episode is declared:

 

10.a.  ALERT:    Prepare to curtail combustion of natural gas.

10.b.  WARNING:  Reduce natural gas combustion by at least 25%.

10.c.  EMERGENCY:  Cease all activities (i.e., spike removal, blowing burners, fluxing, etc.) that would contribute to an air alert.

 

During an applicable Air Pollution Episode, this Source Emission Reduction Plan (SERP) shall be available on the source premises for inspection by Department personnel.

 

11.  If the permittee performs service on motor (fleet) vehicles that involves the refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to the applicable requirements as specified in 40 CFR 82, subpart B; Servicing of Motor Vehicle Air Conditioners. At a minimum, every two years permittee will review the rule according to 40 CFR part 82, subpart B.

 

The term “motor vehicle”, as used in subpart B, does not include a vehicle where final assembly of the vehicle has not been completed. The “MVAC”, as used in subpart B, does not include air tight, sealed refrigeration systems used for refrigerating cargo or systems on passenger busses using HCFC-22 refrigerant.

 

12.  Should this stationary source become subject to the accidental release prevention regulations in 40 CFR Part 68, then the permittee must submit a risk management plan (RMP) by the date specified in 40 CFR 68.10 and comply with the plan and all other applicable Part 68 requirements. [40 CFR Part 68]

 

13.  This facility is subject to 40 CFR part 63, subpart LL (primary aluminum production NESHAP) and subpart RRR (secondary aluminum production NESHAP). The specific requirements from the regulations are included in this permit in the appropriate sections or listed in the non-applicable section of this permit. Unless otherwise stated in this permit or the applicable requirements, the general provisions from subpart A of part 63 are applicable and incorporated by reference as shown in Attachment B. [40 CFR §63.852 and §63.1518]

 

Primary Aluminum Facility

 

Applicable Requirement

Condition Number

Pollutant/

Parameter

Limit/Standard

Averaging Time

Testing Condition

Monitoring Condition

340-236-0120(3)(a)(C)

14

Fluoride ion

22.0 tons/month

monthly average

47

70

340-236-0120(3)(b)(A)

15

PM/PM10

13.0 lbs/TAP/month

monthly average

47

70

340-236-0120(3)(b)(B)

16

PM/PM10

10.0 lbs/TAP/year

yearly average

47

70

EPA Permit No. PSD-X-77-01

17

SO2

19.0 lbs/TAP

monthly & yearly average

47

70

 

14.  The permittee shall operate the plant such that the total emissions, as measured in accordance with Condition 70, from all primary aluminum sources, except emissions units A-4c through A-4h, shall not exceed 22 tons of fluoride ion/month. [OAR 340-236-0120(3)(a)(C)]

 

15.  The permittee shall operate the plant such that the total emissions, as measured in accordance with Condition 47 and monitored in accordance with Condition 70, from all primary aluminum sources, except emissions units A-4c through A-4h, shall not exceed 13.0 pounds of particulate matter/ton of aluminum/month. [OAR 340-236-0120(3)(b)(A)]

 

16.  The permittee shall operate the plant such that the total emissions, as measured in accordance with Condition 47 and monitored in accordance with Condition 70, from all primary aluminum sources, except emissions units A-4c through A-4h, shall not exceed 10.0 pounds of particulate matter/ton of aluminum/year. [OAR 340-236-0120(3)(b)(B)]

 

17.  The permittee shall operate the plant such that the total emissions, as measured in accordance with Condition 47 and monitored in accordance with Condition 70, from all primary aluminum sources, except emissions units A-4c through A-4h, shall not exceed 19.0 pounds of sulfur dioxide/ton of aluminum on a monthly and annual basis. [EPA Permit No. PSD-X-77-01]

 

Emissions Unit A-1 (cell rooms)

Applicable Requirement

Condition Number

Pollutant/

Parameter

Limit/Standard

Averaging Time

Testing Condition

Monitoring Condition

40 CFR §63.843(a)(1)(v), §63.846(b), and 340-236-0120(3)(a)(A)&(B)

18

Total Fluoride (TF)

2.2 lb/TAP/potline or 2.0 lb/TAP average for both potlines

monthly

51

75 through 84

40 CFR §63.843(a)(2)(ii) and §63.846(b)

19

Polycyclic organic matter (POM)

2.4 lb/TAP or 2.1 lb/TAP average for both potlines

quarterly

51

75 through 84

40 CFR §63.846(d)

20

TF and POM

Emissions averaging implementation plan

NA

51

NA

340-226-0210(1)(a)

21

PM/PM10

0.2 gr/dscf

see test method

47

78 through 84

340-236-0120(3)(d)

22

Visible emissions

20% opacity

instantaneous

49

80 through 84

340-236-0120(3)(d)

23

Pot feeding

Consecutive schedule

NA

NA

72

4/13/92 ACDP Condition 2(b)

24

SO2

70 ppm

see test method

47

47

4/13/92 ACDP Condition 13(h)

25

Paste leaks

Number of leaks

NA

NA

74

EPA Permit No. PSD-X-77-01

26

Scrubber recycle rate

2,088 gpm

daily average

NA

78 through 82

EPA Permit No. PSD-X-77-01

27

Scrubber pH

6.6

daily average

NA

78 through 82

EPA Permit No. PSD-X-77-01

28

Scrubber recycle specific gravity

1.090

daily average

NA

78 through 82

 

Primary Aluminum NESHAP Requirements (Subpart LL)

 

18.  The permittee shall not discharge or cause to be discharged into the atmosphere from each potline in emissions unit A-1 any emissions of TF in excess of 2.2 lb/TAP. The permittee may average TF emissions from both potlines (emission unit A-1) and demonstrate compliance using the following procedures. [40 CFR §63.843(a)(1)(v), §63.846(a) ,and OAR 340-236-0120(3)(a)(A) and (B)]

 

18.a.  Monthly (or quarterly, if using the reduced sampling frequency) average emissions of TF shall not exceed 2.0 lb/TAP.

18.b.  The emission rate shall be calculated based on the total emissions from all potlines over the period divided by the quantity of aluminum produced during the period, from all potlines comprising the averaging group. [40 CFR §63.846(b)(1)]

 

19.  The permittee shall not discharge or cause to be discharged into the atmosphere from each potline in emissions unit A-1 any emissions of POM in excess of 2.4 lb/TAP. The permittee may average POM emissions from both potlines (emission unit A-1) and demonstrate compliance using the following procedures. [40 CFR §63.843(a)(2)(ii) and 40 CFR §63.846(a)]

 

19.a.  Quarterly average emissions of POM shall not exceed 2.1 lb/TAP.

19.b.  The emission rate shall be calculated based on the total emissions from all potlines over the period divided by the quantity of aluminum produced during the period, from all potlines comprising the averaging group. [40 CFR §63.846(b)(1)]

 

20.  The implementation plan for emission averaging shall be in effect for the term of this permit. To revise the plan prior to the end of the permit term, the permittee shall submit a request to the applicable regulatory authority. [40 CFR §63.846]

 

SIP Requirements (OAR Chapter 340)

 

21.  The permittee shall not cause or allow the emission of particulate matter in excess of 0.2 grain per dry standard cubic foot from emissions unit A-1, as measured by Condition 47. [OAR 340-226-0210(1)(a)]

 

22.  Visible emissions from emissions unit A-1 shall not exceed 20 percent opacity, excluding uncombined water, at any time. [OAR 340-236-0120(3)(d)]

 

23.  When using truck feeders to feed alumina and alloys to the pot cells, the permittee shall use a consecutive feeding schedule to minimize fugitive emissions. [OAR 340-226-0120]

 

24.  The permittee shall operate the wet SO2 scrubber (A-1b.2) such that the daily average SO2 outlet concentration is no greater than 70 ppm, as measured in accordance with Condition 47. [4/13/92 ACDP 33-0001, Condition 2(b), modified]

 

25.  The permittee shall monitor the paste leaks from the anodes of the pots in emissions unit A-1 and take corrective action to minimize fugitive emissions. Any occurrences of paste leaks shall be reported to the Department monthly. [04/13/92 ACDP 33-0001, Condition 13.h, modified]

 

PSD Requirements (EPA Permit PSD-X-77-01)

 

26.  The permittee shall operate the wet SO2 scrubber (A-1b.2) such that the scrubber recycle rate is not less than 78% of full scale, as a daily average. Full scale is 2,677 gallons per minute (gpm), so 78% of full scale equals 2,088 gpm. [EPA Permit No. PSD-X-77-01]

 

27.  The permittee shall operate the wet SO2 scrubber (A-1b.2) such that the scrubber recycle pH is not less than 6.6, as a daily average. [EPA Permit No. PSD-X-77-01]

 

28.  The permittee shall operate the wet SO2 scrubber (A-1b.2) such that the scrubber recycle specific gravity is not greater than 1.090, as a daily average. [EPA Permit No. PSD-X-77-01]

 

Other Emission Units:

 

EU ID

Applicable Requirement

Condition Number

Pollutant/ Parameter

Limit/Standard

Averaging Time

Testing Condition

Monitoring Condition

A-2

40 CFR §63.843(b)(1) and (2)

29

POM

Capture and control

NA

NA

78, 80, and 82

A-2a, A-2b, A-2d

340-226-0210(1)(a)

30

PM/PM10

0.2 gr/dscf

see test method

49

98

 

340-236-0120(3)(d)

33

Visible emissions

20% opacity

instantaneous

49

98

A-2c

340-228-0210(1)(a)

31

PM/PM10

0.2 gr/dscf @12% CO2 or 50% excess air

see test method

49

99

 

340-236-0120(3)(d)

33

Visible emissions

20% opacity

instantaneous

49

99

A-3a.1, A-3a.2, A-3a.3

340-226-0210(1)(a)

30

PM/PM10

0.2 gr/dscf

see test method

48

100

 

340-236-0120(3)(d)

33

Visible emissions

20% opacity

instantaneous

100

100

A-3a.4, A-3a.5, A-3b.1

340-226-0210(1)(a)

30

PM/PM10

0.2 gr/dscf

see test method

49

99

 

340-236-0120(3)(d)

33

Visible emissions

20% opacity

instantaneous

49

99

A-4a, A-4b, A-4f

340-226-0210(1)(a)

30

PM/PM10

0.2 gr/dscf

see test method

49

98

 

340-236-0120(3)(d)

34

Visible emissions

20% opacity

3 minutes in 60 minutes

49

98

A-4c, A-4d, A-4g

340-236-0120(3)(d)

34

Visible emissions

20% opacity

3 minutes in 60 minutes

49

101

B-3c

340-226-0210(1)(a)

32

PM/PM10

0.1 gr/dscf

defined by the test method

48

100

 

340-236-0120(3)(d)

34

Visible emissions

20% opacity

3 minutes in 60 minutes

100

100

B-3d

340-226-0210(1)(a)

32

PM/PM10

0.1 gr/dscf

defined by the test method

49

99

 

340-236-0120(3)(d)

34

Visible emissions

20% opacity

3 minutes in 60 minutes

49

99

 

Primary Aluminum NESAHP Requirements (Subpart LL)

 

29.  The permittee shall install, operate, and maintain equipment to capture and control POM emissions from each paste production plant (emission unit A-2). [40 CFR §63.843(b)]

 

29.a.  The emission capture system shall be installed and operated to meet the generally accepted engineering standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists in Chapters 3 and 5 of “Industrial Ventilation: A Handbook of Recommended Practice”; and [40 CFR §63.843(b)(1)]

29.b.  Captured emissions shall be routed through a closed system to a dry coke scrubber (PCD A-2a). [40 CFR §63.843(b)(2)]

 

SIP Requirements (OAR Chapter340)

 

30.  The permittee shall not cause or allow the emission of particulate matter from emissions units A-2a, A-2b, A-2d, A-3a.1 through A-3a.5, A-3b.1, A-4a, A-4b, and A-4f in excess of 0.2 grain per dry standard cubic foot, as measured in accordance with Condition 48 for emissions units A-3a.1, A-3a.2, and 3-3a.3; and Condition 49 for the other emissions units. [OAR 340-226-0210(1)(a)]

 

31.  The permittee shall not cause or allow the emission of particulate matter from emissions unit A-2c in excess of 0.2 grain per dry standard cubic foot, corrected to 12% CO2 or 50% excess air, as measured in accordance with Condition 49. [OAR 340-228-0210(1)(a)]

 

32.  The permittee shall not cause or allow the emission of particulate matter from emissions units B-3c and B-3d in excess of 0.1 grain per dry standard cubic foot, as measured in accordance with Condition 48 for emissions units B-3c.1, B-3c.2, and B-3c.3; and Condition 49 for emissions unit B-3d. [OAR 340-226-0210(1)(b)]

 

33.  Visible emissions from emissions units A-2a, A-2b, A-2c, A-2d, A-3a.1 through A-3a.5, and A-3b.1 shall not exceed 20 percent opacity, excluding uncombined water, at any time, as measured in accordance with Condition 49. [OAR 340-236-0120(3)(d)]

 

34.  The permittee shall not cause or allow the emissions of any air contaminant into the atmosphere from emissions units A-4, B-3c, B-3d, and all fugitive emission sources for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, as measured in accordance with Condition 49. [OAR 340-208-0110(2)(b)]

 

Secondary Aluminum NESHAP

 

35.  On or after the date of the initial performance test is conducted or required to be conducted, whichever date is earlier, the permittee must comply with the following all applicable requirements for affected sources and emissions units subject to subpart RRR. [40 CFR §63.1505(a)]

 

35.a.  Aluminum scrap shredder. Particulate matter emissions from the aluminum scrap shredder (emissions unit B-5) must not exceed 0.010 gr/dscf. [40 CFR §63.1505(b)(1)]

35.b.  Group 1 furnaces:. The following limits apply to Group 1 furnaces for purposes of determining the emission standards for SAPUs:

35.b.i.  Particulate matter (PM)/non-clean charge: 0.40 pound per ton of feed/charge; [40 CFR §63.1505(i)(1)]

35.b.ii.  Particulate matter (PM)/clean charge: 0.80 pound per ton of feed/charge; [40 CFR §63.1505(i)(2)]

35.b.iii.  Dioxin/furan (D/F TEQ)/non-clean charge: 2.1x 10-4 gr of D/F TEQ per ton of feed/charge); [40 CFR 63.1505(i)(3)

35.b.iv.  Hydrogen chloride (HCl): 0.40 pound per ton of feed/charge; [40 CFR §63.1505(i)(4)]

35.b.v.  The permittee may determine the emissions standards for a SAPU by applying the group 1 furnace limits on the basis of the aluminum production weight in each group 1 furnace, rather than on the basis of the feed/charge. [40 CFR §63.1505(i)(6)]

35.c.  In-line fluxer. Visible emissions from the in-line fluxer (emissions unit B-3c.1, B-3c.2, and B-3c.3) must not exceed 10% opacity if an add-on control device is used to control PM emissions and a COM is chosen as the monitoring option. [40 CFR §63.1505(j)(4)]

35.d.  Secondary aluminum processing unit (SAPU). The emissions standards for SAPU are deteremined as follows:

35.d.i.  Particulate matter (PM): The permittee must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour rolling average emissions of PM in excess of: [40 CFR §63.1505(k)(1)]

image

 

 

Where,

LtiPM  =  The PM emission limit for individual emission unit i in Condition 35.b.i for a group 1 furnace

Tti  =  The feed/charge rate for individual emission unit i; and

LcPM  =  The PM emission limit for the secondary aluminum processing unit.

Note: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are not subject to the PM limit.

35.d.ii.  Hydrogen chloride (HCl): The permittee must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour rolling average emissions of HCl in excess of: [40 CFR §63.1505(k)(2)]

image

 

 

Where,

LtiHCl  =  The HCl emission limit for individual emission unit i in Condition 35.b.i for a group 1 furnace

Tti  =  The feed/charge rate for individual emission unit i; and

LcHCl  =  The HCl emission limit for the secondary aluminum processing unit.

Note: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are not subject to the HCl limit.

35.d.iii.  Dioxin/furan (D/F): The permittee must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour rolling average emissions of D/F in excess of: [40 CFR §63.1505(k)(3)]

image

 

 

Where,

LtiD/F  =  The D/F emission limit for individual emission unit i in Condition 35.b.i for a group 1 furnace

Tti  =  The feed/charge rate for individual emission unit i; and

LcD/F  =  The D/F emission limit for the secondary aluminum processing unit.

Note: Clean charge furnaces cannot be included in this calculation since they are not subject to the D/F limit.

35.d.iv.  The permittee may demonstrate compliance with emission limits of Conditions 35.d.i and 35.d.iii by demonstrating that each emission unit with the SAPU is in compliance with the applicable emission limits in Conditions 35.b.i and 35.b.iii. [40 CFR §63.1505(k)(4)]

 

36.  On or after the date on which the initial performance test is conducted or required to be conducted, whichever date is earlier, the permittee must operate all new and existing affected sources and control equipment according to the requirements listed below. The completion of the initial performance tests for SAPUs shall be considered the date of approval of the OM&M plan. [40 CFR §63.1506(a)(1) and (2)]

 

36.a.  Labeling. The permittee must provide and maintain easily visible labels posted at each group 1 furnace, group 2 furnace, and in-line fluxer that identifies the applicable emission limits and means of compliance, including: [40 CFR §63.1506(b)]

36.a.i.  The type of affected source or emission unit (e.g., group 1 furnace, in-line fluxer, or group 2 furnace).

36.a.ii.  The applicable operational standard(s) and control method(s) (work practice or control device). This includes, but is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials and addition practices, and the applicable operating parameter ranges and requirements as incorporated in the OM&M plan.

36.b.  Capture/collection systems. For each affected source or emission unit equipped with an add-on air pollution control device (emissions units B-3c.1, B-3c.2, B-3c.3, B-4a.1, B-4a.2, B-4a.3, and B-4a.4), the permittee must: [40 CFR §63.1506(c)]

36.b.i.  Design and install a system for the capture and collection of emissions to meet the engineering standards for minimum exhaust rates as published by the American Industrial hygienists in chapters 3 and 5 of “Industrial Ventilation: A Manual of Recommended Practice” (incorporated by reference);

36.b.ii.  Vent captured emissions through a closed system, except that dilution air may be added to emission streams for the purpose of controlling temperature at the inlet to a fabric filter; and

36.b.iii.  Operate each capture/collection system according to the procedures and requirements in the OM&M plan.

36.c.  Feed/charge weight. The permittee must: [40 CFR §63.1506(d)]

36.c.i.  Except as provided in Condition 36.c.iii, install and operate a device that measures and records or otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the performance test; and

36.c.ii.  Operate each weight measurement system or other weight determination procedure in accordance with the OM&M plan.

36.c.iii.  The permittee may chose to measure and record aluminum production weight from an affected source or emission unit rather than feed/charge weight to an affected source or emission unit provided that:

36.c.iii.A.  The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission units within a SAPU; and

36.c.iii.B.  All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum production weight rather than feed/charge weight.

36.d.  In-line fluxer using no reactive flux material. The permittee must operate each in-line fluxer using no reactive flux materials (emissions units B-3c.1, B-3c.2, and B-3c.3) using no reactive flux materials. [40 CFR §63.1506(l)]

36.e.  Group 1 furnaces without add-on air pollution control devices. For each group 1 furnace, including a group 1 furnace that is part of a SAPU, without add-on pollution control devices (emissions units A-3a.1, A-3a.2, A-3a.3, and A-3a.5), the permittee must: [40 CFR §63.1506(n)]

36.e.i.  Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the performance test at or below the average rate established during the performance test.

36.e.ii.  Operate each furnace in accordance with the work practice/pollution prevention measures documented in the OM&M plan and within the parameter values or ranges established in the OM&M plan.

36.e.iii.  Operate each group 1 melting/holding furnace subject to the emission standards in Condition 35.b.i using only clean charge as the feedstock.

36.f.  Group 2 furnaces. For each group 2 furnace (emission units A-3a.4, A-3b.1, B-3b, B-3c.1, B-3c.2, B-3c.3, B-3d.1, B-3d.2, B-3d.3, B-3d.4, B-4a.1, B-4a.2, B-4a.3, and B-4a.4), the permittee must: [40 CFR §63.1506(o)]

36.f.i.  Operate each furnace using only clean charge as the feedstock.

36.f.ii.  Operate each furnace using no reactive flux.

36.g.  Corrective action. When a process parameter or add-on air pollution control device operating parameter deviates from the value or range established during the performance test and incorporated into the OM&M plan, the permittee must initiate corrective action. Corrective action must restore operation of the affected source or emission unit (including the process or control device) to its normal or usual mode of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must include follow-up actions necessary to return the process or control device parameter level(s) to the value or range of values established during the performance test and steps to prevent the likely recurrence of the cause of the deviation.

 

Insignificant Activities Emission Limits and Standards

 

37.  The Department acknowledges that insignificant emissions units (IEUs) identified by rule as either categorically insignificant activities or aggregate insignificant emissions as defined in OAR 340-200-0020 exist at facilities required to obtain an Oregon Title V Operating Permit. IEUs must comply with all applicable requirements. In general, the requirements that could apply to IEUs are incorporated as follows:

 

37.a.  OAR 340-208-0110 (20% opacity)

37.b.  OAR 340-226-0210 (0.1 gr/dscf for non-fugitive, non-fuel burning equipment)

37.c.  OAR 340-226-0310 (process weight limit for non-fugitive, non-fuel burning process equipment)

37.d.  OAR 340-228-0210 (0.1 gr/dscf corrected to 12% CO2 or 50% excess air for fuel burning equipment)

 

Unless otherwise specified in this permit or an applicable requirement, the Department is not requiring any testing, monitoring, recordkeeping, or reporting for the applicable emissions limits and standards that apply to IEUs. However, if testing were performed for compliance purposes, the permittee would be required to use the test methods identified in the definitions of “opacity” and “particulate matter” in OAR 340-208-0010 and perform the testing in accordance with the Department’s Source Sampling Manual.

 

 

PLANT SITE EMISSION LIMITS

 

38.  The plant site emissions must not exceed the following during any 12 month consecutive period as monitored in accordance with Condition 102: [OAR 340-222-0030 and 340-222-0040]

 

Pollutant

Plant Site Emission Limit (tons/yr)

Unassigned Emissions (tons/yr)

PM/PM10

434

0

SO2

519

0

NOx

96

0

CO

15418

1995

VOC

234

0

F

51

47

 

38.a.  The permittee may only use Unassigned Emissions after any necessary construction (OAR 340-218-0190) and permit revision applications (OAR 340-218-0120 through 340-218-0180) have been approved by the Department.

38.b.  If not used by 07/01/07, the unassigned emissions will be reduced to the SER. [OAR 340-222-0045]

 

39.  The annual Plant Site Emission Limits for hazardous air pollutants for fee purposes only are the following: [OAR 340-222-0060]

 

EU ID

Hazardous Air Pollutant

tons/year

A-1, A-2

POM

102

A-1

COS

254

 

NESHAP COMPLIANCE PROVISIONS

 

40.  At all times, including periods of startup, shutdown, and malfunction, the permittee shall operate and maintain any affected source, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards. [40 CFR §63.6(e)(1)]

 

40.a.  Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan required in Condition 42.

40.b.  Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable independent of emissions limitations or other requirements in relevant standards.

 

41.  Determination of whether acceptable operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures (including the startup, shutdown, and malfunction plan required in Condition 42), review of operation and maintenance records, and inspection of the source. [40 CFR §63.6(e)(2)]

 

42.  Startup, shutdown, and malfunction plan. The permittee shall develop and implement a written plan as described in 40 CFR §63.6(e)(3) that contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a program of corrective action for malfunctioning process and control systems used to comply with the standard. [40 CFR §63.6(e)(3), §63.850(c), and §63.1516(a)]

 

42.a.  This plan shall be developed by the permittee by the source's compliance date for the relevant standards. The purpose of the startup, shutdown, and malfunction plan is to:

42.a.i.  Ensure that, at all times, the permittee operates and maintains affected sources, including associated air pollution control equipment, in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards;

42.a.ii.  Ensure that the permittee is prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize excess emissions of hazardous air pollutants; and

42.a.iii.  Reduce the reporting burden associated with periods of startup, shutdown, and malfunction, including corrective action taken to restore malfunctioning process and air pollution control equipment to its normal or usual manner of operation.

42.b.  During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain the affected source(s) (including associated air pollution control equipment) in accordance with the procedures specified in the startup, shutdown, and malfunction plan developed under Condition 42.a. [40 CFR §63.6(e)(3)(ii)]

42.c.  When actions taken by the permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, the permittee shall keep records for that event that demonstrate that the procedures specified in the plan were followed. These records may take the form of a "checklist," or other effective form of recordkeeping, that confirms conformance with the startup, shutdown, and malfunction plan for that event. In addition, the permittee shall keep records of these events as specified in Condition 110 (and elsewhere in 40 CFR part 63), including records of the occurrence and duration of each startup, shutdown, or malfunction of operation and each malfunction of the air pollution control equipment. Furthermore, the permittee shall confirm that actions taken during the relevant reporting period during periods of startup, shutdown, and malfunction were consistent with the affected source's startup, shutdown and malfunction plan in the semiannual (or more frequent) startup, shutdown, and malfunction report required in Condition 132. [40 CFR §63.6(e)(3)(iii)]

42.d.  If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, the permittee shall record the actions taken for that event and shall report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event, in accordance with Condition 132.b (unless the permittee makes alternative reporting arrangements, in advance, with the Administrator). [40 CFR §63.6(e)(3)(iv)]

42.e.  The permittee shall keep the written startup, shutdown, and malfunction plan on record after it is developed to be made available for inspection, upon request, by the Administrator for the life of the affected source or until the affected source is no longer subject to the provisions of 40 CFR part 63. In addition, if the startup, shutdown, and malfunction plan is revised, the permittee shall keep previous (i.e., superseded) versions of the startup, shutdown, and malfunction plan on record, to be made available for inspection, upon request, by the Administrator, for a period of 5 years after each revision to the plan. [40 CFR §63.6(e)(3)(v)]

42.f.  To satisfy the requirements of this section to develop a startup, shutdown, and malfunction plan, the permittee may use the affected source's standard operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or other plan, provided the alternative plans meet all the requirements of this condition and are made available for inspection when requested by the Administrator. [40 CFR §63.6(e)(3)(vi)]

42.g.  Based on the results of a determination made under Condition 41, the Administrator may require that the permittee make changes to the startup, shutdown, and malfunction plan for that source. The Administrator may require reasonable revisions to a startup, shutdown, and malfunction plan, if the Administrator finds that the plan: [40 CFR §63.6(e)(3)(vii)]

42.g.i.  Does not address a startup, shutdown, or malfunction event that has occurred;

42.g.ii.  Fails to provide for the operation of the source (including associated air pollution control equipment) during a startup, shutdown, or malfunction event in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards; or

42.g.iii.  Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control equipment as quickly as practicable.

42.h.  If the startup, shutdown, and malfunction plan fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the time the permittee developed the plan, the permittee shall revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed procedures for operating and maintaining the source during similar malfunction events and a program of corrective action for similar malfunctions of process or air pollution control equipment. [40 CFR §63.6(e)(3)(viii)]

 

43.  The permittee must keep records of each startup, shutdown, and malfunction event and record and report if any action taken during a startup, shutdown, or malfunctions is not consistent with the procedures in the SSM plan. In addition to the information required in Conditions 42.a through 42.h, the plan must include the following: . [40 CFR §63.850(c) and §63.1516(a)]

 

43.a.i.  Procedures to be followed if a monitoring device measures an operating parameter outside the limit(s) established under Condition 79 and 86, if visible emissions from an exhaust stack indicating abnormal operation of a control device are observed by the permittee during the daily inspection required in Condition 80, or if a problem is detected during the daily inspection of a wet roof scrubber for potline secondary emission control required in Condition 78.d.ii.

43.a.ii.  Procedures to determine and record the cause of any malfunction and the time the malfunction began and ended; and

43.a.iii.  Corrective actions to be taken in the event of a malfunction of a process or control device, including procedures for recording the actions taken to correct the malfunction or minimize emissions.

 

44.  Compliance with nonopacity emission standards. The nonopacity emission standards set forth in 40 CFR part 63 apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in 40 CFR part 63, subparts LL or RRR. [40 CFR §63.6(f)]

 

45.  Compliance with opacity emission standards. The opacity and visible emission standards set forth in 40 CFR part 63, subpart RRR apply at all times except during periods of startup, shutdown, and malfunction, and as otherwise specified in 40 CFR part 63, subpart RRR. [40 CFR §63.6(f)]

 

 

TESTING REQUIREMENTS

 

46.  Unless otherwise specified in this permit, the permittee must conduct all testing in accordance with the Department’s Source Sampling Manual. [OAR 340-212-0120, 40 CFR 60.8, and 40 CFR 63.7]

 

46.a.  Unless otherwise specified by a state or federal regulation, the permittee must submit a source test plan to the Department at least 30 days prior to the date of the test. The test plan must be prepared in accordance with the Source Sampling Manual and address any planned variations or alternatives to prescribed test methods. The permittee should be aware that if significant variations are requested, it may require more than 30 days for the Department to grant approval and may require EPA approval in addition to approval by the Department.

46.b.  Only regular operating staff may adjust the processes or emission control device parameters during a compliance source test and within two (2) hours prior to the tests. Any operating adjustments made during a compliance source test, which are a result of consultation during the tests with source testing personnel, equipment vendors, or consultants, may render the source test invalid.

46.c.  Unless otherwise specified by permit condition or Department approved source test plan, all compliance source tests must be performed as follows:

46.c.i.  at least 90% of the design capacity for new or modified equipment;

46.c.ii.  at least 90% of the maximum operating rate for existing equipment; or

46.c.iii.  at 90 to 110% of the normal maximum operating rate for existing equipment. For purposes of this permit, the normal maximum operating rate is defined as the 90th percentile of the average hourly operating rates during a 12 month period immediately preceding the source test. Data supporting the normal maximum operating rate must be included with the source test report.

46.d.  Each source test must consist of at least three (3) test runs and the emissions results must be reported as the arithmetic average of all valid test runs. If for reasons beyond the control of the permittee a test run is invalid, the Department may accept two (2) test runs for demonstrating compliance with the emission limit or standard.

46.e.  Source test reports prepared in accordance with the Department’s Source Sampling Manual must be submitted to the Department within 45 days of completing any required source test, unless a different time period is approved in the source test plan submitted prior to the source test.

 

47.  The following procedures and test methods shall be used for measuring pollutant emissions from the primary control system wet SO2 scrubber (A-1b.2) and the secondary control system (A-1a):

 

47.a.  EPA Methods 13B and 14, as modified by Northwest Aluminum Company’s Air Emissions Testing Quality Assurance Plan, shall be used for measuring total fluoride emissions (gaseous and particulate).

47.b.  DEQ Method 5, as modified by Northwest Aluminum Company’s Air Emissions Testing Quality Assurance Plan, shall be used for measuring total particulate matter emissions.

47.c.  EPA Method 6, 6A, or 6B, as modified by Northwest Aluminum Company’s Air Emissions Testing Quality Assurance Plan, shall be used for measuring sulfur dioxide emissions.

47.d.  Particulate matter, fluoride, and sulfur dioxide are sampled simultaneously so the testing must be performed using the test frequencies identified in Condition 51.a.

47.e.  The wet SO2 wet scrubber (A-1b.2) and secondary roof system (A-1a.1) must be tested simultaneously during at least one SO2 wet scrubber test run each year.

47.f.  Simultaneous inlet and outlet testing of at least one of the secondary roof control systems shall be done quarterly. A different control system shall be tested each quarter until all 40 systems are tested.

47.g.  During each test, the permittee shall record the following information:

47.g.i.  aluminum production;

47.g.ii.  wet SO2 scrubber recycle rate, pH, specific gravity, fan flow (dscfm), a fan amps; and

47.g.iii.  secondary system fan flow (dscfm), and water flow rate (gpm).

 

48.  The following procedures and test methods must be used for measuring particulate matter emissions from emission units A-3a.1, A-3a.2, A-3a.3, B-3c.1, B-3c.2, and B-3c.3:

 

48.a.  DEQ Method 5 must be used for measuring particulate emissions from either A-3a.1, A-3a.3, or A-3a.3 and either B-3c.1, B-3c.2, or B-3c.3.

48.b.  During each test run, the permittee must record the amount of aluminum being fluxed, the type and amount of flux materials, and the amount of natural gas being burned.

48.c.  EPA Method 9 must be performed for a minimum of 6 minutes during or within 30 minutes before or after each DEQ Method 5 test run.

48.d.  Source testing must be performed at least once during the permit term within two years after the permit is issued.

 

48.e.  The following procedures and test methods shall be used for verifying the emission factors used to calculate the annual emissions in Condition 102

48.e.i.  DEQ Method 5 shall be used to verify the PM/PM10 emission factors for emission units A-3a.1, A-3a.2, B-3a, B-3c.1 B-3c.2 and B-3c.3.

48.e.ii.  EPA Method 10 shall be used to verify the CO emission factor for emissions unit A-1.

48.e.iii.  EPA Method 7e shall be used to verify the NOx emission factor for emissions unit A-1.

48.e.iv.  EPA Method 24A or 25B shall be used to verify the VOC emission factor for emissions unit A-1.

48.e.v.  During each test, the permittee shall record the appropriate monitored parameter(s) listed in Condition 102.c.

48.e.vi.  The permittee may use the results of any other source testing required by this permit to satisfy the emission factor verification test requirements.

48.e.vii.  The permittee shall submit a summary of all emission factor verification tests to the Department within 45 days of any test. The summary shall include the following information:

48.e.vii.A.  Emissions unit identification;

48.e.vii.B.  Emission results in pounds per hour and in units of the emission factor;

48.e.vii.C.  Process parameters during the test (e.g., aluminum production, aluminum fluxed, flus materials, natural gas usage); and

48.e.vii.D.  Control device operating parameters.

 

49.  Unless otherwise specified in this permit, or an applicable requirement, the Department is not requiring any testing for the applicable emissions limits and standards that apply the emissions units identified in this permit. However, if testing were performed for compliance purposes, the permittee would be required to use the test methods identified in the definitions of “opacity” and “particulate matter” in OAR 340-208-0010 and perform the testing in accordance with the Department’s Source Sampling Manual.

 

NESHAP Test Methods and Procedures

 

General Performance Test Requirement

 

50.  All testing performed to demonstrate compliance with NESHAP limits shall be performed in accordance with the applicable general provisions in 40 CFR §63.7 as shown in Attachment B, including, but not limited to the development and implementation of a quality assurance program that includes a site specific test plan and performance test method audit program.

 

Subpart LL Performance Test Requirements

 

51.  The initial performance test and all subsequent performance tests shall be conducted in accordance the following procedures. [40 CFR §63.847(d)]

 

51.a.  TF emissions from potline. For each potline, the permittee shall measure and record the emission rate of TF exiting the outlet of the primary control system for each potline and the rate of secondary emissions exiting through each roof scrubber. Using the equation in Condition 51.e.i, the permittee shall compute and record the average of at least three runs each quarter (one run per month) for secondary emissions and at least six runs each year (three runs per semi-annual period) for the primary control system to determine compliance with the applicable emission limit. Compliance is demonstrated when the emission rate of TF is equal to or less than the applicable emission limit in Conditions 18 or 18.a.

51.b.  POM emissions from potlines. For each potline, the permittee shall measure and record the emission rate of POM exiting the primary emission control system and the rate of secondary emissions exiting through each roof scrubber. Using the equation in Condition 51.e.ii, the permittee shall compute and record the average of at least three runs each quarter (one run per month) for secondary emissions and at least three runs each year for the primary control system to determine compliance with the applicable emission limit. Compliance is demonstrated when the emission rate of TF is equal to or less than the applicable emission limit in Conditions 19 or 19.a.

51.c.  A test run on the secondary scrubber system is defined as the simultaneous sampling of two roof scrubber fans. Each fan shall be tested at least once during a calendar year. Total emissions from the secondary scrubber system on a potline shall be the average emissions concentration (mg/dscf) from the two fans tested, multiplied by the total gas flow rate from all fans in operation during the test. Total gas flow may be calculated using the average measured flow from the two tested fans multiplied by the total number of fans in operation.

51.d.  If emissions in excess of the applicable TF limit occur while performing quarterly sampling on the secondary scrubber system, the permittee shall conduct monthly sampling 3 runs per month for at least 12 months and may reduce to quarterly sampling when: [40 CFR §63.848(e)(4)]

51.d.i.  The average of all tests performed over the most recent 24-month period does not exceed 60 percent of the applicable limit, and

51.d.ii.  No more than one monthly performance test in the most recent 24-month period exceeds 75 percent of the applicable limit.

51.e.  Equations. The permittee shall determine compliance with the applicable TF and POM emission limits using the following equations and procedures: [40 CFR §63.847(e)]

51.e.i.  Compute the emission rate (Ep) of TF from each potline using the following equation: [40 CFR §63.847(e)(1)]

image

 

 

 

Where:

Ep  =  Emission rate of TF from a potline, (lb/TAP);

Cs1  =  Concentration of TF from the primary control system, (mg/dscf);

Qsd  =  Volumetric flow rate of effluent gas corresponding to the appropriate subscript location, (dscf/hr);

Cs2  =  Concentration of TF as measured from secondary roof scrubbers, (mg/dscf);

P  =  Aluminum production rate, (ton/hr); and

K  =  Conversion factor, (453,600 mg/lb).

 

51.e.ii.  Compute the emission rate (Ep) of POM from each potline using the equation in Condition 51.e.i: [40 CFR §63.847(e)(2)]

 

Where:

Ep  =  Emission rate of POM from the potline, (lb/TAP);

Cs  =  Concentration of POM, (mg/dscf). POM emission data collected during the installation and startup of a cathode shall not be included in Cs.;

 

51.e.iii.  Determine the weight of the aluminum tapped from the potline using the monitoring devices required in Condition 83. [40 CFR §63.847(e)(5)]

51.e.iv.  Determine the aluminum production rate (P) by dividing the number of hours in the calendar quarter (or month, if monthly average) into the weight of aluminum tapped from the potline during the calendar quarter (or month, if monthly average) that includes the three runs of a performance test. [40 CFR §63.847(e)(6)]

51.f.  Test Methods: The permittee shall use the following reference test methods, or modified test methods approved in the site specific test plan, to determine compliance with the applicable emission limits for TF and POM emissions [40 CFR §63.849(a)]

 

51.f.i.  Method 1 in appendix A to 40 CFR part 60 for sample and velocity traverses; [40 CFR §63.849(a)(1)]

51.f.ii.  Method 2 in appendix A to 40 CFR part 60 for velocity and volumetric flow rate; [40 CFR §63.849(a)(2)]

51.f.iii.  Method 3 in appendix A to 40 CFR part 60 for gas analysis; [40 CFR §63.849(a)(3)]

51.f.iv.  Method 13A or Method 13B in appendix A to 40 CFR part 60, or an approved alternative, for the concentration of TF where stack or duct emissions are sampled; [40 CFR §63.849(a)(4)]

51.f.v.  Method 315 in appendix A to 40 CFR part 63 or an approved alternative method for the concentration of POM where stack or duct emissions are sampled; and [40 CFR §63.849(a)(6)]

51.f.vi.  For the secondary wet scrubbers, the permittee shall use methods that meet the intent of the sampling requirements of Method 14 in appendix A of 40 CFR part 60 and that are approved by the DEQ. Sample analysis shall be performed using Method 13A or method 13B in appendix A of 40 CFR part 60 for TF, Method 315 in appendix A of 40 CFR part 63 for POM, or an approved alternative method. [§63.849(b)]

 

Subpart RRR Performance Test Requirements:

 

52.  Prior to conducting a performance test, the permittee must prepare and submit a site-specific test plan meeting the requirements in 40 CFR §63.7(c). [40 CFR §63.1511(a)]

 

53.  Following approval of the site-specific test plan, the permittee must demonstrate initial compliance with each applicable emission, equipment, work practice, or operational standard for each affected source and emissions unit identified in 40 CFR §63.1512. The permittee must also conduct a performance test every 5 years following the initial performance test. The specific performance test requirements are as follows: [40 CFR §63.1511(b), §63.1511(e), and §63.1512]

 

53.a.  Aluminum scrap shredder. The permittee must conduct a performance test to measure PM emissions from aluminum scrap shredder (emissions unit B-5). If visible emissions observations is the selected monitoring option, the permittee must record visible emission observations from each exhaust stack for all consecutive 6-minute periods during the PM emission test according to EPA Method 9 in appendix A to 40 CFR part 60. [40 CFR 60.1512(a)]

53.b.  Group 1 furnaces (including melting holding furnaces) without add-on air pollution control devices. For group 1 furnaces(including a melting/holding furnace) without add-on air pollution control devices, the permittee must include data and information demonstrating compliance with the applicable emissions limits. [40 CFR §63.1512(e)]

53.b.i.  If the group 1 furnace processes other than clean charge material, the permittee must conduct emission tests to measure emissions of PM, HCl, and D/F at the furnace exhaust outlet.

53.b.ii.  If the group 1 furnace processes only clean charge, the permittee must conduct emission tests to simultaneously measure emission of PM and HCl at the furnace exhaust outlet. A D/F test is not required. Each test must be conducted while the group 1 furnace (including a melting/holding furnace) processes only clean charge.

53.b.iii.  The permittee may choose to determine the rate of reactive flux addition to the group 1 furnace and assume, for the purposes of demonstrating compliance with SAPU emission limit, that all reactive flux added to the group 1 furnace is emitted. Under these circumstances, the permittee is not required to conduct an emission test for HCl.

53.c.  Secondary aluminum processing unit (SAPU). The permittee must conduct performance tests as described in Conditions 53.c.i and 53.c.ii. The results of the performance tests are used to establish emission rates in lb/ton of feed/charge for PM and HCl and mg TEQ/Mg of feed/charge for D/F emission from each emission unit. These emission rates are used for compliance monitoring in the calculation of the 3-day, 24-hour rolling average emission rates using the equation in Condition 95. A performance test is require for:[40 CFR §63.1512(j)]

53.c.i.  Each group 1 furnace processing only clean charge to measure emissions of PM and either:

53.c.i.A.  Emission of HCl (for the emission limit); or

53.c.i.B.  The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

53.c.ii.  Each group 1 furnace that processes scrap other than clean charge to measure emisions of PM and D/F and either:

53.c.ii.A.  Emission of HCl (for the emission limit); or

53.c.ii.B.  The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

53.c.iii.  Each in-line fluxer to measure emissions of PM and HCl.

53.d.  Feed/charge weight measurement. During the emission test(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format, the permittee must measure (or otherwise determine) and record the total weight of feed/charge to the affected source or emission unit for each of the three runs and calculate and record the total weight. If the compliance is to be determined based aluminum production weight, the permittee must measure the weight of aluminum produced by the emission unit or affected source instead of feed/charge weight. [40 CFR §63.1512(k)]

53.e.  Flux injection rate. The permit must use these procedures to establish an operating parameter value or range for the total reactive chlorine flux injection rate. [40 CFR §63.1512(o)]

53.e.i.  Continuously measure and record the weight of gaseous or liquid reactive flux injected for each 15 minute period during the HCl and D/F tests, determine and record the 15-minute block average weights, and calculate and record the total weight of the gaseous or liquid reactive flux for the 3 test runs;

53.e.ii.  Record the identity, composition, and total weight of each addition of solid reactive flux for the three 3 test runs;

53.e.iii.  image

 

Determine the total reactive chlorine flux injection rate by adding the recorded measurement of the total weight of chlorine in the gaseous or liquid reactive flux injected and the total weight of chlorine in the solid reactive flux using the following equation:

where,

Wt  =  Total chlorine usage, by weight;

F1  =  Fraction of gaseous or liquid flux that is chlorine;

W1  =  Weight of reactive flux gas injected;

F2  =  Fraction of solid reactive chloride flux that is chlorine (e.g., F = 0.75 for magnesium chloride); and

W2  =  Weight of solid reactive flux.

 

53.e.iv.  Divide the weight of total chlorine usage (Wt) for the 3 test runs by the recorded measurement of the total weight of feed for the 3 test runs; and

53.e.v.  If a solid reactive flux other than magnesium chloride is used, the permittee must derive the appropriate proportion factor subject to approval by the Department.

53.f.  Labeling. For each group 1 furnace, group 2 furnace, and in-line fluxer, the permittee must submit the information described in 40 CFR §63.1515(b)(3) as part of the notification of compliance status report to document conformance with the operational standard in Condition 36.a. [40 CFR §63.1512(r)]

53.g.  Capture/collection system. The permittee must submit information as part of the compliance status report to document conformance with the operational standard in Condition 36.b. [40 CFR §63.1512(s)]

 

54.  The permittee must conduct each performance test according to the following requirements: [40 CFR §63.1511(b)]

 

54.a.  The permittee must conduct each test while the affected source or emission unit is operating at the highest production level with charge materials representative of the range of materials processed by the unit and, if applicable, at the highest reactive fluxing rate.

54.b.  Each performance test for a continuous process must consist of 3 separate runs; pollutant sampling for each run must be conducted for the time period specified in the applicable method or, in the absence of a specific time period in the test method, for a minimum of 3 hours.

54.c.  Each performance test for a batch process must consist of three separate runs; pollutant sampling for each run must be conducted over the entire process operating cycle. Note: NWA operations are not batch processes.

54.d.  Where multiple affected sources or emission units are exhausted through a common stack, pollutant sampling for each run must be conducted over a period of time during which all affected sources or emission units complete at least 1 entire process operating cycle or for 24 hours, whichever is shorter.

54.e.  Initial compliance with an applicable emission limit or standard is demonstrated if the average of three runs conducted during the performance test is less than or equal to the applicable emission limit or standard.

 

55.  The permittee must use the following methods in appendix A of 40 CFR part 60 to determine compliance with the applicable emission limits or standards: [40 CFR §63.1511(c)]

 

55.a.i.  Method 1 for sample and velocity traverses.

55.a.ii.  Method 2 for velocity and volumetric flow rates.

55.a.iii.  Method 3 for gas analysis.

55.a.iv.  Method 4 for moisture content of the stack gas.

55.a.v.  Method 5 for the concentration of PM.

55.a.vi.  Method 9 for visible emission observations.

55.a.vii.  Method 23 for the concentration of D/F.

55.a.viii.  Method 25A for the concentration of THC, as propane.

55.a.ix.  Method 26A for the concentration of HCl. Where a lime-injected fabric filter is used as the control device to comply with the 90 percent reduction standard, the permittee must measure the fabric filter inlet concentration of HCl at a point before the lime is introduced to the system.

 

56.  The permittee may use an alternative test method, subject to approval by the Administrator (EPA). [40 CFR §63.1511(d)]

 

57.  With the approval of the Department, a single representative or similar group 1 furnace or in-line fluxer which is not controlled by an add-on control device may be tested to determine the emission rate of all like affected sources at a facility provided that: [40 CFR §63.1511(f)]

 

57.a.  The tested emissions unit must use identical feed/charge and flux materials in the same proportions as the emissions units that it represents;

57.b.  The tested emissions unit is subject to the same work practices as the emission units that it represents;

57.c.  The tested emissions unit is of the same design as the emissions units that it represents;

57.d.  The tested emissions unit is tested under the highest load or capacity reasonably expected to occur for any of the emissions units that it represents;

57.e.  At least one of each different style of emissions unit at the facility is tested; and

57.f.  All add-on control devices are tested.

 

58.  Compliance with the emission limits or standards is determined using the following equations: [40 CFR §63.1513]

 

58.a.  THC emission limit. Use the following equation to determine compliance with an emission limit for THC:

image

 

where,

E  =  Emission rate of measured pollutant, kg/Mg (lb/ton) of feed;

C  =  Measured volume fraction of pollutant, ppmv;

MW  =  Molecular weight of measured pollutant, g/g-mole (lb/lb-mole): THC (as propane) – 44.11;

Q  =  Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr);

K1  =  Conversion factor, 1 kg/1,000 g (1lb/lb);

K2  =  Conversion factor, 1,000 L/m3 (1 ft3/ft3);

Mv  =  Molar volume, 24.45 L/g-mole (385.3 ft3/lb-mole); and

P  =  Production rate, Mg/hr (ton/hr).

58.b.  PM, HCl, and D/F emission limits. Use the following equation to determine compliance with an emission limit for PM, HCl, and D/F:

image

 

 

where,

E  =  Emission rate of PM, HCl, or D/F, kg/Mg (lb/ton) of feed;

C  =  Concentration of PM, HCl, or D/F, g/dscm (gr/dscf);

Q  =  Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr);

K1  =  Conversion factor, 1 kg/1,000 g (1lb/7,000 gr); and

P  =  Production rate, Mg/hr (ton/hr).

58.c.  HCl percent reduction standard. Use the following equation to determine compliance with an HCl percent reduction standard:

 

image

 

where,

%R  =  Percent reduction of the control device;

Li  =  Inlet loading of pollutant, kg/Mg (lb/ton); and

Lo  =  Outlet loading of pollutant, kg/Mg (lb/ton)

58.d.  Conversion of D/F measurements to TEQ units. To convert D/F measurements to TEQ units, the permittee must use the procedures and equations in “Interim Procedures for Estimating Risks Associated with Exposures to Mixtures of Chlorianted Dibenzo-p-Dioxins and –Dibenzofurans (CDDs and CDFs) and 1989 Update” [EPA-625/3-89-016], incorporated by reference in 40 CFR §63.1502, available from the National Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, Virginia, NTIS no. PB 90-145756.

58.e.  Secondary aluminum processing unit. Use the procedures in Conditions 58.e.i, 58.e.ii, and 58.e.iii or the procedure in Condition 58.e.iv to determine compliance with emission limits for a secondary aluminum processing unit.

58.e.i.  Use the following equation to compute the mass-weight PM emissions for a secondary aluminum processing unit. Compliance is achieved if the mass-weight emissions for the secondary aluminum processing unit (EcPM) is less than or equal to the emission limit for the secondary aluminum processing unit (LcPM) calculated using Equation 1 in Condition 35.d:

image

 

 

where,

EcPM  =  The mass-weighted PM emissions for the secondary aluminum processing unit;

EtiPM  =  Measured PM emissions for individual emission unit i;

Tti  =  The average feet rate for individual emission unit i during the operating cycle or performance test period; and

n  =  The number of emissions units in the secondary aluminum processing unit.

58.e.ii.  Use the following equation to compute the aluminum mass-weighted HCl emissions for the secondary aluminum processing unit. compliance is achieved if the mass-weighted emissions for the secondary aluminum processing unit (EcHCl) is less than or equal to the emission limit for the secondary aluminum processing unit (LcHCl) calculated using Equation 2 in Condition 35.d:

image

 

where,

EcHCl  =  The mass-weighted HCl emissions for the secondary aluminum processing unit; and

EtiHCl  =  Measured HCl emissions for individual emission unit i.

58.e.iii.  Use the following equation to compute the aluminum mass-weighted D/F emissions for the secondary aluminum processing unit. compliance is achieved if the mass-weighted emissions for the secondary aluminum processing unit (EcD/F) is less than or equal to the emission limit for the secondary aluminum processing unit (LcD/F) calculated using Equation 3 in Condition 35.d

image

 

where,

EcD/F  =  The mass-weighted D/F emissions for the secondary aluminum processing unit; and

EtiD/F  =  Measured D/F emissions for individual emission unit i.

58.e.iv.  As an alternative to using the equations in Conditions 58.e.i, 58.e.ii, and 58.e.iii, the permittee may demonstrate compliance for a secondary aluminum processing unit by demonstrating that each existing group 1 furnace is in compliance with the emission limits for a new group 1 furnace in Condition 35.b and that each existing in-line fluxer is in compliance with the emission limits for a new in-line fluxer Condition 35.c.

 

59.  The permittee must establish a minimum or maximum operating parameter value, or an operating parameter range for each parameter to be monitored as required by 40 CFR §63.1510 that ensure compliance with the applicable emission limit or standard. To establish the minimum or maximum value or range, the permittee must use the appropriate procedures in this condition and submit the information required by §63.1515(b)(4) in the notification of compliance status report. The permittee may use existing data in addition to the results of performance tests to establish operating parameter values for compliance monitoring provided each of the following conditions are met to the satisfaction of the Department: [40 CFR §63.1511(g)]

 

59.a.  The complete emission test report(s) used as the basis of the parameter(s) is submitted.

59.b.  The same test methods and procedures as required by subpart RRR of 40 CFR part 63 were used in the test.

59.c.  The permittee certifies that no design or work practices changes have been made to the source, process, or emission control equipment since the time of the report;

59.d.  All processes and control equipment operating parameters required to be monitored were monitored as required in subpart RRR of 40 CFR part 63 and documented in the test report.

 

 

MONITORING REQUIREMENTS

 

The monitoring conditions in this section are based on OAR 340-218-0050(3)(a); unless otherwise specified.

 

General Monitoring Requirements

 

60.  The permittee must not knowingly render inaccurate any required monitoring device or method. [OAR 340-218-0050(3)(a)(E)]

 

61.  Methods used to determine actual emissions for fee purposes must also be used for compliance determination and can be no less rigorous than the requirements of OAR 340-218-0080. [OAR 340-218-0050(3)(a)(F)]

 

62.  Monitoring requirements must commence on the date of permit issuance unless otherwise specified in the permit or an applicable requirement. [OAR 340-218-0050(3)(a)(G)]

 

Primary and Secondary Aluminum Facilities:

 

63.  The permittee shall maintain monthly and annual records of all fuels used, except those fuels used in motor vehicles, for monitoring pertaining to Condition 6.

 

64.  The permittee shall maintain a log recording all written complaints or complaints received via telephone by the responsible official or a designated representative that specifically refer to a complaint of fugitive emissions or opacity from the permitted facility for monitoring pertaining to Condition 4, 5 and 7. The log shall also record permittee’s actions to investigate, make a determination as to the validity of the complaint, and resolve the problem, if possible, within two working days of receiving the complaint.

 

65.  The permittee shall maintain weekly records of inspection and maintenance procedures for monitoring pertaining to Condition 7:

 

65.a.  The permittee shall inspect the following areas for fugitive emissions:

65.a.i.  Storage room for wet collected material from the secondary scrubber fan rooms and other similar containers;

65.a.ii.  Cell room (A-1) windows; and

65.a.iii.  Cell room (A-1) doors.

65.b.  Inspection records of dates and times of any visible emissions observed, recorded on inspection forms.

65.c.  Maintenance activity records of any preventative or corrective action taken as a result of the weekly inspections, recorded in a maintenance log. Note: Work order are considered adequate records for the purposes of the is requirement.

 

66.  The permittee shall maintain monthly records of down time and the length of the down time for all pollution control devices, recorded in a maintenance log for monitoring pertaining to Condition 8.

 

67.  The permittee shall maintain quarterly records (e.g., source test results) of any changes in collection efficiency resulting from equipment or process changes for all pollution control devices for monitoring pertaining to Condition 9. The records shall consist of the results from the inlet and outlet testing of the secondary roof system (A-1a.1 through A-1a.5) required in Condition 47 and control device monitoring required in Condition 73.

 

68.  The permittee shall maintain records of air pollution episodes and emission reduction actions taken, recorded in a maintenance log for monitoring pertaining to Condition 10.

 

69.  The permittee shall perform all certification and recordkeeping requirements in accordance with 40 CFR part 82, subpart B; Servicing of Motor Vehicle Air Conditioners for monitoring pertaining to Condition 11.

 

 

Primary Aluminum Facility:

 

70.  The permittee shall maintain monthly and annual records for monitoring pertaining to Conditions 14 through 17:

 

70.a.  The permittee shall maintain records for calculating total and gaseous fluoride, total particulate matter (including fluoride particulate), and sulfur dioxide emissions.

70.b.  The permittee shall calculate monthly emissions of total particulate from emissions units A-2, A-3, and A-4, and sulfur dioxide from emissions unit A-3 in units of lbs/TAP/month using the equation and the emission factors in Condition 102 based on the previous month’s production and fuel usage.

70.c.  The permittee shall calculate annual emissions of total particulate matter from emissions units A-2, A-3, and A-4, and sulfur dioxide from emissions unit A-3 in units of lbs/TAP/year using the equation and emission factors in Condition 102 based on that month’s production and fuel usage and the previous 11 months of production and fuel usage.

70.d.  The permittee shall calculate emissions of total particulate matter, total and gaseous fluoride, and sulfur dioxide emissions from emissions unit A-1 in units of lbs/TAP/month and lbs/TAP/year from the source test data required in Condition 47.

70.d.i.  The emission in lbs/TAP/year shall be based on a 12-month rolling average. Each quarters source test results, in units of lbs/TAP/month shall be added to the previous three quarters of emissions data and averaged to obtain lbs/TAP/year.

70.d.ii.  The monthly PSEL shall be calculated by multiplying the lbs/TAP/month emissions by the production for the month. The annual PSEL shall be calculated by multiplying the lbs/TAP/year emissions by the production for the year.

70.e.  The emissions calculated in Conditions 70.b and 70.c shall be added to the emissions calculated in Condition 70.d.

 

 

Cell Rooms (emissions unit A-1) monitoring:

 

71.  The permittee shall maintain daily records of inspection and maintenance procedures for the wet SO2 scrubber (A-1b.2) and the secondary roof scrubber system (A-1a.1 through A-1a.5) contained in Northwest Aluminum Company’s Air Emissions Testing Quality Assurance Plan dated September 30, 1993 and updated on November 15, 1994 or later version approved by the Department, for monitoring pertaining to Condition 22:

 

71.a.  Inspection records of the date, time, and the device or process inspected, recorded on inspection forms.

71.b.  Maintenance activity records of any preventative or corrective action taken as a result of the daily inspections, recorded in a maintenance log. If corrective action is required, the permittee shall determine whether an exceedance of Condition 22 may have occurred. Maintenance activity records shall also include routine maintenance performed on an annual basis.

 

72.  The permittee shall maintain records of truck feeder schedules for monitoring pertaining to Conditions 22 and 23:

 

72.a.  The permittee shall maintain computerized records which contain schedules of alloy and ore feeding to ensure consecutive feeding of all pots.

72.b.  The computer schedules may be used to document the daily activities.

 

73.  The permittee shall install, calibrate, maintain, and operate a continuous parameter monitoring system (CPMS) in accordance with the Department’s Continuous Monitoring Manual, the manufacturer’s written instructions and Northwest Aluminum Company’s Air Emissions Testing Quality Assurance Plan dated September 30, 1993 and updated on November 15, 1994 or later version approved by the Department, for monitoring pertaining to Conditions 26, 27, and 28 and record the output of the system.

 

73.a.  Monitoring shall be continuous using a daily averaging period. The daily average shall be calculated from 1-hour averages.

73.b.  Insufficient data completeness, excluding CPMS downtime due to zero and span checks, performance audits, and routine maintenance, will void that data period.

 

74.  The permittee shall maintain records of paste leaks from the anodes of the pots in emissions unit A-1, upon occurrence, and the corrective action taken for monitoring pertaining to Condition 25.

 

NESHAP Emissions Monitoring Requirements

 

General Monitoring Requirement

 

75.  All monitoring shall be performed in accordance with the applicable general provisions in subpart A of 40 CFR part 63 as shown in Attachment B, “NWA Emissions Quality Assurance Plan” required by Condition 104, and the following specific requirements.

 

Subpart LL Monitoring Requirements

 

76.  TF emissions from potlines. Using the procedures in Condition 51.a and 51.c and the approved site-specific test plan, the permittee shall monitor emissions of TF from each potline by conducting quarterly (or monthly) performance tests. The permittee shall compute and record the quarterly average from at least three runs for secondary emissions and the previous 12-month average of all runs for the primary control system to determine compliance with the applicable emission limit. All valid test runs must be included in the average. The duration of each run for secondary emissions must represent a complete operating cycle. The primary control system must be sampled over an 8-hour period, unless site-specific factors dictate an alternative sampling time subject to the approval of the Department. [40 CFR §63.848(a)]

 

77.  POM emissions from potlines. Using the procedures in Condition 51.b and 51.c and the approved site-specific test plan, the permittee shall monitor emissions of POM from each potline every three months. The permittee shall compute and record the quarterly (3-month) average from at least one run per month for the secondary emissions and the previous 12-month average of all runs for the primary control systems to determine compliance with the applicable emission limit. All valid test runs must be included in the average. The duration of each test run for secondary emission tests must represent a complete operating cycle. The primary control system must be sampled over an 8-hour period, unless site-specific factors dictate an alternative sampling time subject to the approval of the Department. [40 CFR §63.848(b)]

 

78.  Monitoring parameters for emission control devices. The permittee shall install, operate, calibrate, and maintain a continuous parameter monitoring system for each emission control device. The following monitoring devices shall be installed: [40 CFR §63.848(f) and §63.848(l) and OAR 340-212-0250]

 

78.a.  For dry alumina scrubbers, devices for the measurement of alumina flow, air flow (fan amps), and pressure drop;

78.b.  For dry coke scrubbers, devices for the measurement of coke flow and air flow;

78.c.  For wet scrubbers as the primary control system, recycle water flow rate, recycle water pH, and recycle water specific gravity;

78.d.  For wet roof scrubbers for secondary emission control:

78.d.i.  A device for the measurement of total water flow; and

78.d.ii.  The permittee shall inspect each control device at least once each operating day to ensure the control device is operating properly and record the results of each inspection.

 

79.  Selection of monitoring parameters. The parameter operating limits and monitoring frequency for each control device are identified in Attachment C. [40 CFR §63.847(h) and OAR 340-212-0210]

 

79.a.  The parameter monitoring required by the primary aluminum production NESHAP have MACT included in parenthesis after the control device performance indicator in the table. All other parameter monitoring is required for compliance assurance monitoring.

79.b.  The permittee may re-determine the upper and/or lower operating limits, as appropriate, based on historical data or other information and submit a minor permit modification application to the applicable regulatory authority to change the applicable limit(s). The re-determined limits shall become effective upon approval by the Department.

 

80.  Visible emissions. The permittee shall visually inspect the exhaust stack(s) of each control device on a daily basis for evidence of any visible emissions indicating abnormal operation. [40 CFR §63.848(g) and OAR 340-212-0210]

 

81.  Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the limits(s) established pursuant to Condition 79, if visible emissions indicating abnormal operations are observed from the exhaust stack of a control device during a daily inspection, or if a problem is detected during the daily inspection of a wet roof scrubber for potline secondary emission control, the permittee shall initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within 1 hour. Failure to initiate the corrective action procedures within 1 hour or to take the necessary corrective actions to remedy the problem is a violation. [40 CFR §63.848(h) and OAR 340-212-0210]

 

82.  Exceedances. If the limit for a given operating parameter associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period. [40 CFR §63.848(i) and OAR 340-212-0210]

 

83.  Weight of aluminum. The permittee shall install, operate, and maintain a monitoring device to determine the daily weight of aluminum produced. [40 CFR §63.848(j)]

 

84.  Accuracy and calibration. The permittee shall submit recommended accuracy requirements to the regulatory authority for review and approval in accordance with Condition 104. All monitoring devices required by this section must be certified by the permittee to meet the accuracy requirements and must be calibrated in accordance with the manufacturer’s instructions. [40 CR §63.848(k) and OAR 340-212-0210]

 

Subpart RRR Monitoring Requirements

 

85.  On or after the initial performance test is completed, or is required to be completed, whichever date is earlier, the permittee must monitor all control equipment and processes according to the requirements in 40 CFR §63.1510. Monitoring requirements for each type of affected source and emission unit are summarized in Attachment E. [40 CFR §63.1510(a)]

 

86.  The permittee must prepare and implement for each new or existing affected source and emissions unit, a written operation, maintenance, and monitoring (OM&M) plan. The permittee must submit the plan to the Department for review and approval. Any subsequent changes to the plan must be submitted to the Department for review and approval. Pending approval by the Department of an initial or amended plan, the permittee must comply with the provisions of the submitted plan. Each plan must contain: [40 CFR §63.1510(b)]

 

86.a.  Process and control device parameters to be monitored to determine compliance, along with established operating levels or ranges, as applicable, for each process and control device, as determined in accordance with Condition 59.

86.b.  A monitoring schedule for each affected source and emission unit.

86.c.  Procedures for the proper operation and maintenance of each process unit and add-on control device used to meet the applicable emission limits or standards in 40 CFR §63.1505.

86.d.  Procedures for the proper operation and maintenance of monitoring devices or systems used to determine compliance, including:

86.d.i.  Calibration and certification of accuracy of each monitoring device, at least once every 6 months, according to the manufacturer’s instructions; and

86.d.ii.  Procedures for the quality control and quality assurance of continuous emission or opacity monitoring systems as required by the general provision in subpart A of 40 CFR part 63.

86.e.  Procedures for monitoring process and control device parameters, including procedures for annual inspections of afterburners (if applicable) and the procedure to be used for determining chagre/feed (or throughput) weight if a measurement device is not used.

86.f.  Corrective actions to be taken when process or operating parameters or add-on control device parameters deviate from the value or range established in Condition 59, including:

86.f.i.  Procedures to determine and record the cause of a deviation or excursion, and the time the deviation or excursion began and ended; and

86.f.ii.  Procedures for recording the corrective action taken, the time corrective action was initiated, and the time/date corrective action was completed.

86.g.  A maintenance schedule for each process and control device that is consistent with the manufacturer’s instructions and recommendations for routine and long-term maintenance.

86.h.  Documentation of the work practice and pollution prevention measures used to achieve compliance with the applicable emission limits and a site-specific monitoring plan as require in 40 CFR §63.1510(o) for each group 1 furnace not equipped with an add-on air pollution control device.

 

87.  Labeling. The permittee must inspect the labels for each group 1 furnace, group 2 furnace, and in-line fluxer at least once per calendar month to confirm that posted labels as required by Condition 36.a are intact and legible. [40 CFR §63.1510(c)]

 

88.  Capture/collection system. The permittee must: [40 CFR §63.1510(d)]

 

88.a.  Install, operate, and maintain a capture/collection system for each affected source and emission unit quipped with an add-on air pollution control device; and

88.b.  Inspect each capture/collection and closed vent system at least once each calendar year to ensure that each system is operating in accordance with the operating requirements in Condition 36.b and record the results of each inspection.

 

89.  Feed/charge weight. The permittee must install, calibrate operate, and maintain a device to measure and record the total weight of feed/charge to, or aluminum production from, any affected source and emission unit subject to an emission limit in kg/Mg (lb/ton) of feed/charge over the same operating cycle or time period used in the performance test. Feed/charge or aluminum production with SAPUs must be measured and recorded on an emissions unit-by-emissions unit basis. As an alternative to a measurement device, the permittee may use a procedure acceptable to the Department to determine the total weight of feed/charge or aluminum production to the affected source or emissions unit. [40 CFR §63.1510(e)]

 

89.a.  The accuracy of the weight measurement device or procedure must be ±1 percent of the weight being measure. The permittee may apply to the Department for approval to use a device of alternative accuracy if the required accuracy cannot be achieved as a result of equipment layout or charging practices. A device of alternative accuracy will not be approved unless the permittee provides assurance through data and information that the affected source will meet the relevant emission standard.

89.b.  The permittee must verify the calibration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration schedule is specified, at least every 6 months.

 

90.  Total reactive flux injection rate. These requirements apply to each group 1 furnace (with or without add-on air pollution control devices) or in-line fluxer. The permittee must: [40 CFR §63.1510(j)]

90.a.  Install, calibrate, operate, and maintain a device to continuously measure and record the weight of gaseous or liquid reactive flux injected to each affected source or emissions unit.

90.a.i.  The monitoring system must record the weight for each 15-minute block period, during which reactive fluxing occurs, over the same operating cycle or time period used in the performance test.

90.a.ii.  The accuracy of the weight measurement device must be ±1 percent of the weight of the reactive component of the flux being measured. The permittee may apply to the Department for permission to use a weight measurement device of alternative accuracy in cases where the reactive flux flow rates are so low as to make the use of a weight measurement device of ±1 percent impracticable. A device of alternative accuracy will not be approved unless the permittee provides assurance through data and information that the affected source will meet the relevant emission standards.

90.a.iii.  The permittee must verify the calibration of the weight measurement device in accordance with the schedule specified by the manufacturer, of if no calibration schedule is specified, at least once every 6 months.

90.b.  Calculate and record the gaseous or liquid reactive flux injection rate (kg/Mg or lb/ton) for each operating cycle or time period used in the performance test using the procedure in Condition 53.e.

90.c.  Record, for each 15-minute block period during each operating cycle or time period used in the performance test during which reactive fluxing occurs, the time, weight, and type of flux for each addition of:

90.c.i.  Gaseous or liquid flux other than chlorine; and

90.c.ii.  Solid reactive flux.

90.d.  Calculate and record the total reactive flux injection rate for each operating cycle or time period used in the performance test using the procedure in Condition 53.e.

90.e.  For a group 1 furnace or in-line fluxer performing reactive fluxing, the permittee may apply to the Administrator (EPA) for approval of an alternative method for monitoring and recording the total reactive flux addition rate based on monitoring the weight or quantity of reactive flux per ton of feed/charge for each operating cycle or time period used in the performance test. An alternative monitoring method will not be approved unless the permittee provides assurance through data and information that the affected source will meet the relevant emission standards on a continuous basis.

 

91.  In-line fluxers using no reactive flux. For in-line fluxers that do not use reactive flux materials, the permittee must submit a certification of compliance with the operational standard for no reactive flux materials in 40 CFR §63.1506(l) for each 6-month reporting period. Each certification must contain the information in Condition 136.b.iv. [40 CFR §63.1510(m)]

 

92.  Group 1 furnace without add-on air pollution control devices. These requirements apply to a group 1 furnace that is not equipped with an add-on air pollution control device. [40 CFR §63.1510(o)]

 

92.a.  The permittee must develop, in consultation with the Department, a written site-specific monitoring plan in accordance with 40 CFR §63.1510(o) and 40 CFR §63.1510(p) & (q), if applicable. The site-specific monitoring plan must be part of the OM&M plan that addresses monitoring and compliance requirements for PM, HCl, and D/F emissions.

92.b.  The permittee must submit the site-specific test plan to the Department for review.

 

93.  Group 2 furnace. These requirements apply to a new or existing group 2 furnace. The permittee must: [40 CFR §63.1510(r)]

 

93.a.  Record a description of the materials charge to each furnace, including any non-reactive, non-HAP containing/non-HAP-generating fluxing materials or agents.

93.b.  Submit a certification of compliance with the applicable operational standard for charge materials in Condition 36.f for each 6-month reporting period. Each certification must contain the information in Condition 136.b.iii.

 

94.  Site-specific requirements for secondary aluminum processing units. [40 CFR §63.1510(s)]

 

94.a.  The permittee must include in the OM&M plan required by Condition 86 the following information:

94.a.i.  The identification of each emission unit in the secondary aluminum processing unit;

94.a.ii.  The specific control technology or pollution prevention measure to be used for each emission unit in the secondary aluminum processing unit and the date of its installation or application;

94.a.iii.  The emission limit calculated for each secondary aluminum processing unit and performance test results with supporting calculations demonstrating initial compliance with each applicable emission limit;

94.a.iv.  Information and data demonstrating compliance for each emission unit with all applicable design, equipment, work practice or operational standards of subpart RRR of 40 CFR part 63; and

94.a.v.  The monitoring requirements applicable to each emission unit in a secondary aluminum processing unit and the monitoring procedures for daily calculation of 3-day, 24-hour rolling average using the procedure in Condition 95.

94.b.  The SAPU compliance procedures within the OM&M plan may not contain any of the following provisions:

94.b.i.  Any averaging among emissions of differing pollutants;

94.b.ii.  The inclusion of any affected sources other than emissions units in a secondary aluminum processing unit;

94.b.iii.  The inclusion of any emissions unit while it is shutdown; or

94.b.iv.  The inclusion of any periods of startup, shutdown, or malfunction in emission calculations.

94.c.  To revise the SAPU compliance provision within the OM&M plan prior to the end of the permit term, the permittee must submit a request to the Department containing the information required by Condition 94.a and obtain approval of the Department prior to implementing any revisions.

 

95.  Secondary aluminum processing unit (SAPU). Except as provided in Condition 96, the permittee must calculate and record the 3-day, 24-hour rolling average emission of PM, HCl, and D/F for each secondary aluminum processing unit on a daily basis. To calculate the 3-day, 24-hour rolling average, the permittee must: [40 CFR §63.1510(t)]

 

95.a.  Calculate and record the total weight of material charged to each emission unit in the secondary processing unit for each 24-hour day or operation using the feed/charge weight information required in Condition 89. If the permittee chooses to comply on the basis of weight of aluminum produced by the emissions unit, rather than weight of material charged to the emissions unit, all performance test emissions results and all calculations must be conducted on the aluminum production weight basis.

95.b.  Multiply the total feed/charge weight to the emissions unit, or the weight of aluminum produced by the emissions unit, for each emissions unit for the 24-hour period by the emission rate (in lb/ton of feed/charge) for that emission unit (as determined during the performance test) to provide emissions for each emissions unit for the 24-hour period, in pounds.

95.c.  Divide the total emission for each SAPU for the 24-hour period by the total material charged to the SAPU, or the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the SAPU.

95.d.  Compute the 24-hour daily emission rate using the following equation:

image

 

where,

Eday  =  The daily PM, HCl, or D/F emission rate for the secondary aluminum processing unit for the 24-hour period;

Ti  =  The total amount of feed, or aluminum produced, for emissions unit i for the 24-hour period;

ERi  =  The measure emission rate for emissions unit i as determined in the performance test (lb/ton or µg/Mg of feed/charge); and

n  =  The number of emissions units in the secondary aluminum processing unit.

95.e.  Calculate and record the 3-day, 24-hour rolling average for each pollutant each day by summing the daily emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3.

 

96.  Secondary aluminum processing unit compliance by individual emission unit demonstration. As an alternative to the procedures in Condition 95, the permittee may demonstrate, through performance tests, that each individual emissions unit within the secondary aluminum processing unit is in compliance with the applicable emission limits for the emissions unit. [40 CFR §63.1510(u)]

 

97.  Alternative monitoring methods. The permittee may submit an application to the Administrator (EPA) for approval of alternate monitoring requirements to demonstrate compliance with the emission standards of 40 CFR part 63 subpart RRR subject in accordance with the provisions of 40 CFR §63.1510(w).

 

Paste Plant (emission units A-2a, A-2b, and A-2d), Materials Handling (emissions units A-4a.1, A-4a.2, A-4b.1 through A-4b.6, and A-4f) Monitoring:

 

98.  The permittee shall maintain weekly records of inspection and maintenance procedures for monitoring pertaining to Conditions 30 and 33 for emissions units A-2a, A-2b, and A-2d; Conditions 30 and 34 for emission units A-4a.1, A-4a.2, and A-4b.1 through A-4b.6; and Condition 34 for emissions unitsA-4f at monitoring points A-2a, A-2b, A-2d, A-4a.1, A-4a.2, A-4b.1 through A-4b.6 and a-4f; respectively:

 

98.a.  Inspection records of the baghouse bags and the dry coke scrubber bags, recorded on inspection forms.

98.b.  Maintenance activity records of replacement of baghouse bags on occurrence (when broken and routinely every five (5) years, recorded in a maintenance log.

 

Dowtherm Boiler (emission unit A-2c), Liquid Metal Transfer Furnace (emissions unit A-3a.4), Remelt Furnace (emissions unit A-3a.5), Homogenizing Furnace (emissions unit A-3b.1), and Homogenizing Furnace (emissions unit B-3d) Monitoring:

 

99.  The permittee shall maintain monthly and annual records of total natural gas usage for monitoring pertaining to Conditions 30 through 34 for the emissions units listed above.

 

Holding and Fluxing (emissions units A-3a.1, A-3a.2, A-3a.3, B-3c.1, B-3c.2, and B-3c.3) Monitoring:

 

100.  The permittee shall conduct visible emissions observations in accordance with the following procedures, test methods, and frequencies for monitoring pertaining to Condition 33 for emissions units A-3a.1, A-3a.2, and A-3a.3; and Condition 34 for emissions units B-3c.1, B-3c.2, and B-3c.3:

 

100.a.  Modified EPA Method 9 shall be conducted monthly in accordance with the Department’s Source Sampling Manual at each emission point.

100.b.  Each Modified EPA method 9 test shall be conducted for a minimum observation period of six minutes

100.b.i.  For emission units A-3a.1, A-3a.2, and A-3a.3, if none of the observations exceeds 20% opacity, observations can be discontinued.

100.b.ii.  For emission units B-3c.1, B-3c.2, and B-3c.3, if any of the observations is equal to or greater than 20% opacity, the observation period shall continue for 60 minutes or until an exceedance of Condition 31 (i.e., more than 12 observations equal to or greater than 20% opacity) has been documented, whichever period is shorter, except as provided in Condition 100.c.

 

100.c.  All visible emissions observations shall be conducted during operating conditions that have the potential to create visible emissions (e.g., during fluxing). Visible emissions observations are not required for periods other than fluxing even though 60 minutes of observations have not been recorded.

100.d.  During each visible emissions test, the permittee shall record the amount of aluminum being fluxed and the type and amount of flux materials.

100.e.  If six consecutive monthly observations show opacity within the limits specified in Conditions 33 and 34, the observations need only be done quarterly.

100.f.  If the permittee determines that an exceedance has occurred, the observations shall start over with monthly observations.

 

Materials Handling (emissions unit A-4g) and Carbon Materials Handling (emission units A-4c and A-4d) Monitoring:

 

101.  The permittee shall maintain weekly records of inspection and maintenance procedures for monitoring pertaining to Condition 34 for emission units A-4c, A-4d and A-4g:

 

101.a.  Inspection records of the loading and unloading of the dross, coke, pitch, and aluminum fluoride, recorded on inspection forms.

101.b.  Maintenance activity records of any fugitive emission observed upon occurrence and any corrective action taken, recorded in a maintenance log.

 

 

Plant Site Emissions Monitoring: [OAR 340-222-0080]

 

102.  The permittee shall determine compliance with the Plant Site Emission Limits (PSEL) established in Condition 38 by conducting monitoring in accordance with the following procedures, test methods, and frequencies.

 

102.a.  The permittee shall maintain records of monitored parameters in the table contained in Condition 102.c.

102.b.  Compliance with annual PSELs shall be monitored using the following formula:

 

E  =  EF x P

where:

E  =  Pollutant emissions, tons/year, tons/month

EF  =  PSEL emission factor in Condition 102.c

P  =  Process throughput or production rate per month or year

 

 

102.c.  The following table contains the process throughput or production rate required to be monitored for each PSEL. The table also includes the emission factors for calculating emissions .

 

Emission Source Code

Emission Source Description

Process Code

Process Description

Process Throughput

PM/PM10

SO2

NOx

CO

VOC

PS-1

Cell Rooms

P-1

primary aluminum production

TAP

6.8E+00

8.4E+00

1.1E+00

 

4.7E+00

PS-1

Cell Rooms

P-2

carbon consumed

Tons

   

3.1E-01

 
 

GS-1

Furnaces

P-1

natural gas burned

MMCF

7.5E+00

2.7E+00

1.0E+02

8.4E+01

5.7E+00

GS-2

Casthouses

P-1

total aluminum fluxed

TAP

1.3E-01

    

GS-3

Materials handling

P-1

primary aluminum production

TAP

1.8E-01

    

FS-1

Fugitive emissions

P-1

annual emissions

Year

3.4E+03

2.0E+03

4.0E+03

2.2E+03

8.2E+01

 

102.d.  The emission factors listed in Condition 102.c are not enforceable limits unless otherwise specified in this permit. Compliance with PSELs shall only be certified by the calculations contained in Condition 102 using the monitored parameters recorded during the reporting period.

 

 

Ambient Monitoring Requirements [OAR 340-236-0140(1)(c)]

 

103.  The permittee shall monitor ambient air gaseous fluoride as hydrogen fluoride in accordance with the Northwest Aluminum Company Air Emissions Testing Quality Assurance Plan required by Condition 104. Monitoring shall be done at four stations approved by the Department.:

 

103.a.  Ambient monitoring is not required when the primary aluminum production facility is not operating. The permittee must resume ambient monitoring at least 30 days prior to restarting the primary aluminum production operations.

103.b.  Hydrogen fluoride shall be measured using bicarbonate tube method (ASTM D3268) using a 12-hour averaging period. The daily average shall be calculated from 12-hour averages.

103.c.  The permittee may elect to conduct an evaluation of a continuous ambient monitor as a replacement for the monitoring required in Condition 103.a. The evaluation would include comparisons with existing methods (e.g., ASTM D-3268 and 2-hour dual tape samplers) over a one year period. The results of the study would be submitted to the Department within 60 days of completion.

103.d.  The permittee is not required to monitor forage concentrations of fluoride. [OAR 340-236-0140(1)(b)]

103.e.  The permittee shall continuously monitor wind direction in degrees and wind speed in miles per hour.

103.e.i.  Wind direction and wind speed should be measured using a 15-minute averaging period. The daily average shall be calculated from the 15-minute arithmetic averages. As an alternative, the permittee may record 5-minute averages and use them to calculate the daily average.

103.e.ii.  Meteorological data shall be recorded and maintained on site and reported to the Department upon request.

103.e.iii.  The 5-minute meteorological data collected by this system may be used for computer modeling of ambient impacts provided a quality assurance/quality control plan is established for the monitoring network. The plan must be submitted for Department approval and the system must be audited by the Laboratory Division of the Department before the data can be used for computer modeling. [04/13/92 ACDP 33-0001, Condition 13.a]

 

Quality Assurance Plan

 

104.  An update to NWA Emissions Quality Assurance Plan (QAP) shall be submitted to the Department for review within 90 days after restarting the primary aluminum production operations. The QAP shall include all elements required to insure the integrity of all required emissions and ambient monitoring data. By February 15 of each year, the Department shall be notified of any significant changes to the QAP. The revised QAP must address the following, as applicable:

 

104.a.  Compliance Assurance Monitoring (CAM) requirements;

104.b.  Subpart LL requirements; and

104.c.  Subpart RRR requirements.

 

 

RECORDKEEPING REQUIREMENTS

 

The recordkeeping conditions in this section are based on OAR 340-218-0050(3)(b); unless otherwise specified.

 

General Recordkeeping Requirements

 

105.  The permittee must maintain the following general records of testing and monitoring required by this permit: [OAR 340-218-0050(b)(A)]

 

105.a.  The date, place as defined in the permit, and time of sampling or measurements;

105.b.  The date(s) analyses were performed;

105.c.  The company or entity that performed the analyses;

105.d.  The analytical techniques or methods used;

105.e.  The results of such analyses;

105.f.  The operating conditions as existing at the time of sampling or measurement; and

105.g.  The records of quality assurance for continuous monitoring systems (including but not limited to quality control activities, audits, calibration drift checks).

 

106.  Unless otherwise specified by permit condition, the permittee must make every effort to maintain 100 percent of the records required by the permit. If information is not obtained or recorded for legitimate reasons (e.g., the monitor or data acquisition system malfunctions due to a power outage), the missing record(s) will not be considered a permit deviation provided the amount of data lost does not exceed 10% of the averaging periods in a reporting period or 10% of the total operating hours in a reporting period, if no averaging time is specified. Upon discovering that a required record is missing, the permittee must document the reason for the missing record. In addition, any missing record that can be recovered from other available information will not be considered a missing record. [340-212-0160, OAR 340-214-0110,and 340-218-0050(3)(b)]

 

107.  Recordkeeping requirements must commence on the date of permit issuance unless otherwise specified in the permit or an applicable requirement. [OAR 340-218-0050(3)(b)(C)]

 

108.  Unless otherwise specified, the permittee must retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings (or other original data) for continuous monitoring instrumentation, and copies of all reports required by the permit. All existing records required by the previous Air Contaminant Discharge Permit or Oregon Title V Operating Permit must also be retained for five (5) years from the date of the monitoring sample, measurement, report, or application. [OAR 340-218-0050(b)(B)]

 

Source Specific Recordkeeping Requirements

 

109.  The permittee shall maintain the following specific records of required monitoring information that include the following:

 

109.a.  Monthly and annual primary aluminum production;

109.b.  Monthly and annual secondary aluminum production;

109.c.  Monthly and annual amount of pre-processed aluminum used;

109.d.  Monthly and annual amount of fuels used by type;

109.e.  Daily and annual carbon consumption;

109.f.  Monthly and annual amount of carbon materials (coke and pitch) handled;

109.g.  Monthly and annual amount of dross shipped;

109.h.  Monthly and annual amount of painted scrap processed;

109.i.  Monthly pollutant emissions calculations;

109.j.  Complain log and investigation reports;

109.k.  Fugitive dust inspection and maintenance activities;

109.l.  Visible emissions observations;

109.m.  Daily inspection and maintenance procedures for the wet SOs scrubber, emissions A-1b.2, and the secondary roof scrubber system (emissions unit A-1a.1 through A-1a.5);

109.n.  Daily truck feeder schedules;

109.o.  Weekly inspection reports for the baghouse bags and the dry coke scrubber bags for emissions units A-2a, A-2b, a-4a.1, A-4a.2, and A-4b.1 through A-4b.6;

109.p.  Weekly inspection reports of the loading and unloading of the dross, coke, pitch, and aluminum fluoride;

109.q.  Monthly and annual number of paste leaks;

109.r.  Four-hour fluoride concentrations of the wet SO2 scrubber recycle stream;

109.s.  Changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes;

109.t.  Occurrence and length of down time for all pollution control devices;

109.u.  Wind speed and direction;

109.v.  Twelve-hour ambient concentrations of gaseous fluoride as hydrogen fluoride expressed in micrograms per cubic meter (mg/m3) of air and parts per billion (ppb);

109.w.  Particulate emissions expressed in grain per dry standard cubic foot (gr/dscf) and pounds per ton of aluminum produced (lb/TAP);

109.x.  Gaseous and total fluoride emissions expressed as fluoride ion in mg/m3 and lb/TAP;

109.y.  Sulfur dioxide emissions expressed in parts per million (ppm) and lb/TAP; and

109.z.  Information required by 40 CFR part 82, subpart B: Servicing of Motor Vehicle Air Conditioners.

 

NESHAP Recordkeeping Requirements

 

110.  General recordkeeping requirements. [40 CFR §63.10(b)]

 

110.a.  The permittee must maintain files of all information (including all reports and notifications) required by 40 CFR part 63 recorded in a form suitable and readily available for expeditious inspection and review. The files shall be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2 years of data shall be retained on site. The remaining 3 years of data may be retained off site. Such files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. [40 CFR §63.850(e)(1)-(3) and §63.1516(a)]

110.b.  The permittee must maintain relevant records of: [40 CFR §63.10(b)(2)]

110.b.i.  The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment);

110.b.ii.  The occurrence and duration of each malfunction of the air pollution control equipment;

110.b.iii.  All maintenance performed on the air pollution control equipment;

110.b.iv.  Actions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution control equipment to its normal or usual manner of operation) when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan [see Condition 42];

110.b.v.  All information necessary to demonstrate conformance with the affected source's startup, shutdown, and malfunction plan [see Condition 42] when all actions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution control equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. (The information needed to demonstrate conformance with the startup, shutdown, and malfunction plan may be recorded using a "checklist," or some other effective form of recordkeeping, in order to minimize the recordkeeping burden for conforming events.);

110.b.vi.  Each period during which a CMS is malfunctioning or inoperative (including out-of-control periods);

110.b.vii.  All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to, 15-minute averages of CMS data, raw performance testing measurements, and raw performance evaluation measurements that support data that the source is required to report);

110.b.viii.  All results of performance tests, CMS performance evaluations, and opacity and visible emission observations;

110.b.ix.  All measurements as may be necessary to determine the conditions of performance tests and performance evaluations;

110.b.x.  All CMS calibration checks;

110.b.xi.  All adjustments and maintenance performed on CMS;

110.b.xii.  Any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting requirements under this part, if the source has been granted a waiver under Condition 134;

110.b.xiii.  All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test, if the source has been granted such permission under 40 CFR §63.8(f)(6); and

110.b.xiv.  All documentation supporting initial notifications and notifications of compliance status under Conditions 121 and 124.

110.c.  Recordkeeping requirement for applicability determinations. If the permittee determines that his or her stationary source that emits (or has the potential to emit, without considering controls) one or more hazardous air pollutants is not subject to a relevant standard or other requirement established under 40 CFR part 63, the permittee shall keep a record of the applicability determination on site at the source for a period of 5 years after the determination, or until the source changes its operations to become an affected source, whichever comes first. The record of the applicability determination shall include an analysis (or other information) that demonstrates why the permittee believes the source is unaffected (e.g., because the source is an area source). The analysis (or other information) shall be sufficiently detailed to allow the Administrator to make a finding about the source's applicability status with regard to the relevant standard or other requirement. If relevant, the analysis shall be performed in accordance with requirements established in subparts of 40 CFR part 63 for this purpose for particular categories of stationary sources. If relevant, the analysis should be performed in accordance with EPA guidance materials published to assist sources in making applicability determinations under section 112 of the CAA, if any. [40 CFR §63.10(b)(3)]

 

111.  Additional recordkeeping requirements for sources with continuous monitoring systems. If a continuous monitoring system (CMS) is required by a relevant standard, the permittee must maintain the following records for each affected source in addition to complying with the requirements specified in conditions 110.a and 110.b: [40 CFR §63.10(c)]

111.a.  All required CMS measurements (including monitoring data recorded during unavoidable CMS breakdowns and out-of-control periods);

111.b.  The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks;

111.c.  The date and time identifying each period during which the CMS was out of control, as defined in 40 CFR §63.8(c)(7), if applicable;

111.d.  The specific identification (i.e., the date and time of commencement and completion) of each period of excess emissions and parameter monitoring exceedances, as defined in the relevant standard(s), that occurs during startups, shutdowns, and malfunctions of the affected source;

111.e.  The specific identification (i.e., the date and time of commencement and completion) of each time period of excess emissions and parameter monitoring exceedances, as defined in the relevant standard(s), that occurs during periods other than startups, shutdowns, and malfunctions of the affected source;

111.f.  The nature and cause of any malfunction (if known);

111.g.  The corrective action taken or preventive measures adopted;

111.h.  The nature of the repairs or adjustments to the CMS that was inoperative or out of control;

111.i.  The total process operating time during the reporting period; and

111.j.  All procedures that are part of a quality control program developed and implemented for CMS under 40 CFR §63.8(d), if applicable;

111.k.  In order to satisfy the requirements of Conditions 111.f through 111.h and to avoid duplicative recordkeeping efforts, the permittee may use the affected source's startup, shutdown, and malfunction plan or records kept to satisfy the recordkeeping requirements of the startup, shutdown, and malfunction plan specified in Condition 42, provided that such plan and records adequately address the requirements of Conditions 111.f through 111.h.

 

Subpart LL Recordkeeping Requirements

 

112.  In addition to the general records required by Conditions 110 and 111, the permittee shall maintain records of the following information: [40 CFR §63.850(e)(4)]

 

112.a.  Daily production rate of aluminum;

112.b.  A copy of the startup, shutdown, and malfunction plan;

112.c.  Records of design information for paste production plant capture systems;

112.d.  Records of design information for an alternative emission control device for a paste production plant;

112.e.  Records supporting the monitoring of similar potlines demonstrating that the performance of similar potlines is the same as or better than that of potlines sampled by manual methods;

112.f.  Records supporting a request for reduced sampling of potlines;

112.g.  The current implementation plan for emission averaging and any subsequent amendments;

112.h.  Records, such as a checklist or the equivalent, demonstrating that the daily inspection of a potline with wet roof scrubbers for secondary emission control has been performed as required in Condition 78.d.ii, including the results of each inspection;

112.i.  Records, such as a checklist or the equivalent, demonstrating that the daily visible inspection of the exhaust stack for each control device have been performed as required in Condition 80, including the results of each inspection;

112.j.  Records documenting the corrective actions taken when the limits(s) for an operating parameter established under Condition 79 were exceeded, when visible emissions indicating abnormal operation were observed from a control device stack during a daily inspection required by Condition 80, or when a problem was detected during the daily inspection of a wet roof scrubber for potline secondary control required in Condition 78.d.ii;

112.k.  Records documenting any POM data that are invalidated due to the installation and startup of a cathode; and

112.l.  Records documenting the portion of TF that is measured as particulate matter and the portion that is measured as gaseous when the particulate and gaseous fractions are quantified separately using an approved test method.

 

Subpart RRR Recordkeeping Requirements

 

113.  In addition to the general records required by Condition 110, the permittee must maintain records of: [40 CFR §63.1517(b)]

 

113.a.  For each affected source and emissions unit with emissions controlled by a fabric filter, any of the following that are applicable:

113.a.i.  If a bag leak detection system is used, the number of total operating hours for the affected source or emissions unit during each 6-month reporting period, records of each alarm, the time of the alarm, the time corrective action was initiated and completed, and a brief description of the cause of the alarm and the corrective action(s) taken.

113.a.ii.  If a continuous opacity monitoring system is used, records of opacity measurement data, including records where the average opacity of any 6-minute period exceeds 5 percent, with a brief explanation of the cause of the emissions, the time the emissions occurred, the time corrective action was initiated and completed, and the corrective action taken.

113.a.iii.  If an aluminum scrap shredder is subject to visible emission observation requirements, records of all Method 9 observations, including records of any visible emissions during a 30-minute daily test, with a brief explanation of the cause of the emissions, the time the emissions occurred, the time corrective action was initiated and completed, and the corrective action taken.

113.b.  For each group 1 furnace (with or without add-on air pollution control devices) or in-line fluxer, records of 15-minute block average weights of gaseous or liquid reactive flux injection, total reactive flux injection rate and calculations (including records of the identity, composition, and weight of each addition of gaseous, liquid, or solid reactive flux), including records of any period the rate exceeds the compliant operating parameter value and corrective action taken.

113.c.  For each continuous monitoring system, records required by Condition 111.

113.d.  For each affected source and emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge, records of feed/charge (or throughput) weights for each operating cycle or time period used in the performance test.

113.e.  Approved site-specific monitoring plan for a group 1 furnace without add-on air pollution control devices with records documenting conformance with the plan.

113.f.  Records of all charge materials for each group 1 melting/holding furnaces without air pollution control devices processing only clean charge.

113.g.  Operating logs for each in-line fluxer using no reactive flux materials documenting each flux gas, agent, or material used during each operating cycle.

113.h.  Records of all charge materials and fluxing materials or agents for a group 2 furnace.

113.i.  Records of monthly inspections for proper unit labeling for each affected source and emission unit subject to labeling requirements.

113.j.  Records of annual inspections of emissions capture/collection and closed vent systems.

113.k.  Records for any approved alternative monitoring or test procedure.

113.l.  Current copy of all required plans, including any revisions, with records documenting conformance with the applicable plan, including:

113.l.i.  Startup, shutdown, and malfunction plan;

113.l.ii.  OM&M plan; and

113.l.iii.  Site-specific secondary aluminum processing unit emission plan, if applicable.

113.m.  For each secondary aluminum processing unit, records of total charge weight, or if the permittee chooses to comply on the basis of aluminum production, total aluminum production for each 24-hour period and calculations of 3-day, 24-hour rolling average emissions.

 

 

REPORTING REQUIREMENTS

 

The reporting conditions in this section are based on OAR 340-218-0050(3)(c); unless otherwise specified.

 

General Reporting Requirements

 

114.  Excess Emissions Reporting: The permittee must report all excess emissions in accordance with OAR 340-214-0300 through 340-214-0360. In summary, the permittee must immediately (i.e., as soon as possible but in no case more than one hour after a source knew or should have known of an excess emission period) notify the Department by telephone or in person of any excess emission, other than pre-approved startup, shutdown, or scheduled maintenance. Notification must, to the extent reasonably ascertainable at the time of notification, include the source name, nature of the emissions problem, name of the person making the report, name and telephone number of the contact person for further information, date and time of the onset of the upset condition, whether or not the incident was planned, the cause of the excess emission (e.g., startup, shutdown, maintenance, breakdown, or other), equipment involved in the upset, estimated type and quantity of excess emissions, estimated time of return to normal operations, efforts made to minimize emissions, and a description of remedial actions to be taken. Follow-up reporting must be made in accordance with Department direction and OAR 340-214-0330(2) and 340-214-0340.

 

114.a.  In the event of any excess emissions which are of a nature that could endanger public health and occur during non-business hours, weekends, or holidays, the permittee must immediately notify the Department by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.

114.b.  If startups, shutdowns, or scheduled maintenance may result in excess emissions, the permittee must submit startup, shutdown, or scheduled maintenance procedures used to minimize excess emissions to the Department for prior authorization, as required in OAR 340-214-0310 and 340-214-0320. New or modified procedures must be received by the Department in writing at least 72 hours prior to the first occurrence of the excess emission event. The permittee must abide by the approved procedures and have a copy available at all times.

114.c.  The permittee must notify the Department of planned startup/shutdown or scheduled maintenance events only if required by permit condition or if the source is located in a nonattainment area for a pollutant which may be emitted in excess of applicable standards.

114.d.  The permittee must maintain and submit to the Department a log of planned and unplanned excess emissions, on Department approved forms, in accordance with OAR 340-214-0340.

 

115.  Permit Deviations Reporting: The permittee must promptly report deviations from permit requirements that do not cause excess emissions, including those attributable to upset conditions, as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. “Prompt” means within seven (7) days of the deviation. Deviations that cause excess emissions, as specified in OAR 340-214-0300 through 340-214-0360 must be reported in accordance with OAR 340-214-0340. [OAR 340-218-0050(3)(c)(B)]

 

116.  All required reports must be certified by a responsible official consistent with OAR 340-218-0040(5); [OAR 340-218-0050(3)(c)(D)]

 

117.  Reporting requirements must commence on the date of permit issuance unless otherwise specified in the permit. [OAR 340-218-0050(3)(c)(E)]

 

Addresses of regulatory agencies are the following, unless otherwise instructed:

 

DEQ – Eastern Region

2146 NE 4th Street, #104

Bend, OR 97701

(541) 388-6146

DEQ – Air Quality Division

811 SW Sixth Avenue

Portland, OR 97204

(503) 229-5359

Air Operating Permits

US Environmental Protection Agency

Mail Stop OAQ-108

1200 Sixth Avenue

Seattle, WA 98101

 

Monthly Reports:

 

118.  The permittee shall report the following information within 30 days of the end of each calendar quarter to the Department Regional Office:

 

118.a.  Twelve-hour concentrations of fluoride as hydrogen fluoride in ambient air expressed in mg/m3 of air and ppb;

118.b.  Particulate matter emissions expressed in gr/dscf and lbs/TAP (PM data shall be reported as total PM and the percentage of fluoride ion);

118.c.  Gaseous fluoride emissions expressed as fluoride ion in mg/m3 and lbs/TAP;

118.d.  Sulfur dioxide emissions expressed in ppm and lbs/TAP;

118.e.  Changes to collection efficiency of any portion of the collection or control system that resulted from equipment or process changes; and

118.f.  Records of paste leaks and any corrective action taken.

 

Semi-annual and Annual Reports

 

119.  The permittee shall submit three (3) copies of reports of any required monitoring at least every 6 months, completed on forms approved by the Department. Six month periods are January 1 to June 30, and July 1 to December 31. One copy of the report shall be submitted to the Air Quality Division, one copy to the regional office, and one copy to the EPA. All instances of deviations from permit requirements shall be clearly identified in such reports: [OAR 340-218-0050(3)(c)(A) and 340-218-0080(6)(d)]

 

119.a.  The first semi-annual report shall be due on July 30 and shall include: [OAR 340-218-0080]

119.a.i.  The semi-annual compliance certification;

119.a.ii.  40 CFR part 63, subpart LL excess emissions report in accordance with Condition 130; and

119.a.iii.  40 CFR part 63, subpart RRR excess emissions report in accordance with Condition 136.

119.b.  The annual report shall be due on February 15 and shall consist of the following:

119.b.i.  The emission fee report; [OAR 340-220-0100]

119.b.ii.  The excess emissions upset log; [OAR 340-214-0340]

119.b.iii.  The second semi-annual compliance certification as required by OAR 340-218-0080 and 40 CFR part 63 subparts LL and RRR;

119.b.iv.  The certification as required in 40 CFR part 82, subpart B; Servicing of Motor Vehicle Air Conditioners every two years;

119.b.v.  The following information for the calendar year:

119.b.v.A.  Amount of primary aluminum produced;

119.b.v.B.  Amount of secondary aluminum produced;

119.b.v.C.  Amount of pre-processed aluminum used;

119.b.v.D.  Amount of aluminum fluxed;

119.b.v.E.  Amount of fuels used by type;

119.b.v.F.  Amount of carbon consumed;

119.b.v.G.  Amount of alumina used;

119.b.v.H.  Amount of pitch used;

119.b.v.I.  Amount of dross handled;

119.b.v.J.  Amount of painted scrap used;

119.b.v.K.  Amount of chips and shaving with cutting fluid residue used; and

119.b.v.L.  Hours of operation;

119.b.v.M.  Annual pollutant emissions calculated each month.

 

120.  The semi-annual compliance certification must include the following (provided that the identification of applicable information may cross-reference the permit or previous reports, as applicable): [OAR 340-218-0080(6)(c)]

 

120.a.  The identification of each term or condition of the permit that is the basis of the certification;

120.b.  The identification of the method(s) or other means used by the owner or operator for determining the compliance status with each term and condition during the certification period, and whether such methods or other means provide continuous or intermittent data. Such methods and other means must include, at a minimum, the methods and means required under OAR 340-218-0050(3). Note: Certification of compliance with the monitoring conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance with new applicable requirements that are incorporated by reference. When certifying compliance with new applicable requirements that are incorporated by reference, the permittee must provide the information required by this condition. If necessary, the owner or operator also must identify any other material information that must be included in the certification to comply with section 113(c)(2) of the FCAA, which prohibits knowingly making a false certification or omitting material information;

120.c.  The status of compliance with terms and conditions of the permit for the period covered by the certification, based on the method or means designated in Conditions 120.b. The certification must identify each deviation and take it into account in the compliance certification. The certification must also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance, as defined under OAR 340-200-0010, occurred; and

120.d.  Such other facts as the Department may require to determine the compliance status of the source.

120.e.  Notwithstanding any other provision contained in any applicable requirement, the owner or operator may use monitoring as required under OAR 340-218-0050(3) and incorporated into the permit, in addition to any specified compliance methods, for the purpose of submitting compliance certifications. [OAR 340-218-0080(6)(e)]

 

NESHAP Notification and Reporting Requirements

 

General NESHAP Notification Requirements

 

121.  Initial notifications. For new or reconstructed sources, the permittee must submit an initial notification in accordance with 40 CFR §63.9(b).

 

122.  Request for extension of compliance. If the permittee cannot comply with a relevant standard by the applicable compliance date for that source, or if the permittee has installed BACT or technology to meet LAER consistent with 40 CFR §63.6(i)(5), he/she may submit to the Administrator (or the Department) a request for an extension of compliance as specified in 40 CFR §63.6(i)(4) through 40 CFR §63.6(i)(6). [40 CFR §63.9(c)]

 

123.  Notification that source is subject to special compliance requirements. If the permittee is subject to special compliance requirements as specified in 40 CFR §63.6(b)(3) and §63.6(b)(4), the permittee shall notify the Administrator of his/her compliance obligations not later than the notification dates established in Condition 121 for new sources that are not subject to the special provisions. [40 CFR §63.9(d)]

 

124.  Notification of compliance status. For new or reconstructed sources, the permittee shall submit a notice of compliance status in accordance with 40 CFR §63.9(h).

 

125.  The permittee may request and the Department may approve adjustments to time periods or postmark deadlines for submittal and review of required communications in accordance with 40 CFR §63.9(i).

 

126.  Change in information already provided. Unless otherwise specified by a permit condition or applicable requirement, any change in the information already provided under conditions of this permit shall be provided to the Department in writing within 15 calendar days after the change. [40 CFR §63.10(j)]

 

Subpart LL Notifications.

 

127.  The permittee shall submit the following notifications: [40 CFR §63.850(a)]

 

127.a.  One-time notification for each affected source of the intent to use an HF continuous emission monitor; and [40 CFR §63.850(a)(7)]

127.b.  Notification of compliance approach. The permittee shall develop and submit to the applicable regulatory authority, if requested, an engineering plan that describes the techniques that will be used to address the capture efficiency of the reduction cells for gaseous hazardous air pollutants in compliance with the emission limits in Conditions 18, 19, and 20. [40 CFR §63.850(a)(8)]

 

Subpart RRR Notifications.

 

128.  The permittee shall submit the notifications required by Conditions 121 through 126. [40 CFR §63.1515]

 

General NESHAP Reporting Requirements

 

129.  Performance test reports. Except as provided in Condition 130, the permittee shall submit a summary of all subsequent performance tests to the applicable regulatory authority on an annual basis. [40 CFR §63.850(b)]

 

130.  Excess emissions. As required by 40 CFR §63.10(e)(3), the permittee shall submit a report (or a summary report) if measured emissions are in excess of the applicable standard. The report shall contain the information specified in 40 CFR §63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required as a result of excess emissions. [40 CFR §63.850(d)]

 

131.  Notwithstanding the requirements in this Condition or Condition 133, the owner or operator of an affected source subject to reporting requirements under 40 CFR part 63 shall submit reports to the Administrator in accordance with the reporting requirements in the relevant standard(s). [40 CFR §63.10(d)]

 

132.  Startup, shutdown, and malfunction reports. [40 CFR §63.10(d)(5)]

 

132.a.  Periodic startup, shutdown, and malfunction reports. If actions taken by the permittee during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan (see Condition 42), the permittee shall state such information in a startup, shutdown, and malfunction report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the permittee or other responsible official who is certifying its accuracy, that shall be submitted to the Administrator semiannually (or on a more frequent basis if specified otherwise in a relevant standard or as established otherwise by the permitting authority in the source's title V permit). The startup, shutdown, and malfunction report shall be delivered or postmarked by the 30th day following the end of each calendar half (or other calendar reporting period, as appropriate). If the permittee is required to submit excess emissions and continuous monitoring system performance (or other periodic) reports under 40 CFR part 63, the startup, shutdown, and malfunction reports required under this condition may be submitted simultaneously with the excess emissions and continuous monitoring system performance (or other periodic) reports. If startup, shutdown, and malfunction reports are submitted with excess emissions and continuous monitoring system performance (or other periodic) reports, and the permittee receives approval to reduce the frequency of reporting for the latter under Condition 133, the frequency of reporting for the startup, shutdown, and malfunction reports also may be reduced if the Administrator does not object to the intended change. The procedures to implement the allowanc

e in the preceding sentence shall be the same as the procedures specified in Condition 133.

132.b.  Immediate startup, shutdown, and malfunction reports. Notwithstanding the allowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports under Condition 132.a, any time an action taken by the permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, the permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required under this Condition shall consist of a telephone call (or facsimile [FAX] transmission) to the Administrator within 2 working days after commencing actions inconsistent with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working days after the end of the event, that contains the name, title, and signature of the permittee or other responsible official who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. Notwithstanding the requirements of the previous sentence, after the effective date of an approved permit program in the state in which an affected source is located, the permittee may make alternative reporting arrangements, in advance, with the permitting authority in that State. Procedures governing the arrangement of alternative reporting requirements under this Condition are specified in Condition 125.

 

133.  Additional reporting requirements for continuous monitoring systems. If continuous monitoring systems are required by 40 CFR part 63 subparts LL or RRR, the permittee must comply with the additional semi-annual or quarterly reporting requirements contained in 40 CFR §63.10(e).

 

134.  Waiver of recordkeeping or reporting requirements. The permittee may request a waiver of recordkeeping or reporting requirement in accordance with 40 CFR §63.10(f). Until a waiver of a recordkeeping or reporting requirement has been granted by the Administrator, the permittee of an affected source remains subject to the requirements of this permit. [40 CFR §63.10(f)]

 

SUBPART LL and RRR NESHAP SPECIFIC REPORTING REQUIREMENTS

 

135.  The permittee must develop and implement a written plan as described in Condition 42 that contains specific procedures to be followed for operating and maintaining the source during periods of startup, shutdown, and malfunction, and a program of corrective action for malfunctioning process and air pollution control equipment used to comply with the standard. The permittee must also keep records of each event as required by Condition 110 and record and report if an action taken during a startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in Condition 42. In addition to the information required in 42, the plan must include: [40 CFR §63.850(c) and §63.1516(a)]

 

135.a.  Procedures to determine and record the cause of the malfunction and the time the malfunction began and ended; and

135.b.  Corrective actions to be taken in the event of a malfunction of a process or control device, including procedures for recording the actions taken to correct the malfunction or minimize emissions.

 

136.  Continuous monitoring reports. As required by Condition 133, the permittee must submit semiannual (or quarterly) reports within 60 days after the end of each 6-month period. Each report must contain the information specified in Condition 111. When no deviations of parameters have occurred, the permittee must submit a report stating that no excess emissions occurred during the reporting period. [40 CFR §63.850(d) and §63.1516(b)]

 

136.a.  A report must be submitted if any of the following conditions occur during a 6-month reporting period: [40 CFR §63.1515(b)(1)]

136.a.i.  The corrective action specified in the OM&M plan for visible emissions from an aluminum scrap shredder was not initiated within 1 hour.

136.a.ii.  An excursion of a compliant process or operating parameter value or range (e.g., total reactive chlorine flux injection rate, fabric filter inlet temperature, definition of acceptable scrap, or other approved operating parameter).

136.a.iii.  An action taken during a startup, shutdown, or malfunction was not consistent with the procedures in the plan as described in Condition 42.

136.a.iv.  An affected source (including an emission unit in a secondary aluminum processing unit) was not operated according to the requirements of this permit.

136.a.v.  A deviation for the 3-day, 24-hour rolling average emission limit for a secondary aluminum processing unit.

136.b.  Each report must include each of these certifications, as applicable: [40 CFR §63.1516(b)(2)]

136.b.i.  For each sidewell group 1 furnace with add-on air pollution control devices: “Each furnace was operated such that the level of molten metal remained above the top of the passage between the sidewell and hearth during reactive fluxing, and reactive flux, except for cover flux, was added only to the sidewell or to a furnace hearth equipped with an add-on air pollution control device for PM, HCl, and D/F emissions during this reporting period.”

136.b.ii.  For each group 1 melting/holding furnace without add-on air pollution control devices and using pollution prevention measure that processes only clean charge material: “Each group 1 furnace without add-on air pollution control devices subject to emission limits in Condition 35.b processed only clean charge during this reporting period.”

136.b.iii.  For each group 2 furnace: “Only clean charge materials were processed in any group 2 furnace during this reporting period, and no fluxing was performed or all fluxing performed was conducted using only nonreactive, non-HAP-containing/non-HAP-generating fluxing gases or agents, except for cover fluxes, during this reporting period.”

136.b.iv.  For each in-line fluxer using no reactive flux: “Only nonreactive, non-HAP-containing/non-HAP-generating flux gases, agents, or materials were used at any time during this reporting period.”

136.c.  The permittee must submit the results of any performance test conducted during the reporting period, including one complete report documenting test methods, and procedures, process operation, and monitoring parameter ranges or values for each test method used for a particular type of emission point tested. [40 CFR §63.1516(b)(3)]

 

137.  For the purpose of semi-annual certifications of compliance required by Condition 119, the permittee must certify continuing compliance based upon, but not limited to, the following conditions: [40 CFR §63.1516(c)]

 

137.a.  Any period of excess emissions based on continuous monitoring, as defined in Condition 130 that occurred during the reporting period; and

137.b.  All monitoring, recordkeeping, and reporting requirements were met during the year.

 

 

NON-APPLICABLE REQUIREMENTS

 

138.  State and Federal air quality requirements (e.g., rules and regulations) currently determined not applicable to the permittee are listed below along with the reason for the non-applicability: [OAR 340-218-0110]

 

 

Applicable Requirement

Reason Code

OAR Chapter 340:

Division 202

 

all rules

i

Division 208

 

0520

c

0530

c

0540

c

0550

c

0560

c

0570

c

0580

c

0600

c

0610

c

0620

c

0630

c

0640

c

0660 and 0670

c

Division 210:

 

0100 through 0120

b

0200 through 0220

b

Division 214:

 

0130(2) and (3)

h

0210 and 0220

b

Division 218:

 

0050(4)

b

0050(8)

h

0090

b

0100

b

Division 222

 

0050

h

Division 226:

 

0310 and 0320

e

0400

h

Division 228:

 

0100 through 0130

f

0200

e

0210

e

0300

b

Division 230:

 

0100 through 0150

e

0200 through 0230

e

0310 through 0360

e

0410

e

Division 232:

 

0040 through 0240

c

Division 234:

 

0110 through 0140

e

0210 through 0270

b

0310 through 0360

b

0410 through 0430

b

0510

b

0520

b

0530

b

Division 236:

 

0220 and 0230

b

0310 through 0330

b

0410 through 0440

b

0500

b

Division 238:

 

0060

e

0070

e

0080

e

0100

e

Division 240:

 

0110 through 0440

c

Division 242:

 

0010 through 0790

c

Division 244:

 

0110 through 0180

h

0200

b

0230

b

Division 256:

 

0130

b

0200 through 0470

b

Division 258:

b

0120 through 0310

b

0400

b

40 CFR

part 55

b

part 57

b

part 60, except subparts A, and appendixes

b

part 61, except subpart A, M, and appendices

b

part 63, except subpart A, subpart LL, subpart RRR appendices; unless otherwise noted below or in attachment B

b

§63.6(c)(1)

k

§63.6(c)(5)

k, n

§63.6(g)

n

§63.6(h)

k

§63.6(i)

k, i

§63.8(c)(4)-(8)

k

§63.8(d)

k

§63.8(e)

k

§63.8(f)(1)-(4)

n

§63.8(2)

n

§63.9(e)

k

§63.9(f)

k

§63.9(g)

k

§63.10(d)(2)

k

§63.10(d)(3)

k

§63.10(e)(2)

k

§63.11

k, n

§63.843(a)(1)(i)-(iv) and (vi)-(vii)

b

§63.843(a)(2)(i ) and (iii)

b

§63.843(b)(3)

h

§63.843(c)

e

§63.844

b

§63.845

l

§63.846(c)

e

§63.846(d)(3)

i

§63.847(a)(2)(-(3)

h

§63.847(a)(4)

b

§63.847(d)(3)

h

62.847(d)(4)

e

§63.847(e)(3) and (4)

e

§63.847(g)

b

§63.848(c)

e

§63.848(d)

h

§63.848(e)(3)

l

§63.848(f)(4)

m

§63.849(a)(5)

h

§63.849(c) and (d)

h

§63.850(a)(1)

b

§63.850(e)(4)(ii)

e

§63.850(e)(4)(viii)

h

§63.850(e)(4)(xii)

h

part 72 through 76

b

part77

b

part78

b

part 82, except subpart F

b

part 85 through 89

b

 

 

Reason code definitions:

 

a  This pollutant is not emitted by the facility.

b  The facility is not in this source category.

c  The facility is not in a special control/nonattainment area.

d  The facility is not in this county.

e  The facility does not have this emissions unit.

f  The facility does not use this fuel type.

g  The rule does not apply because no changes have been made at the facility that would trigger these procedural requirements.

h  This method/procedure is not used by the facility.

i  This rule applies only to DEQ and regional authorities.

j.  There are no emissions units with add-on control devices or the pre-controlled potential emissions are is less than 100 tons per year or the emissions units with add-on control devices and pre-controlled emissions greater than 100 tons per year are subject to emissions standards promulgated after November of 1990.

k.  40 CFR, part 63, subpart LL supercedes the general requirements of subpart A. [40 CFR §63.1(a)(13)].

l.  Not subject to NSPS.

m.  Doesn’t use this type of control device.

n.  40 CR, part 63, subpart RRR supercedes the general requirements of subpart B. [40 CFR §63.1(a)(13)].

 

 

GENERAL CONDITIONS

 

G1.  General Provision

 

Terms not otherwise defined in this permit have the meaning assigned to such terms in the referenced regulation.

 

G2.  Reference materials

 

Where referenced in this permit, the versions of the following materials are effective as of the dates noted unless otherwise specified in this permit:

 

a.  Source Sampling Manual; January 23, 1992 - State Implementation Plan Volume 3, Appendix A4;

b.  Continuous Monitoring Manual; January 23, 1992 - State Implementation Plan Volume 3, Appendix A6; and

c.  All state and federal regulations as in effect on the date of issuance of this permit.

 

G3.  Compliance [OAR 340-218-0040(3)(n)(C), 340-218-0050(6), and 340-218-0080(4)]

 

a.  The permittee must comply with all conditions of this permit. Any permit condition noncompliance constitutes a violation of the Federal Clean Air Act and/or state rules and is grounds for enforcement action; for permit termination, revocation and re-issuance, or modification; or for denial of a permit renewal application. Any noncompliance with a permit condition specifically designated as enforceable only by the state constitutes a violation of state rules only and is grounds for enforcement action; for permit termination, revocation and re-issuance, or modification; or for denial of a permit renewal application.

b.  Any schedule of compliance for applicable requirements with which the source is not in compliance at the time of permit issuance is supplemental to, and does not sanction noncompliance with the applicable requirements on which it is based.

c.  For applicable requirements that will become effective during the permit term, the source must meet such requirements on a timely basis unless a more detailed schedule is expressly required by the applicable requirement.

 

G4.  Masking Emissions:

 

The permittee may not install or use any device or other means designed to mask the emission of an air contaminant that causes or is likely to cause detriment to health, safety, or welfare of any person or otherwise violate any other regulation or requirement. [OAR 340-208-0400] This condition is enforceable only by the State.

 

G5.  Credible Evidence:

 

Notwithstanding any other provisions contained in any applicable requirement, any credible evidence may be used for the purpose of establishing whether a person has violated or is in violation of any such applicable requirements. [OAR 340-214-0120]

 

G6.  Certification [OAR 340-214-0110, 340-218-0040(5), 340-218-0050(3)(c)(D), and 340-218-0080(2)]

 

Any document submitted to the Department or EPA pursuant to this permit must contain certification by a responsible official of truth, accuracy and completeness. All certifications must state that based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and, complete. The permittee must promptly, upon discovery, report to the Department a material error or omission in these records, reports, plans, or other documents.

 

G7.  Open Burning [OAR Chapter 340, Division 264]

 

The permittee is prohibited from conducting open burning, except as may be allowed by OAR 340-264-0020 through 340-264-0200.

 

G8.  Asbestos [40 CFR Part 61, Subpart M (federally enforceable), OAR Chapter 340-248-0005 through 340-248-0180 (state-only enforceable) and 340-248-0205 through 340-248-0280]

 

The permittee must comply with OAR Chapter 340, Division 248, and 40 CFR Part 61, Subpart M when conducting any renovation or demolition activities at the facility.

 

G9.  Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-260-0040]

 

The permittee must comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, Recycling and Emissions Reduction.

 

G10.  Permit Shield [OAR 340-218-0110]

 

a.  Compliance with the conditions of the permit is deemed compliance with any applicable requirements as of the date of permit issuance provided that:

i.  Such applicable requirements are included and are specifically identified in the permit, or

ii.  The Department, in acting on the permit application or revision, determines in writing that other requirements specifically identified are not applicable to the source, and the permit includes the determination or a concise summary thereof.

b.  Nothing in this rule or in any federal operating permit alters or affects the following:

i.  The provisions of ORS 468.115 (enforcement in cases of emergency) and ORS 468.035 (function of department);

ii.  The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance;

iii.  The applicable requirements of the national acid rain program, consistent with section 408(a) of the FCAA; or

iv.  The ability of the Department to obtain information from a source pursuant to ORS 468.095 (investigatory authority, entry on premises, status of records).

c.  Sources are not shielded from applicable requirements that are enacted during the permit term, unless such applicable requirements are incorporated into the permit by administrative amendment, as provided in OAR 340-218-0150(1)(h), significant permit modification, or reopening for cause by the Department.

 

G11.  Inspection and Entry [OAR 340-218-0080(3)]

 

Upon presentation of credentials and other documents as may be required by law, the permittee must allow the Department of Environmental Quality, or an authorized representative (including an authorized contractor acting as a representative of the EPA Administrator), to perform the following:

 

a.  Enter upon the permittee's premises where an Oregon Title V Operating Permit program source is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit;

b.  Have access to and copy, at reasonable times, any records that must be kept under conditions of the permit;

c.  Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d.  As authorized by the FCAA or state rules, sample or monitor, at reasonable times, substances or parameters, for the purposes of assuring compliance with the permit or applicable requirements.

 

G12.  Fee Payment [OAR 340-220-0010, and 340-220-0030 through 340-220-0190]

 

The permittee must pay an annual base fee and an annual emission fee for all regulated air pollutants except for carbon monoxide, any class I or class II substance subject to a standard promulgated under or established by Title VI of the Federal Clean Air Act, or any pollutant that is a regulated air pollutant solely because it is subject to a standard or regulation under section 112(r) of the Federal Clean Air Act. The permittee must submit payment to the Department of Environmental Quality, Business Office, 811 SW 6th Avenue, Portland, OR 97204, within 30 days of the date the Department mails the fee invoice or August 1 of the year following the calendar year for which emission fees are paid, whichever is later. Disputes must be submitted in writing to the Department of Environmental Quality. Payment must be made regardless of the dispute. User-based fees will be charged for specific activities (e.g., computer modeling review, ambient monitoring review, etc.) requested by the permittee.

 

G13.  Off-Permit Changes to the Source [OAR 340-218-0140(2)]

 

a.  The permittee must monitor for, and record, any off-permit change to the source that:

i.  Is not addressed or prohibited by the permit;

ii.  Is not a Title I modification;

iii.  Is not subject to any requirements under Title IV of the FCAA;

iv.  Meets all applicable requirements;

v.  Does not violate any existing permit term or condition; and

vi.  May result in emissions of regulated air pollutants subject to an applicable requirement but not otherwise regulated under this permit or may result in insignificant changes as defined in OAR 340-200-0020.

b.  A contemporaneous notification, if required under OAR 340-218-0140(2)(b), must be submitted to the Department and the EPA.

c.  The permittee must keep a record describing off-permit changes made at the facility that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from those off-permit changes.

d.  The permit shield of Condition G9 does not extend to off-permit changes.

 

G14.  Section 502(b)(10) Changes to the Source [OAR 340-218-0140(3)]

 

a.  The permittee must monitor for, and record, any section 502(b)(10) change to the source, which is defined as a change that would contravene an express permit term but would not:

i.  Violate an applicable requirement;

ii.  Contravene a federally enforceable permit term or condition that is a monitoring, recordkeeping, reporting, or compliance certification requirement; or

iii.  Be a Title I modification.

b.  A minimum 7-day advance notification must be submitted to the Department and the EPA in accordance with OAR 340-218-0140(3)(b).

c.  The permit shield of Condition G9 does not extend to section 502(b)(10) changes.

 

G15.  Administrative Amendment [OAR 340-218-0150]

 

Administrative amendments to this permit must be requested and granted in accordance with OAR 340-218-0150. The permittee must promptly submit an application for the following types of administrative amendments upon becoming aware of the need for one, but no later than 60 days of such event:

 

a.  Legal change of the registered name of the company with the Corporations Division of the State of Oregon, or

b.  Sale or exchange of the activity or facility.

 

G16.  Minor Permit Modification [OAR 340-218-0170]

 

The permittee must submit an application for a minor permit modification in accordance with OAR 340-218-0170.

 

G17.  Significant Permit Modification [OAR 340-218-0180]

 

The permittee must submit an application for a significant permit modification in accordance with OAR 340-218-0180

 

G18.  Staying Permit Conditions [OAR 340-218-0050(6)(c)]

 

Notwithstanding Conditions G16 and G17, the filing of a request by the permittee for a permit modification, revocation and re-issuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

 

G19.  Construction/Operation Modification [OAR 340-218-0190]

 

The permittee must obtain approval from the Department prior to construction or modification of any stationary source or air pollution control equipment in accordance with OAR 340-210-0200 through OAR 340-210-0250.

 

G20.  New Source Review Modification [OAR 340-224-0010]

 

The permittee may not begin construction of a major source or a major modification of any stationary source without having received an air contaminant discharge permit (ACDP) from the Department and having satisfied the requirements of OAR 340, Division 224.

 

G21.  Need to Halt or Reduce Activity Not a Defense [OAR 340-218-0050(6)(b)]

 

The need to halt or reduce activity will not be a defense. It will not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

 

G22.  Duty to Provide Information [OAR 340-218-0050(6)(e) and OAR 340-214-0110]

 

The permittee must furnish to the Department, within a reasonable time, any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee must also furnish to the Department copies of records required to be retained by the permit or, for information claimed to be confidential, the permittee may furnish such records to the Department along with a claim of confidentiality.

 

G23.  Reopening for Cause [OAR 340-218-0050(6)(c) and 340-218-0200]

 

a.  The permit may be modified, revoked, reopened and reissued, or terminated for cause as determined by the Department.

b.  A permit must be reopened and revised under any of the circumstances listed in OAR 340-218-0200(1)(a).

c.  Proceedings to reopen and reissue a permit must follow the same procedures as apply to initial permit issuance and affect only those parts of the permit for which cause to reopen exists.

 

G24.  Severability Clause [OAR 340-218-0050(5)]

 

Upon any administrative or judicial challenge, all the emission limits, specific and general conditions, monitoring, recordkeeping, and reporting requirements of this permit, except those being challenged, remain valid and must be complied with.

 

G25.  Permit Renewal and Expiration [OAR 340-218-0040(1)(a)(D) and 340-218-0130]

 

a.  This permit expires at the end of its term, unless a timely and complete renewal application is submitted as described below. Permit expiration terminates the permittee's right to operate.

b.  Applications for renewal must be submitted at least 12 months before the expiration of this permit, unless the Department requests an earlier submittal. If more than 12 months is required to process a permit renewal application, the Department must provide no less than six (6) months for the owner or operator to prepare an application.

c.  Provided the permittee submits a timely and complete renewal application, this permit will remain in effect until final action has been taken on the renewal application to issue or deny the permit.

 

G26.  Permit Transference [OAR 340-218-0150(1)(d)]

 

The permit is not transferable to any person except as provided in OAR 340-218-0150(1)(d).

 

G27.  Property Rights [OAR 340-200-0020 and 340-218-0050(6)(d)]

 

The permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations, except as provided in OAR 340-218-0110.

 

G28.  Permit Availability [OAR 340-200-0020 and 340-218-0120(2)]

 

The permittee must have available at the facility at all times a copy of the Oregon Title V Operating Permit and must provide a copy of the permit to the Department or an authorized representative upon request.

 

 

 

ALL INQUIRIES SHOULD BE DIRECTED TO:

 

Eastern Region

2146 NE 4th Street, #104

Bend, OR 97701

(541) 388-6146

 

ATTACHMENT A: CROSS-REFERENCE FROM NEW RULE NUMBERS TO OLD RULE NUMBERS (EFFECTIVE MARCH 24, 2003)

 

 

New Rule Number

Old Rule Number

208-0110

021-0015

208-0200

021-0055

208-0210

021-0060

214-0300

028-1400

214-0310

028-1410

214-0320

028-1420

214-0330

028-1430

214-0340

028-1440

214-0350

028-1450

214-0360

028-1460

218-0010

028-2100

218-0020

028-2110

218-0040

028-2120

218-0050

028-2130

218-0060

028-2140

218-0070

028-2150

218-0080

028-2160

218-0090

028-2170

218-0100

028-2180

218-0110

028-2190

218-0120

028-2200

218-0130

028-2210

218-0140

028-2220

218-0150

028-2230

218-0160

028-2240

218-0170

028-2250

218-0180

028-2260

218-0190

028-2270

218-0200

028-2280

218-0210

028-2290

218-0220

028-2300

218-0230

028-2310

218-0240

028-2320

218-0250

028-1790

220-0010

028-2560

220-0030

028-2580

220-0040

028-2590

220-0050

028-2600

220-0060

028-2610

220-0070

028-2620

220-0080

028-2630

220-0090

028-2640

220-0100

028-2650

220-0110

028-2660

220-0120

028-2670

220-0130

028-2680

220-0140

028-2690

220-0150

028-2700

220-0160

028-2710

220-0170

028-2720

220-0180

028-2730

220-0190

028-2740

264-0010

023-0022

264-0020

023-0025

264-0030

023-0030

264-0040

023-0035

264-0050

023-0040

264-0060

023-0042

264-0070

023-0043

264-0080

023-0045

264-0100

023-0055

264-0110

023-0060

264-0120

023-0065

264-0130

023-0070

264-0140

023-0075

264-0150

023-0080

264-0160

023-0085

264-0170

023-0090

264-0180

023-0100

264-0190

023-0105

264-0200

023-0115

 

 

ATTACHMENT B: 40 CFR PART 63 GENERAL PROVISIONS INCORPORATED BY REFERENCE

 

Section/Sub-section

Description

Permit action

§63.1

part 63 applicability

Incorporated by reference, except §63.1(c)(2) is not applicable to subpart LL and EPA retains approval authority for subpart RRR.

§63.2

Definitions

Incorporated by reference, except §63.842 defines “reconstruction” for subpart LL and §63.842 and §63.1503 include additional definitions.

§63.3

Units and abbreviations

Incorporated by reference.

§63.4

Prohibited activities and circumvention

Incorporated by reference.

§63.5

Construction and reconstruction

Incorporated by reference.

§63.6

Compliance with standards and maintenance requirements

Incorporated by reference, except as specified for specific sub-sections below.

§63.6(c)(1)

Compliance dates for existing sources

Incorporated by reference, except §63.847(a)(1) and §63.1501 specify compliance dates for subparts LL and RRR, respectively.

§63.6(e)

Operation and maintenance requirements (SSM plans)

Incorporated by reference in addition to specific requirements included in permit conditions.

§63.6(g)

Use of an alternative non-opacity emission standard

Incorporated by reference for subpart LL. §63.6(g) is not applicable to subpart RRR.

§63.6(h)

Compliance with opacity and visible emissions standards

Incorporated by reference for subpart RRR. §63.6(h) is not applicable to subpart LL.

§63.7

Performance testing requirements

Incorporate by reference, except as specified for specific sub-sections below.

§63.7(a)

Applicability and performance test dates

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.7(b)

Notification of performance test

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.7(c)

Quality assurance program (site-specific test plan)

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.7(g)

Data analysis, recordkeeping, and reporting

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.8

Monitoring requirements

Incorporate by reference, except as specified for specific sub-sections below.

§63.8(b)

Conduct of monitoring

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.8(c)

Operation and maintenance of continuous monitoring systems

Incorporated by reference, except §63.8(c)(4) through (8) do not apply to subpart LL.

§63.8(d)

Quality control program

Incorporated by reference, except §63.8(d) does not apply to subpart LL.

ATTACHMENT B: 40 CFR PART 63 GENERAL PROVISIONS INCORPORATED BY REFERENCE

 

Section/Sub-Section

Description

Permit action

§63.8(e)

Performance evaluation of continuous monitoring systems

Incorporated by reference, except §63.8(e) does not apply to subpart LL.

§63.8(f)

Use of an alternative monitoring method

Incorporated by reference, except §63.8(f)(1)-(4) do not apply to subpart RRR.

§63.8(g)

Reduction of monitoring data

Incorporated by reference, except §63.8(2) is not applicable to subpart RRR.

§63.9

Notification requirements

Incorporated by reference, except as specified for specific sub-sections below.

§63.9(b)

Initial notifications

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.9(e)

Notification of performance test

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.9(f)

Notification of opacity and visible emission observations

Incorporated by reference in addition to specific requirements included as permit conditions. §63.9(f) does not apply to subpart LL.

§63.9(g)

Additional notification for sources with continuous monitoring systems

Incorporated by reference in addition to specific requirements included as permit conditions. §63.9(g) does not apply to subpart LL.

§63.9(h)

Notification of compliance status

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.10

Recordkeeping and reporting requirements

Incorporate by reference, except as specified for specific sub-sections below.

§63.10(b)

General recordkeeping requirements

Incorporated by reference in addition to specific requirements included as permit conditions.

§63.10(d)

General reporting requirements

Incorporated by reference in addition to specific requirements included as permit conditions. §63.10(d)(2-(3) are not applicable to subpart LL.

§63.10(e)

Additional reporting requirements for sources with continuous monitoring systems

Incorporated by reference in addition to specific requirements included as permit conditions. §63.10(e)(2) is not applicable to subpart LL.

§63.12

State authority and delegations

Incorporated by reference.

§63.13

Addresses of state air pollution control agencies and EPA regional offices

Incorporated by reference.

§63.14

Incorporation by reference

Incorporated by reference.

§63.15

Availability of information and confidentiality

Incorporated by reference.

 

 

ATTACHMENT C: PRIMARY ALUMINUM PRODUCTION NESHAP AND COMPLIANCE ASSURANCE MONITORING

 

Secondary roof system:

 

Indicator of Performance

Indicator Range

Representative

QA/QC

Monitoring Frequency

Data Collection Procedures

Data averaging

Visible emissions (MACT)

Evidence of abnormal operation (>20% opacity)

Visual inspection

Method 9 training

Once per operating day

Manually record readings

Any readings above 20% opacity

Air flow rate

Plant average >150,000 sdcfm and no fan <100,000 sdcfm

Emission tests

See “NWA Emissions Quality Assurance Plan”

Perform test every month on at least two fans per potline

Manually record readings

Defined by test method

Water flow rate (MACT)

4,000 – 13,000 gpm based on daily average reading from totalizer

Flow totalizer

See “NWA Emissions Quality Assurance Plan”

Take one reading per operating day

Manually record readings

Daily average

Inspection (MACT)

Proper operation

Inspection

See “NWA Emissions Quality Assurance Plan”

Daily inspection

Manually record results of inspection

Not applicable

 

ATTACHMENT C: PRIMARY ALUMINUM PRODUCTION NESHAP AND COMPLIANCE ASSURANCE MONITORING

 

Primary dry scrubber:

 

Indicator of Performance

Indicator Range

Representative

QA/QC

Monitoring Frequency

Data Collection Procedures

Data averaging

Alumina flow (MACT)

>6 tph for two lines or 3 tph for one line

TBD

TBD

TBD

TBD

TBD

Fluoride concentration in hopper discharge water

<500 ppm

Ion specific electrode in hopper discharge water

Check calibration against standard on a weekly basis

Check every four operating hours

Continuous strip chart recording

Instantaneous

Pressure drop

3-12 inches of water column

Pressure taps at inlet and outlet of baghouse

Manufacturer’s recommendations; check against water filled u-tube manometer once per year at 2, 5, and 8” of water column

Take one reading per day. If the reading is fluctuating by more than 1”, take three readings during a one minute period and record the average

Continuous strip chart recording

Instantaneous

Air flow rate (MACT)

Fan amps 425-530 during full operation with 2 fans or 300-530 during single line operation with 1 or 2 fans

Fan motor amp meters

Check amp meters once every calendar quarter

Check every four hours

Manually record readings

Instantaneous

 

ATTACHMENT C: PRIMARY ALUMINUM PRODUCTION NESHAP AND COMPLIANCE ASSURANCE MONITORING

 

Primary wet scrubber:

 

Indicator of Performance

Indicator Range

Representative

QA/QC

Monitoring Frequency

Data Collection Procedures

Data averaging

Visible emissions (MACT)

Evidence of abnormal operation (>20% opacity)

Visual inspection

Method 9 training

Once per operating day

Manually record readings

Any readings above 20% opacity

Air flow rate (MACT)

Fan amps 425-530 during full operation with 2 fans or 300-530 during single line operation with 1 or 2 fans

Fan motor amp meters

Check amp meters once every calendar quarter

Check every four hours

Manually record readings

Instantaneous

Water flow rate (MACT)

>2,088 gpm (78% of full scale)

Flow totalizer

See “NWA Emissions Quality Assurance Plan”

Take one reading per operating day

Manually record readings

Daily average

Water pH

>6.6

pH electrode in scrubber recycle water

See “NWA Emissions Quality Assurance Plan”

Check every four hours

Continuous strip chart recording

One hour

Water specific gravity

<1.090

Specific gravity probe in scrubber recycle water

See “NWA Emissions Quality Assurance Plan”

Check every four hours

Continuous strip chart recording

One hour

SO2 outlet concentration

<70 ppm, daily average

Emission tests

See “NWA Emissions Quality Assurance Plan”

Perform test once every six months

See “NWA Emissions Quality Assurance Plan”

See “NWA Emissions Quality Assurance Plan”

 

ATTACHMENT D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR

Summary of Operating Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

All affected sources and emissions units with an add-on air pollution control devices.

Emission capture and collection system.

Design and install in accordance with Industrial Ventilation: A Handbook of Recommended Practice; operate in accordance with OM&M plan.b

All affected sources and emissions units subject to production-based (lb/ton of feed) emission limits.a

Charge/feed weight or production weight.

Operate a device that records the weight of each charge; Operate in accordance with OM&M plan.b

Group 1 furnace, group 2 furnace, in-line fluxer and scrap dryer/delacquering kiln/decoating kiln.

Labeling

Identification, operating parameter ranges and operating requirements posted at affected sources and emission units; control device temperature and residence time requirements posted at scrap dryer/delacquering/decoating kiln.

Aluminum scrap shredder with fabric filter

 

Note: these requirements are not considered applicable to NWA because the shredder does not have an add-on control device.

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM; or

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

 

VE

Initiate corrective action within 1 hour of any observed VE and complete in accordance with OM&M plan.b

Thermal chip dryer with afterburner

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Afterburner operating temperature

Maintain average temperature for each 3-hour period at or above average operating temperature during the performance test.

 

Afterburner operation

Operate in accordance with OM&M plan.b

 

Feed material

Operate using only unpainted aluminum chips.

Attachment D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR

Summary of Operating Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Scrap dryer/delacquering kiln/decoating kiln with afterburner and lime-injected fabric filter

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Afterburner operating temperature

Maintain average temperature for each 3-hour period at or above average operating temperature during the performance test.

 

Afterburner operation

Operate in accordance with OM&M plan.b

 

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

 

Fabric filter inlet temperature

Maintain average fabric filter inlet temperature for each 3-hour period at or below average temperature during the performance test +14ºC (+25ºF)

 

Lime injection rate

Maintain free-flowing lime in the feed hopper or silo at all times for continuous injection systems; maintain feeder setting at level established during the performance test for continuous injections systems.

Sweat furnace with afterburner

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Afterburner operating temperature

If a performance test was conducted, maintain average temperature for each 3-hour period at or above average operating temperature during the performance test; if a performance test was not conducted, and afterburner meets specifications of §63.1505(f)(1), maintain average temperature for each 3-hour period at or above 1600ºF.

 

After burner operation

Operate in accordance with OM&M plan.b

Attachment D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR

Summary of Operating Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Dross-only furnace with fabric filter

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

 

Feed/charge material

Operate using only dross as the feed materials.

Rotary dross coller

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

In-line fluxer with lime-injected fabric filter (including those that are part of a secondary aluminum processing unit).

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

 

Lime injection rate

Maintain free-flowing lime in the feed hopper or silo at all times for continuous injection systems; maintain feeder setting at level established during the performance test for continuous injections systems.

 

Reactive flux injection rate

Maintain reactive flux injection rate at or below rate used during the performance test for each operating cycle or time period used in the performance test.

Attachment D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR

Summary of Operating Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

In-line fluxer (using no reactive flux material)

Flux materials

Use no reactive flux.

Group 1 furnace with lime-injected fabric filter (including those that are part of a secondary aluminum processing unit)

 

Note: NWA’s operation do not include this type of equipment so operating requirements are not applicable.

Bag leak detector; or

Initiate corrective action within 1 hour of alarm and complete in accordance with OM&M planb; operate such that alarm does not sound more than 5% of operating time in 6 month period.

 

COM

Initiate corrective action within 1 hour of a 6-minute average opacity reading of 5% or more and complete in accordance with OM&M plan.b

 

Fabric filter inlet temperature

Maintain average fabric filter inlet temperature for each 3-hour period at or below average temperature during the performance test +14ºC (+25ºF)

 

Reactive flux injection rate

Maintain reactive flux injection rate at or below rate used during the performance test for each operating cycle or time period used in the performance test.

 

Lime injection rate

Maintain free-flowing lime in the feed hopper or silo at all times for continuous injection systems; maintain feeder setting at level established during the performance test for continuous injections systems.

 

Maintain molten aluminum level

Operate sidewell furnaces such that the level of the molten metal is above the top of the passage between sidewell and hearth during reactive flux injection, unless the hearth is also controlled.

 

Fluxing in sidewell furnace hearth

Add reactive flux only to the sidewell of the furnace unless the hearth is also controlled.

Attachment D: TABLE 2 TO 40 CFR PART 63 SUBPART RRR

Summary of Operating Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Group 1 furnace without add-on controls (including those that are part of a secondary aluminum processing unit).

Reactive flux injection rate

Maintain reactive flux injection rate at or below rate used during the performance test for each operating cycle or time period used in the performance test.

 

Site-specific monitoring planc

Operate furnace within the range of charge materials, contaminant levels, and parameter values established in the site-specific monitoring plan.

 

Feed material (melting/holding furnace)

Use only clean charge.

Clean (group 2) furnace

Charge and flux materials

Use only clean charge. Use no reactive flux.

aThermal chip dryers, scrap dryers/delacquering kilns/decoating kilns, dross-only furnaces, in-line fluxers and group 1 furnaces including melting/holding furnaces.

bOM&M plan – Operation, maintenance, and monitoring plan.

cSite-specific monitoring plan. Owners/operators of group 1 furnaces without control devices must include a section in their OM&M plan that documents work practice and pollution prevention measures, including procedures for scrap inspection, by which compliance is achieved with emission limits and process or feed parameter-based operating requirements. This plan and the testing to demonstrate adequacy of the monitoring plan must be developed in coordination with and approved by the Department.

ATTACHMENT E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR

Summary of Monitoring Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

All affected sources and emission units with an add-on air pollution control device

Emission capture and collection system.

Annual inspection of all emission capture, collection, and transport system to ensure that systems continue to operate in accordance with ACGIH standards.

All affected sources and emission units subject to production-based (lb/ton feed/charge) emission limitsa.

Feed/charge weight

Record weight of each feed/charge, weight measurement device or other procedure accuracy of ±1%b; calibrate according to manufacturers specification, or at least once every 6 months.

Group 1 furnaces, group 2 furnaces, in-line fluxers, and scragp dryer/delacquering kiln/decoating kiln.

Labeling

Check monthly to confirm that labels are intact and legible.

Aluminum scrap shredder with fabric filter.

 

Note: There is no control device on the shredder at NWA so these monitoring requirements are not applicable.

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

 

VE

Conduct and record results of 30-minute daily test in accordance with Method 9.

Thermal chip dryer with afterburner

 

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Afterburner operating temperature

Continuous measurement device to meet specifications in 40 CFR §63.1510(g)(1); record average temperature for each 15-minute block period; determine and record 3-hour block averages.

 

Afterburner operation

Annual inspection of afterburner internal parts; complete repairs in accordance with OM&M plan.

 

Feed/charge material

Record identity of each feed/charge; certify feed/charge materials every 6 months.

Attachment E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR

Summary of Monitoring Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Scrap dryer/delacquering kiln/decoating kiln with after burner and lime injected fabric filter

 

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Afterburner operating temperature

Continuous measurement device to meet specifications in 40 CFR §63.1510(g)(1); record average temperature for each 15-minute block period; determine and record 3-hour block averages.

 

Afterburner operation

Annual inspection of afterburner internal parts; complete repairs in accordance with OM&M plan.

 

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

 

Lime injection rate

For continuous injection systems, inspect each feed hopper or silo every 8 hours to verify that lime is free-flowing; record results of each inspection. If blockage occurs, inspect every 4 hours for 3 days; return to 8 hour inspections if corrective action results in no further blockage during 3-day period; record feeder setting daily.

 

Fabric filter inlet temperature

Continuous measurement device to meet specifications in 40 CFR §63.1510(g)(1); record average temperature for each 15-minute block period; determine and record 3-hour block averages.

Sweat furnace with afterburner

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Afterburner operating temperature

Continuous measurement device to meet specifications in 40 CFR §63.1510(g)(1); record average temperature for each 15-minute block period; determine and record 3-hour block averages.

 

Afterburner operation

Annual inspection of afterburner internal parts; complete repairs in accordance with OM&M plan.

Attachment E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR

Summary of Monitoring Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Dross-only furnace with fabric filter

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

 

Feed/charge material

Record identity of each feed/charge; certify feed/charge materials every 6 months.

Rotary dross cooler with fabric filter

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

In-line fluxer with lime-injected fabric filter.

 

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

 

Reactive flux injection rate

Weight measurement device accuracy ±1%b; calibrate according to manufacturer’s specifications or at least once every 6 months; record time, weight and type of reactive flux added or injected for each 15-minute block period while reactive fluxing occurs; calculate and record total reactive flux injection rate for each operating cycle or time period used in performance test; or, Alternative flux injection rate determination procedure per 40 CFR §63.1510(j)(5).

 

Lime injection rate

For continuous injection systems, inspect each feed hopper or silo every 8 hours to verify that lime is free-flowing; record results of each inspection. If blockage occurs, inspect every 4 hours for 3 days; return to 8 hour inspections if corrective action results in no further blockage during 3-day period.d

Attachment E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR

Summary of Monitoring Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

In-line fluxer using no reactive flux

Flux materials

Record flux materials; certify every 6 months for no reactive flux.

Group 1 furnace with lime injected fabric filter

 

Note: NWA’s operations do not include this type of equipment or control device so these monitoring requirements are not applicable.

Bag leak detector; or

Install and operate in accordance with “Fabric Filter Bag Leak Detector Guidance”c; record voltage output from bag leak detector.

 

COM, or

Design and install in accordance with PS-1; collect data in accordance with subpart A of 40 CFR part 63; determine and record 6-minute block averages.

 

Lime injection rate

For continuous injection systems, inspect each feed hopper or silo every 8 hours to verify that lime is free-flowing; record results of each inspection. If blockage occurs, inspect every 4 hours for 3 days; return to 8 hour inspections if corrective action results in no further blockage during 3-day period.d

 

Reactive flux injection rate

Weight measurement device accuracy ±1%b; calibrate according to manufacturer’s specifications or at least once every 6 months; record time, weight and type of reactive flux added or injected for each 15-minute block period while reactive fluxing occurs; calculate and record total reactive flux injection rate for each operating cycle or time period used in performance test; or, Alternative flux injection rate determination procedure per 40 CFR §63.1510(j)(5).

 

Fabric filter inlet temperature

Continuous measurement device to meet specifications in 40 CFR §63.1510(g)(1); record average temperature for each 15-minute block period; determine and record 3-hour block averages.

 

Maintain molten aluminum level in sidewell furnace

Maintain aluminum level operating log; certify every 6 months.

 

Fluxing in sidewell furnace hearth

Maintain flux addition operation log; certify every 6 months.

Attachment E: TABLE 3 TO 40 CFR PART 63 SUBPART RRR

Summary of Monitoring Requirements for New and Existing Affected Sources and Emission Units

 

Affected Source/Emission Unit

Monitor Type/Operation/Process

Operating Requirements

Group 1 furnace without add-on controls.

Reactive flux injection rate

Weight measurement device accuracy ±1%b; calibrate according to manufacturer’s specifications or at least once every 6 months; record time, weight and type of reactive flux added or injected for each 15-minute block period while reactive fluxing occurs; calculate and record total reactive flux injection rate for each operating cycle or time period used in performance test; or, Alternative flux injection rate determination procedure per 40 CFR §63.1510(j)(5).

 

OM&M plan (approved by the Department)

Demonstration of site-specific monitoring procedures to provide data and show correlation of emissions across the range of charge and flux materials and furnace operating parameters.

 

Feed material (melting/holding furnace)

Record type of permissible feed/charge material; certify charge materials every 6 months.

Clean (group 2) furnace

Charge and flux materials

Record charge and flux materials; certify every 6 months for clean charge and no reactive flux.

aThermal chip dryers, scrap dryers/delacquering kilns/decoating kilns, dross-only furnaces, in-line fluxers and group 1 furnaces or melting/holding furnaces.

bThe Department may approve measurement devices of alternative accuracy, for example in cases where flux rates are very low and costs of meters of specified accuracy are prohibitive; or where feed/charge weighing devices of specified accuracy are not practicable due to equipment layout or charging practices.

cNon-triboelectric bag leak detectors must be installed and operated in accordance with manufacturer’s specifications.

dThe Department may approve other alternatives including load cells for lime hopper weight, sensors for carrier gas pressure, or HCl monitoring devices at fabric filter outlet.

 

 

The emissions unit identifications beginning with the letter A are part of the primary aluminum facility while the emissions unit identifications beginning with the letter B are part of the secondary aluminum facility.