OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
OREGON TITLE-V OPERATING PERMIT
Northwest Region
2020 S.W. 4th Avenue, #400
Portland, OR 97201-4987
Telephone: (503) 229-5263
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:
Reynolds Metals Company
5100 NE Sundial Road
Troutdale, OR 97060
PLANT SITE LOCATION:
5100 NE Sundial Road
Troutdale, Oregon
INFORMATION RELIED UPON:
Application No.: 017423 and 017541
Date Received: 04/07/99 and 06/07/99
LAND USE COMPATIBILITY STATEMENT:
From: Multnomah County
Dated: 06/27/95
ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY
Audrey O’Brien, Northwest Region Air Quality Manager Date
Nature of Business: Primary Aluminum Production
Primary SIC: 3334
RESPONSIBLE OFFICIAL: FACILITY CONTACT PERSON
Name: W. Kent Moore Name: Kristin Nadermann
Title: Plant Manager Title: Environmental Manager
Phone: (503) 666-0259
Name: R. A. Starkweather
Title: Plant Superintendent (alternate)
TABLE OF CONTENTS
PERMITTED ACTIVITIES 4
EMISSION UNIT (EU) AND POLLUTION CONTROL DEVICE IDENTIFICATION 4
EMISSION LIMITS AND STANDARDS 6
NESHAP REQUIREMENTS/EMISSIONS LIMITS - 40 CFR 63, SUBPART LL 10
PLANT SITE EMISSION LIMITS 17
TESTING REQUIREMENTS 18
NESHAP TESTING REQUIREMENTS 24
MONITORING REQUIREMENTS 29
NESHAPS MONITORING REQUIREMENTS 36
COMPLIANCE ASSURANCE MONITORING (CAM) REQUIREMENTS 40
PLANT SITE EMISSIONS LIMITS MONITORING 42
AMBIENT MONITORING REQUIREMENTS [OAR 340-025-0285] 45
RECORDKEEPING REQUIREMENTS [OAR 340-028-02130(3)(b)] 46
NESHAPS RECORDKEEPING REQUIREMENTS 47
REPORTING REQUIREMENTS [OAR 340-025-0285 and 340-028-2130(3)(c)] 49
NESHAPS NOTIFICATION AND REPORTING REQUIREMENTS 51
NON-APPLICABLE REQUIREMENTS [OAR 340-028-2190] 55
GENERAL CONDITIONS 56
LIST OF ABBREVIATIONS USED IN THIS PERMIT
10^6 million
ASTM American Society of Testing and Materials
CDP compliance demonstration point
CEMS continuous emissions monitoring system
CFR Code of Federal Regulations
CMS continuous monitoring system
CO carbon monoxide
CPMS continuous parameter monitoring system
DEQ Oregon Department of Environmental Quality
dscf dry standard cubic foot
EF emission factor
EPA US Environmental Protection Agency
EU emissions unit
F fluoride
FCAA Federal Clean Air Act
gr/dscf grain per dry standard cubic foot
H2O water
HAP hazardous air pollutant as defined by OAR 340-032-0130
HF hydrogen fluoride
ID identification number
I&M inspection and maintenance
kg kilogram
MACT Maximum Achievable Control Technology
MB material balance
Mg megagram
MMBtu million British thermal units
NA not applicable
NG natural gas
NOx oxides of nitrogen
O2 oxygen
OAR Oregon Administrative Rules
O&M Operation and Maintenance
ORS Oregon Revised Statutes
PCD pollution control device
PM particulate matter
PM/PM10 particulate matter/particulate matter less than 10 microns in size
PM10 particulate matter less than 10 microns in size
PM2.5 particulate matter less than 2.5 microns in size
POM polycyclic organic matter
ppm part per million
PSEL Plant Site Emission Limit
SERP Source Emission Reduction Plan
SO2 sulfur dioxide
ST source test
TAP tons of primary aluminum produced
TF total fluoride
TGC tons of green carbon placed into the bake furnaces
TSP total suspended particulate
VE visible emissions
VOC volatile organic compound
0. The OAR rule numbers referenced in this permit have been revised. Attachment 1 of this permit provides a cross-reference for SIP rules that have been renumbered in the current Oregon Administrative Rules. [OAR 340-218-0060 and 340-218-0070]
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 340-028-2100, 340-028-2200(2), 340-032-0240]
2. All conditions in this permit are federally enforceable and state enforceable except for conditions 4, 8, 9, 20, 37, and, 78 which are enforceable by the state only. [OAR 340-028-2140 and 340-028-2150]
EMISSION UNIT (EU) AND POLLUTION CONTROL DEVICE IDENTIFICATION
3. Emissions units regulated by this permit are the following: [OAR 340-028-2120(3)]
Emissions Unit | EU ID | Pollution Control Device | PCD ID |
Coke Unloading Dock Ventilation | EU01 | Dock Baghouse | CD01 |
Coke Unloading Dock | EU02 | None | NA |
Coke & Pitch Storage Building | EU03 | None | NA |
Greenmill Ventilation System | EU04 | Greenmill Baghouse | CD04 |
Multiclone | CD04a | ||
Greenmill dry ESP (backup device - CD04) | CD05b | ||
Greenmill Roof Vents | EU05 | None | NA |
Butt Shaker, Crushers | EU06 | Butt Shaker Filter Unit | CD06 |
Carbon Bake ESP | EU07 | Carbon Bake wet ESP | CD07 |
Carbon Bake Roof Vents | EU08 | None | NA |
Carbon Cleaners | EU09 | Carbon Cleaner Baghouse | CD09 |
Cast Iron Furnaces | EU10 | Cast Iron Furnace Baghouses | CD10N and CD10S |
Stub Buffers/Grinders | EU11 | Stub Cleaner Filter Unit | CD11 |
Stub Graphite Station | EU12 | Stub Dip Station Filter Unit | CD12 |
Rodding Room Roof Vents | EU13 | None | NA |
Cast Iron Tumble Mill | EU14 | Tumble Mill Filter Unit | CD14 |
Rod Blast Cabinets | EU15 | Rod Blast Cabinet Filter Units | CD15S |
CD15N | |||
Potlining (Milling) | EU16 | Potlining Baghouse | CD16 |
Potlining (Ramming) | EU17 | None | NA |
Potlining (Bakeout) | EU18 | None | NA |
Potlining (Digging/Disposal) | EU19 | Potlining Disposal Building Filter Unit | CD19 |
Potrooms Primary Collection System | EU20 | Potroom Dry Scrubber (baghouse complex) | CD20 |
Potroom Roof Vents | EU21 | None | NA |
Alumina Ventilation System | EU600 | Auxiliary Baghouse | CD600 |
Fresh Ore Tank | EU28 | Fresh Ore Tank Baghouses (2) | CD28A |
CD28B | |||
200 Ton Air Lifts | EU24 | 200 Ton Air Lift Baghouses (2) | CD2C |
CD3C | |||
60 Ton Air Lifts | EU25 | 60 Ton Air Lift Baghouses (2) | CD4C |
CD5C | |||
Ore Dock | EU27 | Ore Dock Baghouse | CD27B and CD27C |
Ore Belt Crossover | EU37 | Crossover Filter | CD37 |
Floor Sweeping/Screenings | EU38 | Screening System Baghouse | CD38 |
Cast House Holding Furnaces (6 total) | EU29 | Casthouse Baghouse | CD29 |
(4) Furnaces | |||
(2) Furnaces | |||
Cast House Roof Vents | EU30 | None | NA |
Natural Gas Combustion | EU31 | None | NA |
Boilers (2) | |||
Carbon Bake Furnaces (3) | |||
Holding Furnaces (4) | |||
Holding Furnaces (2) | |||
Miscellaneous (5) | |||
Propane Combustion (backup fuel) | EU32 | None | NA |
#2 Diesel Combustion (backup fuel) | EU33 | None | NA |
Graveled Road System | EU34 | None | NA |
Outside Storage Piles and Handling | EU35 | ||
Dross Handling | Enclosure/Dross Press | NA | |
Dross Storage Pile | Enclosure/Dross Press | NA | |
Charcoal Storage Pile | None | NA | |
Anode Paste Scrubber (future) | EU36 | Anode Paste Scrubber | CD36 |
Crucible Cleaning | EU39 | Filter unit | CD39 |
Airslide 21 (future) | EU40 | Baghouse | CD40 |
EMISSION LIMITS AND STANDARDS
The following tables contain summaries of applicable requirements, other than the Plant Site Emission Limit (PSEL), along with the monitoring methods for the emissions units to which those requirements apply.
Applicable | Condition | Pollutant/ | Limit/Standard | Monitoring Requirements |
Requirement | Number | Parameter | Method | Cond. No. | |
ACDP condition 5 | 4 | gaseous fluoride | see below | ASTM D3268 | 78 |
340-021-0060(2) | 5 | fugitive dust | minimize fugitives | O&M Recordkeeping | 50, 51, 52 |
340-022-0015(1) | 6 | distillate fuel oil, ASTM Grade 1 | 0.3% sulfur | Recordkeeping | 53 |
340-022-0015(2) | 7 | distillate fuel oil, ASTM Grade 2 | 0.5% sulfur | Recordkeeping | 53 |
340-030-0520 | 8 | fallout | <250 microns | Recordkeeping | 50, 52 |
340-030-0540(1) | 9 | odors | no nuisance | Recordkeeping | 52 |
340-025-0285(1)(f) | 10 | PCD collection efficiency | monitor collection efficiency | Recordkeeping | 54 |
40 CFR Part 68 | 11 | accidental release | prevention/emergency response | Recordkeeping | 55 |
4. Gaseous fluorides in the ambient air sampled at the plant’s approved ambient monitoring sites calculated as HF, corrected to 25°C and 760 mm mercury shall not exceed the following:
4.a. 3.5 micrograms HF per cubic meter average for any twelve (12) consecutive hours;
4.b. 2.7 micrograms HF per cubic meter average for any twenty-four (24) consecutive hours;
4.c. 1.6 micrograms HF per cubic meter average for any thirty (30) consecutive days. [05/27/88 ACDP 26-1851, condition 5] [state-only enforceable]
5. The permittee shall take reasonable precaution to prevent particulate matter from becoming airborne including, but not limited to the following specific actions: [OAR 340-021-0060(2)]
EU ID | Work Practice |
EU01, EU02, EU03 | storing collected material from CD01 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
requiring a particle size specification on the purchased coke | |
requiring application of a dedusting agent on the purchased coke | |
maintaining the storage building enclosure | |
EU04, EU05, EU06, EU36 | storing collected material from CD04 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
requiring a particle size specification on the purchased coke | |
requiring application of a dedusting agent on the purchased coke | |
using the sealing system for batch car unloading | |
using the batch car emissions minimization system during unloading | |
EU07, EU08, EU09 | using the bake furnace draft system |
using a screened particle size for the packing material | |
EU10, EU11, EU12, EU13, EU14, EU15 | storing collected material from CD10N and CD10S, CD15S, CD15N, CD11, CD14, and CD12 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
EU16, EU17, EU18, EU19 | storing collected material from CD16 and CD19 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
Operate CD 19 baghouse whenever dry pots are being processed | |
using a cold ram mix instead of hot ram | |
EU20, EU21 | storing collected material from CD20 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
reducing the -20 µm fraction of alumina to less than 10%, weight basis | |
producing pressed green carbon anodes averaging at least 315 pounds on a daily basis | |
using computers to control pot feeding operations unless manual feeding is required due to problems with computer pot feeding system | |
EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU39, EU40 | storing collected material from CD600, CD28A, CD28B, CD2C, CD3C, CD4C, CD5C, CD27B and CD27C, CD37, and CD38 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
EU29, EU30 | storing collected material from CD29 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer |
using a fugitive minimization system |
6. The permittee shall not use any ASTM Grade 1 distillate fuel oil containing more than 0.3 percent sulfur by weight. Sulfur content shall be measured using the test methods identified in condition 53. [OAR 340-022-0015(1)]
7. The permittee shall not use any ASTM Grade 2 distillate fuel oil containing more than 0.5 percent sulfur by weight. Sulfur content shall be measured using the test methods identified in condition 53. [OAR 340-022-0015(2)]
8. No person shall cause or permit the emission of any particulate matter which is larger than 250 microns in size provided such particulate matter does or will deposit upon the real property of another person. [OAR 340-030-0520] [state-only enforceable]
9. No person shall cause or permit the emission of odorous matter in such manner as to contribute to a condition of air pollution, or exceed:
9.a. A Scentometer No. 0 odor strength or equivalent dilution in residential and commercial areas;
9.b. A Scentometer No. 2 odor strength or equivalent dilution in all other land use areas. [OAR 340-030-0540(1)] [state-only enforceable]
10. The permittee shall monitor and record changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes. [OAR 340-025-0285(1)(f)]
11. The permittee shall comply with the applicable requirements of 40 CFR Part 68, “Accidental Release Prevention”, including all monitoring, recordkeeping, and reporting requirements.
EMISSIONS UNITS
EU ID | Applicable | Cond. | Pollutant/ | Limit/Standard | Monitoring Requirements |
Requirement | No. | Parameter | Method | Condition Number | ||
EU07, E20, EU21 | 340-025- 0265(3)(a)(A) | 12 | Fluoride ion | 3.5 lbs/TAP monthly average | Recordkeeping/ ST periodic monitoring/ I&M Recordkeeping | 44, 57, 60, 61, 62 |
Elective condition | Fluoride ion | 3.0 lbs/TAP monthly average | Recordkeeping/ ST periodic monitoring/ I&M Recordkeeping | 44, 57, 60, 61, 62 | ||
340-025- 0265(3)(a)(B) | 14 | Fluoride ion | 2.5 lbs/TAP/year | Recordkeeping/ I&M Recordkeeping | 44, 57, 60, 61, 62 | |
EU01, EU04, EU06, EU07, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU21, EU600, | 340-025- 0265(3)(c)(A) | 15 | PM/PM10 | 15.6 lbs/TAP monthly average | Recordkeeping/ ST periodic monitoring/ I&M Recordkeeping | 44, 57, 60, 61, 62, 64 |
EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU31, EU32, EU33, EU36 | 340-025- 0265(3)(c)(B) | 16 | PM/PM10 | 13.5 lbs/TAP/year | Recordkeeping/ I&M Recordkeeping | 44, 57, 60, 61, 62, 64 |
EU01, EU04, EU06, EU07, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU21, EU37, EU38, EU29, EU36 | 340-021- 0030(1)(a) | 17 | PM/PM10 | 0.2 gr/dscf | ST periodic monitoring/ I&M Recordkeeping | 44, 58, 60, 61, 62 |
EU600, EU28, EU24, EU25, EU27, EU39, EU40 | 340-021- 0030(1)(b) | 18 | PM/PM10 | 0.1 gr/dscf | ST periodic monitoring/ I&M Recordkeeping | 61, 62 |
EU31, EU32, EU33 | 340-021- 0020(1)(a) | 19 | PM/PM10 | 0.2 gr/dscf | I&M Recordkeeping | 63 |
EU33 | 340-030- 0510(1) | 20 | PM/PM10 | see condition 20 | I&M Recordkeeping | 63 |
EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU36 | ACDP condition 2 | 21 | opacity | 10% for 30 seconds | VE periodic monitoring/ Recordkeeping/ I&M Recordkeeping | 51, 56, 60, 61, 62, 64 |
EU01, EU02, EU03, EU04, EU05, EU06, EU07, EU08, EU09, EU10, EU11, EU12, EU13, EU14, EU15, EU16, EU17, EU18, EU19, EU20, EU21, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU30, EU31, EU32, EU33, EU34, EU35, EU36, EU39, EU40 | 340-025- 0265(3)(d) | 22 | opacity | 20% any time | VE periodic monitoring/ Recordkeeping/ I&M Recordkeeping | 50, 56, 60, 61, 62, 64 |
12. Before the date on which the total fluoride emissions standards of 40 CFR 63.843 are effective for all potlines, the permittee shall operate the plant such that the total emissions from the following primary aluminum sources: EU07, EU20, and EU21 do not exceed 3.5 lbs fluoride ion/ton of aluminum/month. After the date that the total fluoride emissions standards of 40 CFR 63.843 are effective, this emission limit is no longer effective. Fluoride emissions shall be measured in accordance with conditions 44 and 45. [OAR 340-025-0265(3)(a)(A)]
13. Before the date on which the total fluoride emissions standards of 40 CFR 63.843 are effective for all potlines, the permittee shall operate the plant such that the total emissions from the following primary aluminum sources: EU07, EU20, and EU21 do not exceed 3.0 lbs fluoride ion/ton of aluminum/month. After the date that the total fluoride emissions standards of 40 CFR 63.843 are effective, this emission limit is no longer effective. Fluoride emissions shall be measured in accordance with conditions 44 and 45. [Elective Condition]
14. The permittee shall operate the plant such that the total emissions from the following primary aluminum sources: EU07, E20, and EU21 do not exceed an annual average of 2.5 lbs fluoride ion/ton of aluminum produced. Fluoride emissions shall be measured in accordance with conditions 44 and 45. [OAR 340-025-0265(3)(a)(B)]
15. The permittee shall operate the plant such that the total emissions from the following primary aluminum sources: EU01, EU04, EU06, EU07, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU21, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU31, EU32, EU33, EU36, EU39, and EU40 do not exceed 15.6 lbs particulate/ton of aluminum/month. Particulate matter emissions shall be measured in accordance with conditions 44 and 45. [OAR 340-025-0265(3)(c)(A)]
16. The permittee shall operate the plant such that the total emissions from the following primary aluminum sources: EU01, EU04, EU06, EU07, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU21, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU31, EU32, EU33, EU36, EU39, and EU40 do not exceed 13.5 lbs particulate/ton of aluminum/year. Particulate matter emissions shall be measured in accordance with conditions 44 and 45. [OAR 340-025-0265(3)(c)(B)]
17. 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 units EU01, EU04, EU06, EU07, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU21, EU37, EU38, EU29, or EU36. Particulate matter emissions shall be measured in accordance with conditions 44 and 45. [OAR 340-021-0030(1)(a)]
18. The permittee shall not cause or allow the emission of particulate matter in excess of 0.1 grain per dry standard cubic foot from emissions units EU600, EU28, EU24, EU25, EU27, EU39, or EU40. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-021-0030(1)(b)]
19. The permittee shall not cause or allow the emission of particulate matter in excess of 0.2 grains per dry standard cubic foot, corrected to 12% CO2, from emissions units EU31, EU32, or EU33. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-021-0020(1)(a)]
20. The emission of particulate matter from emissions unit EU33 shall not exceed the following: [OAR 340-030-0510] [state-only enforceable]
20.a. 0.41 lb/MMBtu when burning diesel fuel; and
20.b. Smoke Spot #2 for distillate fuel, measured by ASTM D2156-65, “Standard Method for Test for Smoke Density of the Flue Gases from Distillate Fuels”.
20.c. Particulate matter emissions shall be measured in accordance with condition 45.
21. Visible emissions from emissions units EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU36, EU39, or EU40 shall not exceed ten percent (10%) opacity for more than thirty (30) seconds in any one hour period. Opacity shall be measured in accordance with conditions 45 and 56. [05/27/88 ACDP 26-1861, condition 2]
22. Visible emissions from emissions units EU01, EU02, EU03, EU04, EU05 (before installation of EU36), EU06, EU07, EU08, EU09, EU10, EU11, EU12, EU13, EU14, EU15, EU16, EU17, EU18, EU19, EU20, EU21, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU30, EU31, EU32, EU33, EU34, EU35, EU36, EU39, or EU40 shall not exceed 20 percent opacity, excluding uncombined water, or 1.0 on the Ringlemann Smoke Chart at any time. Opacity shall be measured in accordance with conditions 45 and 56. [OAR 340-025-0265(3)(d)]
OPERATIONAL REQUIREMENTS
EU ID | Applicable | Cond. | Pollutant/ | Requirement | Monitoring Requirements |
Requirement | No. | Parameter | Method | Cond. No. | ||
EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU600, EU28, EU24, EU25, EU27, EU29, EU37, EU38, EU39, EU40 | 340-028- 0620(2), 340-028- 2130(1) | 23 | Pressure drop | Take corrective action to return to highest and best practicable treatment and control | Recordkeeping | 62 |
23. The permittee shall take corrective action to return to highest and best practicable treatment and control if the pressure drop for baghouses and filter units CD01, CD2C, CD3C, CD04, CD4C, CD5C, CD06, CD09, CD10N and CD10S, CD11, CD12, CD14, CD15S, CD15N, CD16, CD19, CD28B, CD27B and CD27C, CD28A, CD29, CD37, CD38, CD39, CD40 or CD600 deviate from the operating ranges, as established in the operating plan required in condition 62. [OAR 340-028-0620(1) and 340-028-2130(1)]
23.a. The deviation from a parameter operating range shall not be considered a violation of an emission standard in this permit.
NESHAP REQUIREMENTS/EMISSIONS LIMITS - 40 CFR 63, SUBPART LL
24. For purposes of the requirements of 40 CFR 63 Subpart LL contained in this permit, the “applicable regulatory authority” shall be the Administrator (EPA), unless notified otherwise in writing by the Department. [40 CFR 63.2]
25. Compliance dates. [40 CFR 63.847]
The permittee shall demonstrate initial compliance by:
25.a. October 7, 1999, for all requirements of conditions 26, 27, 28, 29, 46, 47, 65, 82, 90, and 91 pertaining to Potlines #3 and #5.
25.b. October 9, 2000, for the following requirements pertaining to the Paste production plant EU36;
25.b.i. Condition 27.b Emission limits;
25.b.ii. Condition 29 Operational requirements;
25.b.iii. Condition 46 Compliance provisions;
25.b.iv. Condition 47 Test Methods;
25.b.v. Condition 65 Monitoring;
25.b.vi. Condition 82 Recordkeeping;
25.b.vii. Condition 90 Notifications; and
25.b.viii. Condition 91 Reporting.
25.c. October 9, 2000, for the following requirements pertaining to the Anode bake furnaces EU07;
25.c.i. Condition 27.c Emission limits;
25.c.ii. Condition 29 Operational requirements;
25.c.iii. Condition 46 Compliance provisions;
25.c.iv. Condition 47 Test Methods;
25.c.v. Condition 65 Monitoring;
25.c.vi. Condition 82 Recordkeeping;
25.c.vii. Condition 90 Notifications; and
25.c.viii. Condition 91 Reporting.
25.d. For Potlines #1, #2, and #4, October 9, 2000,or 180 days after restart of an existing potline that is temporarily shutdown, whichever is later, for the following monitoring requirements;
25.d.i. Conditions 27.a and 28 Emission limits and Emission averaging;
25.d.ii. Condition 46 Compliance provisions;
25.d.iii. Condition 47 Test Methods;
25.d.iv. Condition 65 Monitoring;
25.d.v. Condition 82 Recordkeeping;
25.d.vi. Condition 90 Notifications; and
25.d.vii. Condition 91 Reporting.
26. Compliance with emission standards. The emission standards set forth in conditions 27 and 28 shall apply at all times except during periods of startup, shutdown, and malfunction. [40 CFR 63.6(f)(1)]
27. Emission limits for existing sources under the Primary Aluminum Reduction NESHAP. [40 CFR 63.843]
27.a. Potlines. The permittee shall not discharge or cause to be discharged into the atmosphere from the potlines (EU20 and EU21) any emissions of TF in excess of the applicable limits in condition 27.a.i.
27.a.i. TF limits. Emissions of TF shall not exceed 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each potline.
27.b. Paste production plant. The permittee shall install, operate, and maintain equipment to capture and control POM emissions from the paste production plant (EU05).
27.b.i. 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” (incorporated by reference in 40 CFR 63.841); and
27.b.ii. Captured emissions shall be routed through a closed system to a dry coke scrubber (EU36).
27.c. Anode bake furnaces. The permittee shall not discharge or cause to be discharged into the atmosphere any emissions of TF or POM in excess of the limits in conditions 27.c.i and 27.c.ii, from the anode bake furnaces, EU07.
27.c.i. TF limit. Emissions of TF shall not exceed 0.10 kg/Mg (0.20 lb/ ton) of green anode; and
27.c.ii. POM limit. Emissions of POM shall not exceed 0.09 kg/Mg (0.18 lb/ton) of green anode.
28. Emission averaging under the Primary Aluminum Reduction NESHAP. [40 CFR 63.846]
28.a. General. The permittee may demonstrate compliance for the potline(s) by emission averaging according to the procedures in this condition.
28.b. The permittee may submit a request to the applicable regulatory authority to implement emission averaging after the applicable compliance date.
28.c. Potlines. The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table 1 (below) using the procedures in condition 28.c.i and 28.c.ii.
28.c.i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 (for TF emissions). The emission rate shall be calculated based on the total emissions over the period from all potlines comprising the averaging group divided by the quantity of aluminum produced during the period, from all potlines comprising the averaging group.
28.c.ii. To determine compliance with the applicable emission limit in Table 1 for TF emissions, the permittee shall determine the monthly average emissions (in lb/ton) from each potline from at least three runs per potline each month for TF secondary emissions using the procedures and methods in conditions 46 and 47. The permittee shall combine the results of secondary TF monthly average emissions with the TF results for the primary control system and divide total emissions by total aluminum production.
Table 1 To Subpart LL Potline TF Limits for Emission Averaging
Type 2 lines 3 lines 4 lines 5 lines 6 lines 7 lines 8 lines
CWPB2 2.9 2.8 2.7 2.7 2.6 2.6 2.6
Monthly TF limit (1b/ton) [for given number of potlines]
28.d. Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging to the applicable regulatory authority for review and approval according to the following procedures and requirements:
28.d.i. Deadlines. The permittee must submit the implementation plan no later than 6 months before the date that the facility intends to comply with the emission averaging limits.
28.d.ii. Contents. The permittee shall include the following information in the implementation plan or in the application for an operating permit for all emission sources to be included in an emissions average:
28.d.ii.1. The identification of all emission sources (potlines) in the average;
28.d.ii.2. The assigned TF emission limit for each averaging group of potlines;
28.d.ii.3. The specific control technology or pollution prevention measure to be used for each emission source in the averaging group and the date of its installation or application. If the pollution prevention measure reduces or eliminates emissions from multiple sources, the permittee must identify each source;
28.d.ii.4. The test plan for the measurement of TF emissions in accordance with the requirements in condition 46.b;
28.d.ii.5. The operating parameters to be monitored for each control system or device and a description of how the operating limits will be determined;
28.d.ii.6. A demonstration that compliance with each of the applicable emission limit(s) will be achieved under representative operating conditions.
28.d.iii. Prohibitions. The implementation plan shall not contain any of the following provisions:
28.d.iii.1. Any averaging between emissions of differing pollutants or between differing sources. Emission averaging shall not be allowed between potlines and bake furnaces;
28.d.iii.2. The inclusion of any emission source other than an existing potline or the inclusion of any potline not subject to the same operating permit;
28.d.iii.3. The inclusion of any potline while it is shut down; or
28.d.iii.4. The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown, and malfunction plan required by 91.d, in the emission calculations.
28.d.iv. Term. The term of approval for the plan is the operating permit term.
28.d.iv.1. To revise the plan prior to the end of the permit term, the permittee shall submit a request to the applicable regulatory authority.
29. NESHAP Operational Requirements
29.a. Operation and maintenance requirements [40 CFR 63.6(e)] 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 conditions 27 and 28.
29.a.i. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan required in condition 29.c.
29.a.ii. Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable independent of emissions limitations or other requirements in conditions 26, 27, 28, 46, 47, 65, 82, 90, and 91.
29.a.iii. 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 29.c], review of operation and maintenance records, and inspection of the source.
29.b. Corrective action. [63.848(h)] If a monitoring device for a primary control device measures an operating parameter outside the limit(s) established pursuant to condition 46.f or, if visible emissions indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection, the owner or operator 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.
29.c. Startup, Shutdown, and Malfunction Plan. [40 CFR 63.6(e)]
29.c.i. For each affected source, the permittee shall develop and implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures 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 conditions 26, 27, 28, 29, and 65. As required under condition 66.b.i.1, the plan shall identify all routine or otherwise predictable CMS malfunctions. This plan shall be developed by the permittee by the first compliance date in condition 25. The plan shall be considered to be incorporated by reference into this Permit. Changes to the startup, shutdown, and malfunction plan shall be made in accordance with the procedures in condition 29.c. No change that affects only the startup, shutdown, and malfunction plan shall be considered a change, revision or modification to the permit. The purpose of the startup, shutdown, and malfunction plan is to--
29.c.i.1. 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 conditions 26, 27, 28, and 29;
29.c.i.2. Ensure that permittee are prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize excess emissions of hazardous air pollutants; and
29.c.i.3. 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).
29.c.ii. During periods of startup, shutdown, and malfunction, the permittee shall operate and maintain each affected source (including associated air pollution control equipment) in accordance with the procedures specified in the startup, shutdown, and malfunction plan developed under condition 29.c.i.
29.c.iii. 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 82.a (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 91.a.ii.
29.c.iv. 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 91.a.iii (unless the permittee makes alternative reporting arrangements, in advance, with the Administrator [see condition 91.a.iii]).
29.c.v. 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 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.
29.c.vi. To satisfy the requirement 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 and are made available for inspection when requested by the Administrator.
29.c.vii. Based on the results of a determination made under condition 29.a.iii, 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:
29.c.vii.1. Does not address a startup, shutdown, or malfunction event that has occurred;
29.c.vii.2. 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 conditions 26, 27, 28, and 29; or
29.c.vii.3. Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control equipment as quickly as practicable.
29.c.viii. 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.
INSIGNIFICANT ACTIVITIES
Applicable | Condition | Pollutant | Limit/Standard |
Requirement | Number | /Parameter | |
340-025-0265(3)(a)(A) | 30 | Fluoride ion | 3.5 lbs/TAP/month monthly average |
340-025-0265(3)(a)(B) | 31 | Fluoride ion | 2.5 lbs/TAP/year |
340-025-0265(3)(c)(A) | 32 | PM/PM10 | 15.6 lbs/TAP/month monthly average |
340-025-0265(3)(c)(B) | 33 | PM/PM10 | 13.5 lbs/TAP/year |
340-025-0265(3)(d) | 34 | opacity | 20% at any time |
340-021-0020(1)(b) | 35 | PM/PM10 | 0.1 gr/dscf 3 hour average |
340-021-0030(1)(b) | 36 | PM/PM10 | 0.1 gr/dscf 3 hour average |
340-030-0460(3) | 37 | gasoline tank | submersible fill or control system |
30. Before the date on which the total fluoride emissions standards of 40 CFR 63.843 are effective for all potlines, the permittee shall operate the plant such that the total emissions from any categorically insignificant activity or any activity included in the aggregate insignificant emissions in addition to the sources listed in condition 12 shall not exceed 3.5 lbs fluoride ion/ton of aluminum/month. After the date that the total fluoride emissions standards of 40 CFR 63.843 are effective, this emission limit is no longer effective. Fluoride emissions shall be measured in accordance with condition 45. [OAR 340-025-0265(3)(a)(A)]
31. The permittee shall operate the plant such that the total emissions from any categorically insignificant activity or any activity included in the aggregate insignificant emissions in addition to the sources listed in condition 14 shall not exceed 2.5 lbs fluoride ion/ton of aluminum/year. Fluoride emissions shall be measured in accordance with condition 45. [OAR 340-025-0265(3)(a)(B)]
32. The permittee shall operate the plant such that the total emissions from any categorically insignificant activity or any activity included in the aggregate insignificant emissions in addition to the sources listed in condition 15 shall not exceed 15.6 lbs particulate/ton of aluminum/month. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-025-0265(3)(c)(A)]
33. The permittee shall operate the plant such that the total emissions from any categorically insignificant activity or any activity included in the aggregate insignificant emissions in addition to the sources listed in condition 16 shall not exceed 13.5 lbs particulate/ton of aluminum/year. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-025-0265(3)(c)(B)]
34. Visible emissions from any categorically insignificant activity or any activity included in the aggregate insignificant emissions shall not exceed 20 percent opacity, excluding uncombined water, or 1.0 on the Ringlemann Smoke Chart at any time. Opacity shall be measured in accordance with condition 45. [OAR 340-025-0265(3)(d)]
35. The permittee shall not cause or allow the emission of particulate matter, for any three (3) hour average period, in excess of 0.1 grain per dry standard cubic foot, corrected to 12% CO2, from any fuel burning and refuse burning equipment that is a categorically insignificant activity or any activity included in the aggregate insignificant emissions. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-021-0020(1)(b)]
36. The permittee shall not cause or allow the emission of particulate matter, for any three (3) hour average period, in excess of 0.1 grain per dry standard cubic foot, from any non-fugitive air contaminant source other than fuel burning and refuse burning equipment that is a categorically insignificant activity or any activity included in the aggregate insignificant emissions. Particulate matter emissions shall be measured in accordance with condition 45. [OAR 340-021-0030(1)(b)]
37. Gasoline tanks with a capacity of 500 gallons or more, installed after January 1, 1970, shall be equipped with submersible filling device or other vapor emission control systems. [OAR 340-030-0460(3)] [state-only enforceable]
PLANT SITE EMISSION LIMITS
38. The short term plant site emissions (tons/month) shall not exceed the following [OAR 340-028-1010 and 340-028-1020]:
EU ID | Pollutant | Short Term PSEL | Monitoring Requirements |
Method | Condition Number | |||
Facility Wide | F | 21 | ST periodic monitoring/Recordkeeping | 44, 73 |
PM/PM10 | 95 | ST periodic monitoring/Recordkeeping | 44, 73 | |
SO2 | 399 | ST periodic monitoring/ Recordkeeping/MB Recordkeeping | 44, 73 | |
CO | 1,314 | Recordkeeping | 73 | |
NOx | 9 | Recordkeeping | 73 | |
VOC | 8 | Recordkeeping | 73 | |
VOC | 795 lb/day | Recordkeeping | 73 |
39. The annual plant site emissions (tons/year) shall not exceed the following [OAR 340-028-1010 and 340-028-1020]:
Facility-Wide | CO | NOx | PM/PM10 | SO2 | VOC | Pb | F |
Total | 13,138 | 59 | 956 | 4701 | 86 | 0.1 | 171 |
40. The annual Plant Site Emission Limits of hazardous air pollutants for fee purposes only are the following [OAR 340-028-1050 and 340-032-0260]:
EU ID | Hazardous Air Pollutant | tons/year
|
EU29 | Hydrogen chloride | 27 |
EU05, EU07, EU17, EU18, EU20, EU21 | Polycyclic organic matter | 43 |
TESTING REQUIREMENTS
41. Unless otherwise specified in this permit, routine testing requirements contained in conditions 43 and 44 are not applicable during periods of temporary or permanent shutdown.
42. Unless otherwise specified in this permit, the permittee shall begin source testing as required by this permit within 60 days after initial startup of a potline. Initial startup of a potline is the point when quality metal is tapped from a pot in the potline.
43. Unless otherwise specified in this permit, the permittee shall conduct all testing in accordance with the Department’s Source Sampling Manual, the latest Department-approved Reynolds Metals’ Air Emissions Testing Quality Assurance Plan, or alternative method approved in writing by the Department.
43.a. The permittee shall use the following reference methods to determine compliance with the applicable emission limits for particulate matter, and sulfur dioxide for conditions 15, 16,and 17 and conditions 38 and 39. The permittee shall also use the following reference methods to determine compliance with the total fluoride emissions limits of condition 12, 13 and 14 until the date on which the total fluoride emissions standards of 40 CFR 63.843 are effective (for each individual potline):
43.a.i. Method 1 in appendix A to 40 CFR Part 60 for sample and velocity traverses;
43.a.ii. Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;
43.a.iii. Method 3 in appendix A to 40 CFR Part 60 for gas analysis;
43.a.iv. EPA Method 5, as modified by Reynolds Metals’ Air Emissions Testing Quality Assurance Plan, for the concentration of particulate matter emissions, or the RMC Method (EU21 only);
43.a.v. EPA Method 6, 6A, or 6B, as modified by Reynolds Metals’ Air Emissions Testing Quality Assurance Plan, for the concentration of sulfur dioxide emissions, except as allowed by condition 74.c;
43.a.vi. Method 13B in appendix A to 40 CFR Part 60, as modified by Reynolds Metals’ Air Emissions Testing Quality Assurance Plan, or the RMC Method (EU21 only), or an approved alternative, for the concentration of total fluoride where stack or duct emissions are sampled;
43.b. The Department shall be notified, in writing, at least 15 days prior to any source test. Instead of the 15-day prior notification, the permittee may submit a source test schedule for the year for the routine source testing. The permittee shall notify the Department only upon any changes to the routine source testing schedule or if other than the permittee performs the testing.
43.c. 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 performance test, which are a result of consultation during the tests with source testing personnel, equipment vendors or consultants, may render the source performance test invalid.
43.d. Unless otherwise specified by permit condition or approved in writing by the Department, all compliance source tests shall be performed at maximum operating capacity for the number of pot lines operating. For purposes of this permit, the maximum operating rate is defined as the 90th percentile of all hourly operating rates during a 12-month period of time immediately preceding the source test.
44. The following procedures and test methods shall be used for all source tests, including the monthly source tests required by OAR 340-025-0280 and subsequent performance tests on emissions units EU07, EU20, EU21, and EU36, for total fluoride, particulate and sulfur dioxide emissions. Source tests shall be performed at the respective monitoring points CDP07, CDP20, CDP21, and CDP 36 for monitoring pertaining to the emissions limits in conditions 12, 13, 14, 15, 16, 17, 38, and 39:
44.a. The following table contains a brief summary of particulate and total fluoride source testing requirements that apply before and after the total fluoride emissions standards of 40 CFR 63.843 are effective for EU21 (for each individual potline).
EU ID | Applicable Requirement Condition | Pollutant | Test Method | Frequency |
EU21 | 15, 16, 17 | particulate matter | RMC Method \ | monthly |
Before | 12, 13, 14 | total fluoride | RMC Method \/EPA Method 13B | monthly |
EU21 | 15, 16, 17 | particulate matter | EPA Method 14/5, or RMC Method \ | as required |
After | 12, 13, 14 | total fluoride | EPA Method 14/13B (NESHAP), or HF CEM( as approved) | by conditions |
\ RMC Method is the method approved in the permittee’s current Quality Assurance Plan.
44.b. The following table contains a brief summary of particulate and total fluoride source testing requirements that apply before and after the emissions standards of 40 CFR 63.843 are effective for EU07.
EU ID | Applicable Requirement Condition | Pollutant | Test Method | Frequency |
EU07 | 15, 16, 17 | particulate matter | EPA Method 5 \( | monthly |
Before | 12, 13, 14 | total fluoride | EPA Method 13B | monthly |
EU07 | 15, 16, 17 | particulate matter | EPA Method 5 \( | as required |
After | 12, 13, 14 | total fluoride | EPA Method 13B (NESHAP) | by conditions |
\( EPA Method 5 and 13B may be a combined sample train.
44.c. The following table contains a brief summary of source testing requirements for EU20, and EU36.
EU ID | Applicable Requirement Condition | Pollutant | Test Method | Frequency |
EU20 | 15, 16, 17 | particulate matter | EPA Method 5 \( | as required |
12, 13, 14 | total fluoride | EPA Method 13B (NESHAP) | by conditions | |
EU36 | 21, 22 | visible emissions | Modified Method 9 | one time within |
17 | particulate matter | EPA Method 5 | 60 days of startup |
\( EPA Method 5 and 13B may be a combined sample train.
44.d. During each test, the permittee shall record the following information as applicable:
For EU20:
44.d.i. aluminum production, per potline;
44.d.ii. alumina injection rate, per potline;
44.d.iii. baghouse pressure drops per potline and EU20 volumetric flowrate (dscfm); and
For EU07:
44.d.iv. baked anode production;
44.d.v. ESP primary voltages and secondary currents;
44.d.vi. ESP inlet temperature and volumetric flowrate (dscfm); and
For EU36:
44.d.vii. green carbon production;
44.d.viii. coke injection rate; and
44.d.ix. baghouse pressure drops and EU36 volumetric flowrate (dscfm).
44.e. Until the total flouride emissions standards of 40 CFR 63.843 are effective for the carbon bake furnace EU07, source testing shall be performed for total fluoride emissions and particulate emissions using EPA Method 13b and EPA Method 5 (combined train) at least one time each calendar month for the carbon bake wet ESP system, CD07. The permittee shall compute and record the monthly average from at least three runs for the carbon bake ESP, EU07, to determine compliance with conditions 12 and 13 for fluoride emissions and conditions 15, 16 and 17 for particulate emissions. [OAR 340-25-0280]
After the total fluoride emissions standards of 40 CFR 63.843 are effective for the carbon bake furnace, the permittee shall perform compliance testing as scheduled and required by conditions 46.d and 47 (NESHAP testing). Until conditions 12 and 13 are no longer effective, the permittee shall compute and record the carbon bake furnace’s contribution to monthly total fluoride ion / ton of aluminum produced (lb-F/TAP), from the average of all valid test runs performed in the previous 12-month period, to determine compliance with the total fluoride emissions limitations of conditions 12 and 13. The permittee shall also perform particulate source testing using EPA Method 5 (combined train with EPA Method 13b) in accordance with the schedule required by condition 46.d (NESHAP testing), and shall compute and record the monthly average particulate emissions /ton of aluminum produced (lb-PM/TAP), from the average of all valid runs performed in the previous 12-month period for the carbon bake ESP, EU07, to determine compliance with the particulate emissions limitations of conditions 15 and 16.
44.f. The permittee shall perform compliance testing as scheduled and required by conditions 46.d and 47 (NESHAP testing). Until conditions 12 and 13 are no longer effective, the permittee shall compute and record the potroom dry scrubber’s contribution to monthly total fluoride ion / ton of aluminum produced (lb-F/TAP), from the average of all valid test runs performed in the previous 12-month period, to determine compliance with the total fluoride emissions limitations of conditions 12 and 13. The permittee shall also perform particulate source testing using EPA Method 5 (combined train with EPA Method 13b) in accordance with the schedule required by condition 46.d (NESHAP testing), and shall compute and record the monthly average particulate emissions /ton of aluminum produced (lb-PM/TAP), from the average of all valid runs performed in the previous 12-month period for the potroom dry scrubber, EU20, to determine compliance with the particulate emissions limitations of conditions 15, 16 and 17.
44.g. Until the total fluoride emissions standards of 40 CFR 63.843 are effective for a potline in EU21 (each individual line), source testing shall be performed for total fluoride emissions and particulate emissions using the RMC Method as approved in the permittee’s Quality Assurance Plan at least once each month for each operating potline. The permittee shall compute and record the monthly average from at least three runs, to determine compliance with conditions 12 and 13 for fluoride emissions, and 15, 16 and 17 for particulate emissions. [OAR 340-025-0280].
44.h. After the total fluoride emissions standards of 40 CFR 63.843 are effective for a potline in EU21, the permittee shall perform fluoride compliance testing as scheduled and required by conditions 46.d and 47 (NESHAP testing). The permittee shall also perform particulate source testing using EPA Method 5 (combined train with EPA Method 13b, collected by EPA Method 14) in accordance with the same schedule as the NESHAP testing or, if fluoride compliance testing is performed using an HF CEM, particulate testing may be conducted using the RMC method as approved in the permittee’s QAP:
44.h.i. Until conditions 12 and 13 are no longer effective, the permittee shall compute and record the potline 3 and 5 monthly contribution to total fluoride ion using the results of the compliance testing as scheduled and required by conditions 46.d and 47 (NESHAP testing), to determine compliance with the total fluoride emissions limitations of conditions 12 and 13.
44.i. After the total fluoride emissions standards of 40 CFR 63.843 are effective for a potlines 3 and 5, and until conditions 12 and 13 are no longer effective for potlines 1, 2, and 4, source testing shall be performed for total fluoride emissions and particulate emissions using the RMC Method as approved in the permittee’s Quality Assurance Plan at least once each month for potlines 1, 2, and 4 (if operating). The permittee shall compute and record the monthly average from at least three runs, to determine compliance with conditions 12 and 13 for fluoride emissions, and 15, 16 and 17 for particulate emissions. [OAR 340-025-0280]
44.j. Within 60 days after initial startup of EU36, the permittee shall perform source testing of EU36 to determine compliance with conditions 17, 21, and 22, and to develop emissions factors for determining compliance with conditions 15, 16, and 38. Modified Method 9 shall be used to determine compliance with conditions 21 and 22, and EPA Method 5 shall be used to determine compliance with condition 17, and to develop the emissions factors for determining compliance with conditions 15, 16, and 38.
44.k. The following table contains a brief summary of the sulfur dioxide source testing required:
EU ID | Applicable Requirement Condition | Pollutant | Test Method | Frequency |
EU07 | 38, 39 | sulfur dioxide | Material Balance or EPA Method 6, 6A, or 6B | monthly |
EU20 | 38, 39 | sulfur dioxide | Material Balance or EPA Method 6, 6A, or 6B | monthly |
EU21 | 38, 39 | sulfur dioxide | Material Balance or EPA Method 6, 6A, or 6B | monthly |
44.l. If source testing is performed for sulfur dioxide emissions for EU07, EU20, or EU21 instead of the calculations as allowed by condition 74.c, it shall be performed at least one time each calendar month. The permittee shall compute and record the monthly average from at least three runs to determine compliance with conditions 38 and 39. [OAR 340-025-0280]
44.m. Results from monthly source tests shall be submitted in the monthly report required by condition 83.
45. If source testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the following test methods and averaging times to measure the pollutant emissions for the applicable requirements referenced in the table:
Emissions Unit ID | Applicable Requirement Condition | Test Method | Averaging Time | Special Conditions |
EU31, EU32, EU33, insignificant activities | ODEQ Method 5 | average of three one-hour test runs | ODEQ Method 5 is for indirect contact fuel burning equipment (e.g., boilers) and any other source. | |
EU04, EU36, insignificant activities | 15, 16, 17, 32, 33 | ODEQ Method 7 | average of three one-hour test runs | ODEQ Method 7 is for direct contact combustion or other heat sources (e.g., particle and veneer dryers) |
EU01, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU600, EU28, EU24, EU25, EU27, EU29, insignificant activities | ODEQ Method 8 | average of three one-hour test runs | ODEQ Method 8 is for sources with exhaust gases at essentially ambient conditions (e.g. material handling cyclones) | |
EU01, EU02, EU03, EU05, EU06, EU08, EU09, EU10,EU11, EU12,EU13, EU14,EU15, EU16, EU17, EU18, EU19, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU30, EU31, EU32, EU33, EU35, EU36, insignificant activities | 21, 22 | Modified Method 9 in accordance with the Department’s Source Sampling Manual | aggregate of three minutes in any 60 minute period | Each Method 9 observation shall represent a period of 15 seconds for the purpose of determining the aggregate amount of time in a 60 minute period that the visible emissions are greater than the opacity limit. The test duration may be less than 60 minutes if a violation of the standard is documented before the full 60 minute observation period is completed. |
EU600, EU24, EU25, EU27, EU37, EU38, insignificant activities | 12, 13 and 14 | EPA Method 13B and modified 14 |
NESHAP TESTING REQUIREMENTS
46. Compliance provisions under the Primary Aluminum Reduction NESHAP. [40 CFR 63.847]
46.a. Paste production plants. Initial compliance with the standards for existing paste production plants in condition 27.b will be demonstrated through site inspection(s) and review of site records by the applicable regulatory authority.
46.b. Test plan. The permittee shall prepare a site-specific test plan prior to the initial performance test according to the requirements of 40 CFR 63.7(c). The test plan must include procedures for conducting the initial performance test and for subsequent performance tests required in condition 65 for emission monitoring. In addition to the information required by 40 CFR 63.7, the test plan shall include:
46.b.i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each source;
46.b.ii. For multiple control devices on a single source, procedures to ensure that at least one run is performed annually for each control device by a representative sample of the stacks satisfactory to the applicable regulatory authority;
46.b.iii. Procedures for sampling single stacks associated with multiple anode bake furnaces;
46.b.iv. Procedures for establishing the frequency of testing to ensure that at least one run is performed before the 15th of the month, at least one run is performed after the 15th of the month, and that there are at least 6 days between two of the runs during the month, or that secondary emissions are measured according to an alternate schedule satisfactory to the applicable regulatory authority.
46.c. Initial performance test. Following approval of the site- specific test plan, the permittee shall conduct an initial performance test during the first month following the compliance date in accordance with the procedures in condition 46.d, unless a waiver of performance testing is obtained under 40 CFR 63.7(h) or the conditions of 40 CFR 63.7(c)(3)(ii)(B) apply. If a performance test has been conducted on the primary control system for potlines or for the anode bake furnace within the 12 months prior to the compliance date, the results of that performance test may be used to determine initial compliance. The Administrator may require the permittee to conduct performance tests at the affected source at any other time when the action is authorized by section 114 of the Act.
46.d. Performance test requirements. The initial performance test and all subsequent performance tests shall be conducted in accordance with the requirements of 40 CFR part 63 subpart A, the approved test plan, and the procedures in this permit.
46.d.i. TF emissions from potlines. For each potline, the permittee shall measure and record the emission rate of TF exiting the outlet of the primary control system and the rate of secondary emissions exiting through each roof monitor. Using the equation in condition 46.e.i, the permittee shall compute and record the average of at least three runs each 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 condition 27 or 28.
46.d.ii. Previous control device tests. If the permittee has performed more than one test of primary emission control device(s) for a potline or for a bake furnace during the previous consecutive 12 months, the average of all runs performed in the previous 12-month period shall be used to determine the contribution from the primary emission control system.
46.d.iii. TF and POM emissions from anode bake furnaces. The permittee shall measure and record the emission rate of TF and POM exiting the exhaust stack of the primary emission control system for the anode bake furnace. Using the equations in conditions 46.e.ii and 46.e.iii, the permittee shall compute and record the average of at least three runs each year to determine compliance with the applicable emission limits for TF and POM. Compliance is demonstrated when the emission rates of TF and POM are equal to or less than the applicable TF and POM emission limits in condition 27 or 28.
46.e. Equations. The permittee shall determine compliance with the applicable TF and POM emission limits using the following equations and procedures:
46.e.i. Compute the emission rate (Ep) of TF from each potline using Equation 1:
(Equation 1)
Where
Ep = emission rate of TF from a potline, kg/Mg (lb/ton);
Cs1 = concentration of TF from the primary control system, mg/dscm (mg/dscf);
Qsd = volumetric flow rate of effluent gas corresponding to the appropriate subscript location, dscm/hr (dscf/hr)\;
Cs2 = concentration of TF as measured for roof monitor emissions, mg/dscm (mg/dscf);
P = aluminum production rate, Mg/hr (ton/hr);
K = conversion factor, 106 mg/kg (453,600 mg/lb);
1 = subscript for primary control system effluent gas; and
2 = subscript for secondary control system or roof monitor effluent gas.
\ -For each potline,
Qsd1 = volumetric flow rate of effluent gas assigned to a potline, dscm/hr (dscf/hr);
P = aluminum production rate, Mg/hr (ton/hr);
46.e.ii. Compute the emission rate (Eb) of TF from the anode bake furnace using Equation 2,
(Equation 2)
Where:
Eb = emission rate of TF, kg/mg (lb/ton) of green anodes produced;
Cs = concentration of TF, mg/dscm (mg/dscf);
Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr);
Pb = quantity of green anode material placed in the furnace, mg/hr (ton/hr); and
K = conversion factor, 106 mg/kg (453,600 mg/lb).
46.e.iii. Compute the emission rate of POM from the anode bake furnace using Equation 2,
Where:
Cs = concentration of POM, mg/dscm (mg/dscf).
46.e.iv. Determine the weight of the aluminum tapped from the potlines and the weight of the green anode material placed in the anode bake furnace using the monitoring devices required in condition 65.h.
46.e.v. Determine the aluminum production rate (P) by dividing the number of hours in the calendar month into the weight of aluminum tapped from the potline during the calendar month that includes the three runs of a performance test.
46.e.vi. Determine the rate of green anode material introduced into the furnace by dividing the number of operating hours in the calendar month into the weight of green anode material used during the calendar month in which the performance test was conducted.
46.f. Selection of monitoring parameters. The permittee shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in condition 65.e.
46.f.i. For potlines and anode bake furnaces, the permittee shall determine upper and/or lower operating limits, as appropriate, for each monitoring device for the emission control system from the values recorded during each of the runs performed during the initial performance test and from historical data from previous performance tests conducted by the methods specified in this permit.
46.f.ii. For a paste production plant, the permittee shall specify and provide the basis or rationale for selecting parameters to be monitored and the associated operating limits for the emission control device.
46.f.iii. The permittee may redetermine the upper and/or lower operating limits, as appropriate, based on historical data or other information and submit an application to the applicable regulatory authority to change the applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory authority. [40 CFR 63.847]
47. Test methods and procedures under the Primary Aluminum Reduction NESHAP. [40 CFR 63.849]
47.a. The permittee shall use the reference methods from 40 CFR 63.849(a) to determine compliance with the applicable emission limits for TF and POM emissions, except as provided below in condition 47.d.
47.b. References to “potroom” or “potroom group” in Method 14 in appendix A to 40 CFR part 60 shall be interpreted as “potline” for the purposes of 40 CFR part 63 subpart LL.
47.c. For sampling using Method 14 in appendix A to 40 CFR part 60, the permittee shall install one Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to 40 CFR part 60.
47.d. The permittee may use an alternative test method for TF or POM emissions providing:
47.d.i. The permittee has already demonstrated the equivalency of the alternative method for a specific plant and has received previous approval from the Administrator or the applicable regulatory authority for TF or POM measurements using the alternative method; or
47.d.ii. The permittee demonstrates to the satisfaction of the applicable regulatory authority that the results from the alternative method meet the criteria specified in conditions 65.c.i and 65.c.iii through 65.c.vi. The results from the alternative method shall be based on simultaneous sampling using the alternative method and the following reference methods:
47.d.ii.1. For TF, Methods 13 and 14 or Method 14A in appendix A to 40 CFR part 60; or
47.d.ii.2. For POM, Method 315 in appendix A to 40 CFR part 63 and Method 14 in appendix A to 40 CFR part 60.
48. Performance testing requirements under the NESHAP General Provisions [40 CFR 63.7(d)]
48.a. Performance testing facilities. [40 CFR 63.7(d)]
If required to do performance testing, at the request of the Administrator, the permittee shall provide performance testing facilities as follows:
48.a.i. Sampling ports adequate for test methods applicable to such source. This includes:
48.a.i.1. Constructing the air pollution control system such that volumetric flow rates and pollutant emission rates can be accurately determined by applicable test methods and procedures; and
48.a.i.2. Providing a stack or duct free of cyclonic flow during performance tests, as demonstrated by applicable test methods and procedures;
48.a.ii. Safe sampling platform(s);
48.a.iii. Safe access to sampling platform(s);
48.a.iv. Utilities for sampling and testing equipment; and
48.a.v. Any other facilities that the Administrator deems necessary for safe and adequate testing of a source. [40 CFR 63.7(d)]
48.b. Conduct of performance tests. [40 CFR 63.7(e)]
48.b.i. Performance tests shall be conducted under such conditions as the Administrator specifies to the permittee based on representative performance (i.e., performance based on normal operating conditions) of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test, nor shall emissions in excess of the level allowed in conditions 26, 27, 28, 29, during periods of startup, shutdown, and malfunction be considered a violation of the relevant standard unless otherwise specified in the relevant standard or a determination of noncompliance is made under condition 29. Upon request, the permittee shall make available to the Administrator such records as may be necessary to determine the condition of performance tests.
48.b.ii. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in this permit, and, if required, in applicable appendices of 40 CFR parts 51, 60, 61, and 63 unless the Administrator--
48.b.ii.1. Specifies or approves, in specific cases, the use of a test method with minor changes in methodology; or
48.b.ii.2. Approves the use of an alternative test method, the results of which the Administrator has determined to be adequate for indicating whether a specific affected source is in compliance; or
48.b.ii.3. Approves shorter sampling times and smaller sample volumes when necessitated by process variables or other factors; or
48.b.ii.4. Waives the requirement for performance tests because the permittee has demonstrated by other means to the Administrator’s satisfaction that the affected source is in compliance with permit conditions.
48.b.iii. Unless otherwise specified in condition 46, 47, or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in this permit. For the purpose of determining compliance, the arithmetic mean of the results of the three runs shall apply. Upon receiving approval from the Administrator, results of a test run may be replaced with results of an additional test run in the event that--
48.b.iii.1. A sample is accidentally lost after the testing team leaves the site; or
48.b.iii.2. Conditions occur in which one of the three runs must be discontinued because of forced shutdown; or
48.b.iii.3. Extreme meteorological conditions occur; or
48.b.iii.4. Other circumstances occur that are beyond the owner or operator’s control.
48.b.iv. Nothing in conditions 48.b.i through 48.b.iii shall be construed to abrogate the Administrator’s authority to require testing under section 114 of the Act.
48.c. Use of an alternative test method. [40 CFR 63.7(f)]
The permittee remains subject to the requirements of condition 47 until permission to use an alternative test method has been granted by the Administrator under 40 CFR 63.7(f).
48.d. Data analysis, recordkeeping, and reporting. [40 CFR 63.7(g)]
48.d.i. Unless otherwise specified in this permit or test method or as otherwise approved by the Administrator, in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is “completed” when field sample collection is terminated. For each affected source, the permittee shall report the results of the performance test to the Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in this permit or as approved otherwise in writing by the Administrator [see 40 CFR 63.9(i)]. The results of the performance test shall be submitted as part of the notification of initial compliance status required under condition 90.c. The permittee shall send the results of the performance test to the Department.
48.d.ii. For a minimum of 5 years after a performance test is conducted, the permittee shall retain and make available, upon request, for inspection by the Administrator the records or results of such performance test and other data needed to determine emissions from an affected source.
MONITORING REQUIREMENTS
49. Upon initial startup of any potline, the permittee shall begin the monitoring as required by this permit. The permittee shall abide by approved startup procedures to minimize excess emissions when the facility is first beginning operation and during initial startup in accordance with OAR 340-028-1410 and condition G6.
Primary Aluminum Facility:
50. At least one time per calendar week, the permittee shall conduct a six (6) minute visible emission survey of the boundary of the active portion of the plant downwind from the emissions units using EPA Method 22 for monitoring pertaining to conditions 5 and 8 for the whole facility and condition 22 for emissions unit EU34. The person conducting this survey does not have to be EPA Method 9 certified. However, the individual should be familiar with the procedures of EPA Method 9 including using the proper location to observe visible emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions that leave the boundaries of the facility.
50.a. If visible emissions are detected at the property boundary for more than 5% (18 seconds) of the survey time, the permittee shall take the necessary corrective action to eliminate the visible emissions, or
50.b. Conduct an EPA Method 9 test in accordance with the Department’s Source Sampling Manual and condition 45 within 24 hours, unless weather conditions are such that it is not possible to read opacity.
50.c. The permittee shall record the corrective action taken or the results of the EPA Method 9 tests.
51. The permittee shall certify that the equipment was in place or maintain records that all the activities listed in condition 5 were performed for monitoring compliance as specified below:
EU ID | Work Practice | Monitoring
|
EU01, EU02, EU03 | storing collected material from CD01 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
requiring a particle size specification on the purchased coke | coke certificate | |
requiring application of a dedusting agent on the purchased coke | coke certificate | |
maintaining the storage building enclosure | certification | |
EU04, EU05, EU06, EU36 | storing collected material from CD04 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
requiring a particle size specification on the purchased coke | coke certificate | |
requiring application of a dedusting agent on the purchased coke | coke certificate | |
using the sealing system for batch car unloading | certification | |
using the batch car emissions minimization system during unloading | certification | |
EU07, EU08, EU09 | using the bake furnace draft system | certification |
using a screened particle size for the packing material | recordkeeping | |
EU10, EU11, EU12, EU13, EU14, EU15 | storing collected material from CD10N and CD10S, CD15S, CD15N, CD11, CD14, and CD12 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
EU16, EU17, EU18, EU19 | storing collected material from CD16 and CD19 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
Operate CD 19 baghouse whenever dry pots are being dug | ||
using a cold ram mix instead of hot ram | recordkeeping | |
EU20, EU21 | storing collected material from CD20 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
reducing the -20 µm fraction of alumina to less than 10% | alumina certificate | |
producing pressed green carbon anodes averaging at least 315 pounds on a daily basis | recordkeeping | |
using computers to control pot feeding operations unless manual feeding is required due to problems with computer pot feeding system | recordkeeping | |
EU600, EU28, EU24, EU25, EU27, EU37, EU38 | storing collected material from CD600, CD28A, CD28B, CD2C, CD3C, CD4C, CD5C, CD27B and CD27C, CD37, and CD38 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
EU29, EU30 | storing collected material from CD29 in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer | certification |
using a fugitive minimization system | certification |
52. The permittee shall maintain a log recording all written complaints, or complaints received via telephone or facsimile by the responsible official or a designated appointee, that specifically refer to a complaint of odor or fugitive emissions or opacity from the permitted facility for monitoring pertaining to conditions 5, 8, and 9. Documentation shall include the date of contact, time of observed nuisance condition, description of nuisance condition, location of receptor, and status of the plant operation during the observed period. The log shall also record permittee’s actions to investigate, make a determination as to the validity of the complaint, and resolve the problem within two (2) working days of receiving the complaint or within such longer time (not to exceed five (5) working days) as is reasonably necessary. If more than five (5) days are needed to resolve the problem, the permittee shall notify the Department within the five (5) day period. The permittee shall provide a response to the complainant within 24 hours of receipt of the complaint.
53. The permittee shall monitor the sulfur content of each batch (e.g., truck load, etc.) of oil received for monitoring pertaining to conditions 6 and 7:
53.a. obtaining a sulfur analysis certificate from the vendor for each batch; or
53.b. analyzing or having analyzed by a contract laboratory a monthly composite of representative samples taken by the permittee from each batch of fuel received. Liquid fuels shall be analyzed using ASTM D129-64, D1552-83, or D4057-81.
54. The permittee shall maintain monthly records of any changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes recorded in a maintenance log. [OAR 340-025-0285(1)(f)]
55. The permittee shall maintain the records required by 40 CFR Part 68, Accidental Release Prevention, for monitoring pertaining to condition 11.
Emissions Units:
56. Until the requirements of 40 CFR 63.843 are effective (for each individual potline or emissions unit), the permittee shall monitor visible emissions from emissions units EU07, EU20, EU21, and EU36 (upon installation) in accordance with the Department’s Source Sampling Manual, and the following procedures, test methods, and frequencies for monitoring pertaining to conditions 21 and 22: After the total fluoride emissions standards of 40 CFR 63.843 are effective (for each individual potline) the permittee shall monitor visible emissions from emissions units EU07, EU20, EU21, and EU36 (upon installation) in accordance with condition 65.f (NESHAPs monitoring).
56.a. The permittee shall conduct a six-minute visible emissions test of each monitoring point for emissions units EU07, EU20, EU21, and EU36 (upon installation) using EPA Method 9. If any one reading is greater than the applicable limits specified in conditions 21 or 22, the observation period shall continue for a minimum of 60 minutes total or until a violation of the applicable limit is documented, whichever is a shorter period. Condensed water vapor is not considered an emission for the purposes of this method.
56.a.i. The permittee shall conduct the visible emission tests/surveys each week day (Monday through Friday) of operation, excluding holidays, for the following emissions units:
Emissions Unit | Monitoring Point |
EU07 | CDP07 |
EU20 | CDP20 |
EU21 | CDP21 (rooms 4 and 22) |
EU36 | CDP36 (upon installation) |
56.a.ii. If the Method 9 tests show opacity within the applicable limits specified in conditions 21 and 22 for emissions units EU07, EU20, and EU36 only, the Method 9 tests need only be done once per week.
56.a.iii. If the Method 9 tests show opacity within the applicable limits specified in conditions 21 and 22 for at least 10 consecutive weeks for emissions units EU07, EU20, and EU36 only, the Method 9 tests need only be done once per month.
56.a.iv. The frequency for Method 9 tests for emissions unit EU21 shall remain at daily.
56.b. All visible emissions tests shall be conducted during operating conditions that have the potential to create visible emissions.
56.c. If an exceedance occurs, the test frequency for the affected monitoring point will start over with daily observations. If the Method 9 tests conducted during ten (10) consecutive observation days identify no visible emissions or emissions less than the applicable limit in conditions 21 and 22, the test frequency can go back to the same frequency as before the exceedance occurred.
56.d. If the observer is unable to conduct the daily Method 9 tests due to visual interferences caused by other visible emissions sources (e.g., fugitive emissions during high wind conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer shall note such conditions on the data observation sheet and make at least three attempts to conduct the tests at approximately 2 hour intervals throughout the day. If the visible emissions test could not be conducted on the regularly scheduled day due to interferences, the observer shall conduct the test on the following weekday.
56.e. Prior notification and a pre-test plan are not required to be submitted to the Department for each visible emissions survey or Method 9 test.
57. The permittee shall calculate and record total fluoride emissions for monitoring pertaining to conditions 12, 13, and 14 and total particulate emissions for monitoring pertaining to conditions 15 and 16, as follows: [OAR 340-025-0285]
57.a. For monitoring pertaining to conditions 12 and 13 for fluoride emissions the monthly average total emissions in lbs/TAP/month shall be calculated as sum of the contributions for emissions units EU07, EU20 and EU21 for a calendar month, divided by the total aluminum production in tons for the month. The contributions from each emissions unit shall be calculated in accordance with condition 57.c below.
57.b. For monitoring pertaining to condition 15 for particulate emissions, the monthly average total emissions in lbs/TAP/month shall be calculated as sum of the contributions for emissions units EU07, EU20 and EU21 (calculated in accordance with condition 57.c below) divided by the total aluminum production in tons for the month, and the contribution of emissions units EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU31, EU32, and EU33, calculated as the sum of the short term particulate matter emission factors in the table in condition 73.a.
57.c. For the following calculations, the permittee shall use the results of source testing performed in accordance with condition 44 and/or 46, for emissions units EU07, EU20, and EU21.
Carbon Bake Furnace
57.c.i. The permittee shall compute and record the carbon bake furnace’s contribution to monthly total fluoride ion from the average of all valid test runs performed in the previous 12-month period, to determine compliance with the total fluoride emissions limitations of conditions 12 and 13.
57.c.ii. After the total fluoride emissions standards of 40 CFR 63.843 are effective for EU07, the permittee shall compute and record the carbon bake furnace’s contribution to monthly particulate emissions, from the average of all valid test runs performed in the previous 12-month period, to determine compliance with the particulate emissions limitations of condition 15.
Potroom Dry Scrubber
57.c.iii. The permittee shall compute and record the potroom dry scrubber’s contribution to monthly total fluoride ion, from the average of all valid test runs performed in the previous 12-month period, to determine compliance with the total fluoride emissions limitations of conditions 12 and 13.
57.c.iv. After the total fluoride emissions standards of 40 CFR 63.843 are effective for the potroom dry scrubber, the permittee shall compute and record the potroom dry scrubber’s contribution to monthly total particulate emissions, from the average of all valid runs performed in the previous 12-month period for the potroom dry scrubber, EU20, to determine compliance with the particulate emissions limitations of condition 15.
Potroom Roof Vents
57.c.v. Until the total fluoride emissions standards of 40 CFR 63.843 are effective for a potline in EU21 (each individual line), the permittee shall compute and record each potline’s monthly contribution to total fluoride (average from at least three runs), to determine compliance with conditions 12 and 13. The permittee shall also compute and record each potline’s monthly contribution to total particulate emissions (average from at least three runs), to determine compliance with condition 15.
57.c.vi. After the total fluoride emissions standards of 40 CFR 63.843 are effective for EU21 (each individual line), and until conditions 12 and 13 are no longer effective, the permittee shall compute and record the potline 3 and 5 monthly contributions to total fluoride ion using the results of the compliance testing as scheduled and required by conditions 46.d and 47 (NESHAP testing), to determine compliance with the total fluoride emissions limitations of conditions 12 and 13.
57.c.vii. After the total fluoride emissions standards of 40 CFR 63.843 are effective for a potline in EU21, the permittee shall compute and record the potline monthly contribution to total particulate emissions using the results of the most recent compliance testing (average from at least three runs), to determine compliance with the particulate emissions limitations of condition 15. [OAR 340-025-0280]
57.d. The annual average total fluoride emissions in lbs/TAP/year shall be calculated as a 12-month rolling average. Each month the monthly total fluoride emissions, in units of lbs/TAP/month, shall be combined with the previous 11 months’ results and averaged to obtain lbs/TAP/year for monitoring pertaining to condition 14.
57.e. The annual average total particulate emissions in lbs/TAP/year shall be calculated as a 12-month rolling average of the monthly averages. Each month the monthly total particulate emissions in units of lbs/TAP/month, shall be combined with the previous 11 months of source test results and averaged to obtain lbs/TAP/year for monitoring pertaining to condition 16.
58. The permittee shall perform the particulate source testing required in condition 44 and/or 46 for monitoring pertaining to condition 17 for emissions units EU07, EU20, and EU21.
59. Until the total fluoride emissions standards of 40 CFR 63.843 are effective (for each individual potline), the permittee shall install, calibrate, maintain, and operate continuous air flow and alumina flow monitoring systems (CPMS) for the potroom baghouse complex, CD20, in accordance with the Department’s Continuous Monitoring Manual and the manufacturer’s written instructions for monitoring pertaining to conditions 12 through 17, 21, and 22. After the total fluoride emissions standards of 40 CFR 63.843 are effective (for each individual potline) the permittee shall operate the continuous monitors in accordance with condition 65.e. [OAR 340-028-0640]
59.a. The output of the system shall be recorded continuously. The permittee shall maintain an audible alarm on the potroom baghouse complex that sounds when the hourly average air flow or the hourly average alumina flow deviates from the approved parameter operating ranges.
59.b. The permittee shall also monitor and record deviations of airflow and alumina flow parameter operating ranges for CD20, and the corrective actions taken, recorded in a maintenance log.
60. The permittee shall maintain weekly records of inspection and maintenance procedures for the carbon bake wet ESP, CD07, contained in latest Department-approved Reynolds Metals’ Air Emissions Testing Quality Assurance Plan for monitoring pertaining to conditions 12 through 17, 21, and 22:
60.a. Inspection records of the date and time the device was inspected, recorded on inspection forms.
60.b. Inspection records of the date and time of the bi-weekly cleaning of the ESP plates, recorded on inspection forms.
60.c. Maintenance activity records of any preventative or corrective action taken as a result of the weekly inspections, recorded in a maintenance log. Maintenance activity records shall also include routine maintenance performed on an annual basis and occurrences when one ESP is shut down.
61. The permittee shall maintain annual records of inspection and maintenance procedures for monitoring pertaining to conditions 12 through 18, 21, and 22 for emissions units EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU36 (upon installation), and other baghouses or filter units installed after the issuance of this permit for an emission unit:
61.a. Inspection records of the baghouse bags and/or filter cartridges, recorded on inspection forms.
61.b. Maintenance activity records of replacement of baghouse bags and/or filter cartridges on occurrence (when damaged and/or routine replacement), recorded in a maintenance log.
62. The permittee shall install, calibrate, maintain, and operate a monitoring device for the measurement of the pressure drop of the gas stream through the baghouses and/or filter units listed below for monitoring pertaining to conditions 12 through 18, 21, 22, and 23 in accordance with the manufacturer’s written instructions. [OAR 340-028-0640]
62.a. The permittee shall record the pressure drop for the following devices on each day in operation: CD2C, CD3C, CD4C, CD5C, CD27B, CD27C, CD28A, and CD28B.
62.b. The permittee shall record the pressure drop for the following devices one time each week in operation: CD01, CD04, CD06, CD09, CD10N and CD10S, CD11, CD12, CD14, CD15S, CD15N, CD16, CD19, CD600, CD37, CD38, CD29, and, other baghouses or filter units controlling emissions from an emission unit, and installed after the issuance of this permit.
62.c. The permittee shall also monitor deviations of pressure drop from the operating ranges in the permittee’s operating plan, and the resulting corrective actions taken. Deviations and corrective actions shall be recorded in a maintenance log.
62.d. The permittee shall develop and maintain an operating plan for the control devices listed in condition 23. The operating plan shall include an operating range for each of the control devices. The operating ranges shall be determined based on the arithmetic average of monitoring data collected during at least a 90 day calendar period, plus and minus two standard deviations, or one standard deviation if the data is highly variable, and on manufacturer’s operating recommendations. The operating ranges shall be representative of highest and best practicable treatment and control. At least one time during the 90 day data collection period the permittee shall monitor visible emissions from each of the control devices for a minimum period of six minutes using EPA Method 22, and shall record the pressure drop immediately after the observations.
62.d.i. The permittee shall submit an operating plan to the Department for approval within 90 days after the effective date of this permit. With the plan the permittee shall submit the data and information used to determine each operating range, and the results of the visible emissions monitoring and the pressure drop readings. The operating ranges shall be effective upon submittal by the permittee.
62.d.ii. The permittee may redetermine the operating ranges, and submit a request to the Department to approve a new operating range. The revised limits shall become effective upon approval in writing by the Department.
62.d.iii. Revisions to the operating plan shall be made in accordance with condition 62.d.ii. No change that affects only the operating plan shall be considered a change, revision or modification to the permit.
63. The permittee shall maintain monthly and annual records of fuel type and total usage for monitoring pertaining to conditions 19 and 20 for emissions units EU31, EU32, and EU33.
64. The permittee shall maintain an audible alarm on the holding furnaces that sounds instantaneously when the furnace is being fluxed and the draft system is not operating for monitoring pertaining to conditions 15, 16, 21, and 22, and shall maintain records of occurrences of the alarm sounding, and corrective action taken.
NESHAPS MONITORING REQUIREMENTS
Monitoring
65. Emission monitoring requirements under the Primary Aluminum Reduction NESHAP. [40 CFR 63.848]
Until permission to use an alternative monitoring method has been granted by the Administrator under 40 CFR 63.8(f), the permittee remains subject to the following requirements.
65.a. TF emissions from potlines. Using the procedures in condition 46 and in the approved test plan, the permittee shall monitor emissions of TF from each potline by conducting monthly performance tests. The permittee shall compute and record the monthly 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. The permittee must include all valid runs in the monthly average. The duration of each run for secondary emissions must represent a complete operating cycle.
65.b. TF and POM emissions from anode bake furnaces. Using the procedures in condition 46 and in the approved test plan, the permittee shall monitor TF and POM emissions from each anode bake furnace on an annual basis. The permittee shall compute and record the annual average of TF and POM emissions from at least three runs to determine compliance with the applicable emission limits. The permittee must include all valid runs in the annual average.
65.c. Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline using the test methods in condition 47, the permittee may perform monthly monitoring of TF or POM secondary emissions from one potline using the test methods in condition 47.a to represent the performance of similar potline(s). The similar potline(s) shall be monitored using an alternative method that meets the requirements of conditions 65.c.i through 65.c.vii. Two or more potlines are similar if the permittee demonstrates that their structure, operability, type of emissions, volume of emissions, and concentration of emissions are substantially equivalent.
65.c.i. To demonstrate (to the satisfaction of the applicable regulatory authority) that the level of emission control performance is the same or better, the permittee shall perform an emission test using an alternative monitoring procedure for the similar potline simultaneously with an emission test using the applicable test methods. The results of the emission test using the applicable test methods must be in compliance with the applicable emission limit for existing potlines in condition 27. An alternative method:
65.c.i.1. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of particulate matter or particulate fluoride alone; and
65.c.i.2. For TF and POM emissions, must meet or exceed Method 14 criteria.
65.c.ii. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary emissions.
65.c.iii. If electing to use an alternative monitoring procedure, the permittee shall establish an alternative emission limit based on at least nine simultaneous runs using the applicable test methods and the alternative monitoring method. All runs must represent a full process cycle.
65.c.iv. The permittee shall derive an alternative emission limit for the HF continuous emission monitor or an alternative method using either of the following procedures:
65.c.iv.1. Use the highest value from the alternative method associated with a simultaneous run by the applicable test method that does not exceed the applicable emission limit; or
65.c.iv.2. Correlate the results of the two methods (the applicable test method results and the alternative monitoring method results) and establish an emission limit for the alternative monitoring system that corresponds to the applicable emission limit.
65.c.v. The permittee shall submit the results required in condition 65.c.iv and all supporting documentation to the applicable regulatory authority for review and approval.
65.c.vi. The regulatory authority shall review and approve or disapprove the request for an alternative method and alternative emission limit. The criterion for approval shall be a demonstration (to the satisfaction of the regulatory authority) that the alternative method and alternative emission limit achieve a level of emission control that is the same as or better than the level that would have otherwise been achieved by the applicable method and emission limit.
65.c.vii. If the alternative method is approved by the applicable regulatory authority, the permittee shall perform monthly emission monitoring using the approved alternative monitoring procedure to demonstrate compliance with the alternative emission limit for each similar potline.
65.d. Reduced sampling frequency. The permittee may submit a written request to the applicable regulatory authority to establish an alternative testing requirement to reduce the sampling of secondary TF emissions from potlines from monthly to quarterly.
65.d.i. In the request, the permittee shall provide information and data demonstrating, to the satisfaction of the applicable regulatory authority, that secondary emissions of TF from potlines have low variability during normal operations using the procedures in conditions 65.d.i.1 or 65.d.i.2.
65.d.i.1. Submit data from 24 consecutive months of sampling that show the average TF emissions are less than 60 percent of the applicable limit and that no monthly performance test in the 24 months of sampling exceeds 75 percent of the applicable limit; or
65.d.i.2. Submit data and a statistical analysis that the regulatory authority may evaluate based on the approach used in ``Primary Aluminum: Statistical Analysis of Potline Fluoride Emissions and Alternative Sampling Frequency’’ (EPA-450-86-012, October 1986), which is available from the National Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, VA 22161.
65.d.ii. An approved alternative requirement must include a test schedule and the method to be used to measure emissions for performance tests.
65.d.iii. Receiving approval of an alternative sampling frequency under 40 CFR 60.194 is deemed to have approval of the alternative sampling frequency under 40 CFR part 63 subpart LL.
65.d.iv. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under condition 65.d.i.1, the permittee shall return to monthly sampling for at least 12 months and may reduce to quarterly sampling when:
65.d.iv.1. The average of all tests performed over the most recent 24- month period does not exceed 60 percent of the applicable limit, and
65.d.iv.2. No more than one monthly performance test in the most recent 24-month period exceeds 75 percent of the applicable limit.
65.d.v. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under condition 65.d.i.2, the permittee shall immediately return to the monthly sampling schedule required by condition 65.a until another request for an alternative sampling frequency is approved by the applicable regulatory authority.
65.e. 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 permittee shall submit for approval by the regulatory authority a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how these relate to emission control also shall be submitted to the regulatory authority. The following monitoring devices shall be installed:
65.e.i. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;
65.e.ii. For dry coke scrubbers, devices for the measurement of coke flow and air flow;
65.e.iii. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;
65.e.iv. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and
65.f. 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.
65.g. 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.
65.h. Weight of aluminum and green anodes. The permittee shall install, operate, and maintain a monitoring device to determine the daily weight of aluminum produced and the weight of green anode material placed in the anode bake furnace. The weight of green anode material may be determined by monitoring the weight of all anodes or by monitoring the number of anodes placed in the furnace and determining an average weight from measurements of a representative sample of anodes.
65.i. Accuracy and calibration. The permittee shall submit recommended accuracy requirements to the regulatory authority for review and approval. All monitoring devices required by condition 65 must be certified by the owner or operator to meet the accuracy requirements and must be calibrated in accordance with the manufacturer’s instructions.
66. Monitoring Requirements of the NESHAPS General Provisions [40CFR 63.8]
66.a. Conduct of monitoring. [40 CFR 63.8(b)]
66.a.i. Monitoring shall be conducted as set forth in this condition unless the Administrator--
66.a.i.1. Specifies or approves the use of minor changes in methodology for the specified monitoring requirements and procedures; or
66.a.i.2. Approves the use of alternatives to any monitoring requirements or procedures.
66.a.ii.1. When the effluents from a single affected source, or from two or more affected sources, are combined before being released to the atmosphere, the permittee shall install an applicable CMS on each effluent.
66.a.iii. When more than one CMS is used to measure the emissions from one affected source (e.g., multiple breechings, multiple outlets), the permittee shall report the results as required for each CMS. However, when one CMS is used as a backup to another CMS, the permittee shall report the results from the CMS used to meet the monitoring requirements of 40 CFR part 63. If both such CMS are used during a particular reporting period to meet the monitoring requirements of this part, then the permittee shall report the results from each CMS for the relevant compliance period. [40 CFR 63.8(b)]
66.b. Operation and maintenance of continuous monitoring systems. [40 CFR 63.8(c)]
66.b.i. For any affected source, the permittee shall maintain and operate each CMS as follows and in a manner consistent with good air pollution control practices.
66.b.i.1. For any affected source, the permittee shall ensure the immediate repair or replacement of CMS parts to correct “routine” or otherwise predictable CMS malfunctions as defined in the source’s startup, shutdown, and malfunction plan required by 29.c. The permittee shall keep the necessary parts for routine repairs of the affected equipment readily available. If the plan is followed and the CMS repaired immediately, this action shall be reported in the semiannual startup, shutdown, and malfunction report required under condition 91.a.ii.
66.b.i.2. For those malfunctions or other events that affect the CMS and are not addressed by the startup, shutdown, and malfunction plan, the permittee shall report actions that are not consistent with the startup, shutdown, and malfunction plan within 24 hours after commencing actions inconsistent with the plan. The permittee shall send a follow-up report within 2 weeks after commencing actions inconsistent with the plan that either certifies that corrections have been made or includes a corrective action plan and schedule. The permittee shall provide proof that repair parts have been ordered or any other records that would indicate that the delay in making repairs is beyond his or her control.
66.b.i.3. The Administrator’s determination of whether acceptable operation and maintenance procedures are being used will be based on information that may include, but is not limited to, review of operation and maintenance procedures, operation and maintenance records, manufacturing recommendations and specifications, and inspection of the CMS. Operation and maintenance procedures written by the CMS manufacturer and other guidance also can be used to maintain and operate each CMS.
66.b.ii. All CMS shall be installed such that representative measurements of emissions or process parameters from the affected source are obtained.
66.b.iii. All CMS shall be installed, operational, and the data verified as specified in this permit either prior to or in conjunction with conducting performance tests under condition 46. Verification of operational status shall, at a minimum, include completion of the manufacturer’s written specifications or recommendations for installation, operation, and calibration of the system.
66.c. Reduction of monitoring data. [40 CFR 63.8(g)]
66.c.i. Data from CEMS, unless otherwise specified in this permit, shall be reduced to 1-hour averages computed from four or more data points equally spaced over each 1-hour period, except during periods when calibration, quality assurance, or maintenance activities pursuant to provisions of this part are being performed. During these periods, a valid hourly average shall consist of at least two data points with each representing a 15-minute period. Alternatively, an arithmetic or integrated 1-hour average of CEMS data may be used. Time periods for averaging are defined in 40 CFR 63.2.
66.c.ii. The data may be recorded in reduced or nonreduced form (e.g., ppm pollutant and percent O2 or Ng/J of pollutant).
66.c.iii. All emission data shall be converted into units of the relevant standard for reporting purposes using the conversion procedures specified in that standard. After conversion into units of the relevant standard, the data may be rounded to the same number of significant digits as used in that standard to specify the emission limit (e.g., rounded to the nearest 1 percent opacity).
66.c.iv. Monitoring data recorded during periods of unavoidable CMS breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level adjustments shall not be included in any data average computed.
COMPLIANCE ASSURANCE MONITORING (CAM) REQUIREMENTS
67. To satisfy the requirements of 340-028-1200 through 1280, the permittee shall monitor the indicators identified in condition 65.e for CD07 (Carbon Bake wet ESP), CD20 (Potroom Dry Scrubber), and CD36 (Anode Paste Scrubber), using the devices listed in condition 65.e. [OAR 340-028-1240(3)(a)]
68. The monitoring devices for CD07, CD20, and CD36 shall be installed, operated, calibrated, and maintained in accordance with condition 65.e, and the following performance criteria: [OAR 340-028-1210(a) and (c)]
68.a. CD07 Carbon Bake wet ESP
Location and installation specifications of monitoring device(s)
Continuous recording devices to record the voltage and current data from the ESP controllers shall be maintained at the ESP control room.
QA/QC
Calibration and calibration checks shall be performed on the recording device and the ESP controllers in accordance with the manufacturer’s instructions.
Data averaging period
The recorder shall collect a data point from the ESP controllers (voltage and current) every 60 seconds. The data shall then be averaged over 1 hour. The parameter being monitored shall be the 1-hour rolling average.
Frequency of data collection
The recorder shall collect a data point from the ESP controllers one time every 60 seconds. The data shall then be averaged over 1 hour.
Indicator ranges
The Indicator ranges shall be the operating limits determined in accordance with condition 46.f.
68.b. CD20 Potroom Dry Scrubber
Location and installation specifications of monitoring device(s)
The potroom alumina dry scrubber air flow meter shall be installed in the main stack. Continuous recording devices in the control room shall capture the data from the airflow-measuring device. Alumina flow meters shall be installed on the alumina feed for each baghouse group for each potline. Continuous recording devices in the control room shall capture this data.
QA/QC
Calibration and calibration checks shall be performed in accordance with the manufacturer’s instructions for the recording device, air flow meter, and alumina flow meters.
Data averaging period
The recorder shall record a data point from the flow meters one time every 60 seconds. The data shall then be averaged over 1 hour. The parameter being monitored shall be the 1-hour rolling average.
Frequency of data collection
The recorder shall collect a data point from the flow meters one time every 60 seconds. The data shall then be averaged over 1 hour.
Indicator ranges
The Indicator ranges shall be the operating limits determined in accordance with condition 46.f.
68.c. CD36 Anode Paste Scrubber
Location and installation specifications of monitoring device(s)
The anode paste scrubber air flow meter shall be installed in the main stack. Continuous recording devices in the control room shall capture the data from the airflow device. A coke flow meter shall be installed on the coke feed for the anode paste scrubber. Continuous recording devices in the control room shall capture this data.
QA/QC
Calibration and calibration checks shall be performed in accordance with the manufacturer’s instructions for the recording device, air flow meter, and coke flow meter.
Data averaging period
The recorder shall collect a data point from the flow meters one time every 60 seconds. The data shall then be averaged over 1 hour. The parameter being monitored shall be the 1-hour rolling average.
Frequency of data collection
The recorder shall collect a data point from the flow meters one time every 60 seconds. The data shall then be averaged over 1 hour.
Indicator ranges
The indicator ranges shall be the operating limits determined in accordance with condition 46.f, and the following:
The operating limits will be based on manufacturers data for the anode paste scrubber and the arithmetic mean plus and minus 2 standard deviations of the representative monitoring data for the first 3 months of operation.
68.d. The monitoring devices for CD07, CD20, and CD36 shall be installed and become operational in accordance with conditions 25 and 65.e. [OAR 340-028-1210(a) and (c)]
68.e. For the purposes of CAM, an exceedance shall be determined as defined in condition 65.g. [OAR 340-028-1240(3)(b)]
68.f. Minimum data availability shall be 90% for any month and year of operation. Data availability shall be determined excluding periods of calibrations and routine maintenance. [OAR 340-028-1240(3)(d)]
69. Proper maintenance. At all times, the owner or operator shall maintain the monitoring required for conditions 67 and 68, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment. [OAR 340-028-1250(2)]
70. Continued operation. Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the owner or operator shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the associated emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of condition 68, including data averages and calculations, or fulfilling a minimum data availability requirement, as applicable. The owner or operator shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. [OAR 340-028-1250(3)]
71. Response to excursions or exceedances: [OAR 340-028-1250(4)]
71.a. (a) Upon detecting an excursion or exceedance, the owner or operator shall restore operation of the associated emissions unit (including the control device and associated capture system) to its normal or usual manner of operation in accordance with condition 29.b and the permittee’s SSM plan required in condition 29.c as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions.
71.b. (c) Documentation of need for improved monitoring. After approval of monitoring under OAR 340-028-1200 through 340-028-1280, if the owner or operator identifies a failure to achieve compliance with an emission limitation or standard for which the approved monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing indicator ranges or designated conditions, the owner or operator shall promptly notify the Department and, if necessary, submit a proposed modification to the Oregon Title V Operating Permit to address the necessary monitoring changes. Such a modification may include, but is not limited to, reestablishing indicator ranges or designated conditions, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters.
72. Quality Improvement Plan [OAR 340-028-1260] When the accumulation of exceedances or excursions for CD07, CD20 or CD36 exceeds 240 hours (individually) during any Semi-annual Compliance Certification period, as defined in condition 86, the permittee shall prepare and implement a QIP in accordance with the requirements of OAR 340-028-1260. The QIP shall be submitted to the Department within 90 days of the end of the Semi-annual Compliance Certification Period.
PLANT SITE EMISSIONS LIMITS MONITORING
73. The permittee shall determine compliance with the Plant Site Emission Limits established in conditions 38 and 39 of this permit by conducting monitoring in accordance with the following procedures, test methods, and frequencies:
73.a. The permittee shall monitor and record the process parameters listed in the table below, on a daily, monthly and annual basis.
EU ID | Pollutant | Process Parameter | Units | Short Term | Annual | Units | EF Verification | |
EF | EF | Test Method | Frequency | |||||
EU01 | PM/PM10 | aluminum production | TAP | 0.007 | 0.006 | lb/TAP | Not required | |
EU02 | PM/PM10 | aluminum production | TAP | 0.036 | 0.031 | lb/TAP | Not required | |
EU03 | PM/PM10 | aluminum production | TAP | 0.008 | 0.007 | lb/TAP | Not required | |
EU04 | PM/PM10 | aluminum production | TAP | 0.031 | 0.026 | lb/TAP | Not required | |
EU05 | PM/PM10 | aluminum production | TAP | 0.28 | 0.238 | lb/TAP | Not required | |
VOC | aluminum production | TAP | 1.157 | 1.157 | lb/TAP | Not required | ||
EU06 | PM/PM10 | aluminum production | TAP | 0.01 | 0.008 | lb/TAP | Not required | |
EU07 | F | aluminum production | TAP | 0.048 | 0.045 | lb/TAP | Not required | |
CO | aluminum production | TAP | 10.213 | 8.683 | lb/TAP | EPA Method 10 | twice | |
PM/PM10 | aluminum production | TAP | 1.53 | 1.3 | lb/TAP | EPA Method 5 | once | |
SO2 | aluminum production | TAP | 0.191 | 0.195 | lb/TAP | EPA Method 6 or 6C | once | |
POM | aluminum production | TAP | TBD | TBD | lb/TAP | EPA Method 315 | once | |
EU08 | F | aluminum production | TAP | 0.021 | 0.021 | lb/TAP | Not required | |
CO | aluminum production | TAP | 0.102 | 0.086 | lb/TAP | EPA Method 10 | once | |
PM/PM10 | aluminum production | TAP | 0.159 | 0.135 | lb/TAP | Not required | ||
SO2 | aluminum production | TAP | 0.178 | 0.181 | lb/TAP | EPA Method 6 or 6C | once | |
EU09 | PM/PM10 | aluminum production | TAP | 0.02 | 0.017 | lb/TAP | Not required | |
EU10 | CO | aluminum production | TAP | 0.525 | 0.446 | lb/TAP | EPA Method 10 | once |
NOx | aluminum production | TAP | NA* | NA* | lb/TAP | EPA Method 7E | once | |
PM/PM10 | aluminum production | TAP | 0.026 | 0.022 | lb/TAP | Not required | ||
EU11 | PM/PM10 | aluminum production | TAP | 0.003 | 0.003 | lb/TAP | Not required | |
EU12 | PM/PM10 | aluminum production | TAP | 1.64E-04 | 1.39E-04 | lb/TAP | Not required | |
EU13 | CO | aluminum production | TAP | 0.053 | 0.045 | lb/TAP | Not required | |
PM/PM10 | aluminum production | TAP | 0.169 | 0.144 | lb/TAP | Not required | ||
EU14 | PM/PM10 | aluminum production | TAP | 0.015 | 0.013 | lb/TAP | Not required | |
EU15 | PM/PM10 | aluminum production | TAP | 0.003 | 0.003 | lb/TAP | Not required | |
EU16 | PM/PM10 | aluminum production | TAP | 0.002 | 0.001 | lb/TAP | Not required | |
EU17 | PM/PM10 | aluminum production | TAP | 0.008 | 0.007 | lb/TAP | Not required | |
EU19 | PM/PM10 | aluminum production | TAP | 0.002 | 0.001 | lb/TAP | Not required | |
EU20 | F | aluminum production | TAP | 1.803 | 1.168 | lb/TAP | EPA Method 13B | once |
CO | aluminum production | TAP | 197.95 | 168.29 | lb/TAP | modified EPA Method 10 | twice | |
NOx | aluminum production | TAP | NA* | NA* | lb/TAP | EPA Method 7E | once | |
PM/PM10 | aluminum production | TAP | 1.04 | 0.9 | lb/TAP | EPA Method 5 | once | |
SO2 | aluminum production | TAP | 61.311 | 62.551 | lb/TAP | EPA Method 6 or 6C | twice | |
EU21 | F | aluminum production | TAP | 1.633 | 1.148 | lb/TAP | EPA Method 13B and 14 | once |
CO | aluminum production | TAP | 6.311 | 5.366 | lb/TAP | EPA Method 10 | twice | |
PM/PM10 | aluminum production | TAP | 11.66 | 10.06 | lb/TAP | RMC Method or EPA Method 5 and 14 | twice | |
SO2 | aluminum production | TAP | 2.419 | 2.468 | lb/TAP | EPA Method 6 or 6C | twice | |
EU600 | PM/PM10 | aluminum production | TAP | 0.026 | 0.022 | lb/TAP | Not required | |
EU28 | PM/PM10 | aluminum production | TAP | 0.059 | 0.05 | lb/TAP | Not required | |
EU24 | PM/PM10 | aluminum production | TAP | 0.01 | 0.009 | lb/TAP | Not required | |
EU25 | PM/PM10 | aluminum production | TAP | 0.061 | 0.052 | lb/TAP | Not required | |
EU27 | PM/PM10 | aluminum production | TAP | 0.056 | 0.047 | lb/TAP | Not required | |
EU37 | PM/PM10 | aluminum production | TAP | 5.0E-04 | 4.0E-04 | lb/TAP | Not required | |
EU38 | PM/PM10 | aluminum production | TAP | 0.023 | 0.02 | lb/TAP | Not required | |
EU29 | PM/PM10 | aluminum production | TAP | 0.031 | 0.026 | lb/TAP | Not required | |
EU30 | PM/PM10 | aluminum production | TAP | 0.082 | 0.07 | lb/TAP | Not required | |
EU31 | CO | aluminum production | TAP | 0.208 | 0.177 | lb/TAP | Not required | |
NOx | aluminum production | TAP | 0.895 | 0.761 | lb/TAP | |||
PM/PM10 | aluminum production | TAP | 0.097 | 0.082 | lb/TAP | |||
VOC | aluminum production | TAP | 0.025 | 0.021 | lb/TAP | |||
EU32 | NOx | aluminum production | TAP | 0.23 | 0.02 | lb/TAP | Not required | |
PM/PM10 | aluminum production | TAP | 0.007 | 0.001 | lb/TAP | |||
EU33 | NOx | aluminum production | TAP | 0.328 | 0.028 | lb/TAP | Not required | |
PM/PM10 | aluminum production | TAP | 0.033 | 0.003 | lb/TAP | |||
SO2 | aluminum production | TAP | 1.23 | 0.105 | lb/TAP | |||
EU35 | PM/PM10 | aluminum production | TAP | 0.005 | 0.004 | lb/TAP | Not required | |
EU36** | PM/PM10 | aluminum production | TAP | 0.002 | 0.001 | lb/TAP | EPA Method 5 | once |
VOC | aluminum production | TAP | TBD | TBD | lb/TAP | EPA Method 25A, 25B | once | |
POM | aluminum production | TAP | TBD | TBD | lb/TAP | EPA Method 315 | once | |
EU39 | PM/PM10 | aluminum production | TAP | 0.005 | 0.005 | lb/TAP | Not required | |
EU40 | PM/PM10 | aluminum production | TAP | 0.001 | 0.001 | lb/TAP | Not required |
* The Department will be requiring NOx emission factor verification from the cast iron furnaces and potrooms.
** Upon installation. The Emissions factors for EU36 labeled TBD will be determined by source test after the initial source testing is complete. Until the emissions factors are determined, emissions shall be calculated using the EU05 emission factor.
*** These emissions factors are only effective until EU36 is installed and the emissions factors for EU36 are determined by source test.
73.b. For the emissions units listed in the table above, the permittee shall determine compliance with the short term and annual PSELs by multiplying the process parameter by the emission factor listed above for each pollutant. The calculation shall be done monthly for the short term PSEL and annually for the annual PSEL. The calculation shall be done daily for the daily VOC PSEL.
Where:
E = Emissions, pounds/day, tons/month or tons/year
Peu = Process parameter for each emissions unit, units/day,
Units/month or units/year
EFeu = Emission factor for each emissions unit, pounds/units
k = 1 lb/lb or 1 ton/2000 lbs
74. The permittee shall conduct emission factor verification tests in accordance with the Department’s Source Sampling Manual for the PM, CO, NOx, and VOC emission factors using the test methods and minimum test frequencies for the permit term listed above in condition 73.a.
74.a. When more than one test is required during the permit term, the tests shall be separated by a minimum period of one (1) year.
74.b. The testing required in condition 44 may be used to satisfy part of this requirement.
74.c. To measure sulfur dioxide emissions from emissions unit EU20, EU21, EU07, and EU08 the permittee shall perform one of the following:
74.c.i. a source test using EPA Method 6 or 6C, performed on EU20, EU21, EU07, and EU08, or
74.c.ii. a material balance using the following equation to calculate the SO2 emissions:
where
E = Emissions of sulfur dioxide, tons/month;
Al = Aluminum production, tons/month;
C = Net carbon consumption, tons C/ton Al; and
%S = Sulfur content of baked anodes, %
2 = 64 lbs SO2/mole,
32 lbs S/mole
0.37 = EF for EU07 and EU08, lb/ton.
74.c.ii.1. The net carbon consumption, C, shall be obtained from monthly records of net carbon consumption and aluminum production and shall be updated each month.
74.c.ii.2. The sulfur content of the baked anodes, %S, shall be measured monthly on a composite of daily anode samples, using a sulfur analyzer.
74.d. The permittee shall notify the Department at least 15 days prior to conducting any emission factor verification tests by submitting a source test plan in accordance with the Department’s Source Sampling Manual. The permittee is not required to submit a source test plan if a plan has already been approved for the emissions unit and the pollutant to be tested but should notify the Department at least 15 days prior to conducting the test.
74.e. 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:
74.e.i. emissions unit and monitoring point identification;
74.e.ii. emission factors in the same units as in the table above;
74.e.iii. emission results in pounds per hour;
74.e.iv. pertinent process parameters during the test (e.g., aluminum production, material throughput, types and amounts of fuels, heat input, etc.); and
74.e.v. control device operating parameters.
75. The emissions factors listed in condition 73.a are not enforceable limits unless otherwise specified in this permit. Compliance with PSELs shall only be determined by the calculations contained in condition 73.b of this permit using the measured process parameters recorded during the reporting period and the emission factors contained in condition 73.a.
76. The permittee shall maintain monthly and annual records of the amount of lubricating materials used on the casting tables in the casthouse. The VOC content of the materials shall be determined by material safety data sheets using the mid-value for VOC percentages.
77. One time per calendar year the permittee shall review the Quality Assurance Plan (QAP) and notify the Department of any significant changes. [OAR 340-025-0280(1)]
AMBIENT MONITORING REQUIREMENTS [OAR 340-025-0285]
78. The permittee shall monitor ambient air gaseous fluoride, as hydrogen fluoride in accordance with the latest Department-approved Reynolds Metals Air Emissions Testing Quality Assurance Plan for monitoring pertaining to condition 4. Monitoring shall be performed at station numbers 1 and 4 twice daily from April 1 through November 30. Monitoring may be suspended if none of the potlines are operating, upon written approval by the Department. The stations are identified as follows along with the distance from the plant: [340-025-0285, state-only enforceable]
STATION | NAME | LOCATION |
1 | West Air Station | 1.5 miles west of plant |
4 | East Air Station | 0.7 mile east of plant |
78.a. Hydrogen fluoride shall be measured using bi-carbonate tube method (ASTM D3268) using a 12-hour averaging period. The daily average shall be calculated from 12-hour arithmetic averages. The 30 day rolling average will be calculated only after the 30th calendar day following April 1 of each year.
RECORDKEEPING REQUIREMENTS [OAR 340-028-02130(3)(b)]
79. The permittee shall 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 data collection system recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All existing records required by the previous Air Contaminant Discharge Permit shall also be retained for five (5) years. The most recent 2 years of records must be retained at the facility. The remaining 3 years of records may be retained off site. The permittee may retain records on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche.
80. As applicable, the permittee shall maintain the following general records of required monitoring information:
80.a. the date, place as defined in the permit, and time of sampling or measurements;
80.b. the date(s) analyses were performed;
80.c. the company or entity that performed the analyses;
80.d. the analytical techniques or methods used;
80.e. the results of such analyses;
80.f. the pertinent operating conditions as existing at the time of sampling or measurement; and
80.g. the records of quality assurance for continuous monitoring systems.
81. The permittee shall maintain the following specific records of required monitoring information:
81.a. records of the operating plan required by condition 62.d;
81.b. records of monthly testing as required by conditions 43 and 44;
81.c. records of the weekly property boundary visible emissions survey as required by condition 50;
81.d. records of corrective action taken or EPA Method 9 testing performed as a result of visible emission surveys required by condition 50;
81.e. records maintained to monitor the performance of the work practice requirements, as required by condition 51;
81.f. complaint log and investigation reports, as required by condition 52;
81.g. records of the sulfur content of fuel oils received, as required by condition 53;
81.h. changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes, as required in condition 54;
81.i. records required by 40 CFR Part 68, Accidental Release Prevention, as required by condition 55;
81.j. records of the visible emissions surveys and tests as required by condition 56;
81.k. records of total fluoride emissions and calculations thereof as required by condition 57;
81.l. records of total particulate matter emissions, and calculations thereof as required by condition 57;
81.m. continuous monitoring records of the air flow and alumina flow for the potroom dry scrubber as required by condition 59;
81.n. records of deviations, corrective action taken, calibration, maintenance and operation (log) of the continuous monitors for the potroom dry scrubber, as required by condition 59;
81.o. records of inspection, maintenance and corrective action for the carbon bake wet ESP, as required by condition 60;
81.p. records of inspection, maintenance, corrective action of the baghouses for emissions units EU01, EU04, EU06, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU20, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29 and EU36 as required by condition 61;
81.q. daily records of baghouse pressure drop for baghouses CD2C, CD3C, CD4C, CD5C, CD27B and CD27C, CD28A, and CD28B as required by condition 62;
81.r. weekly records of baghouse pressure drop for baghouses CD01, CD04, CD06, CD09, CD10N and CD10S, CD11, CD12, CD14, CD15S, CD15N, CD16, CD19, CD600, CD29, CD37, and CD38 as required by condition 62;
81.s. records of deviations, corrective action taken, maintenance and operation (log) for baghouses CD2C, CD3C, CD4C, CD5C, CD27B and CD27C, CD28A, CD28B, CD01, CD04, CD06, CD09, CD10N and CD10S, CD11, CD12, CD14, CD15S, CD15N, CD16, CD19, CD600, CD29, CD37, and CD38, as required by condition 62;
81.t. daily and monthly records of the type and annual records of the amount of fuels used, for condition 63;
81.u. records of the occurrences of the holding furnace alarm sounding and corrective action taken as required by condition 64;
81.v. daily, monthly and annual records of process parameters required for PSEL calculations in condition 73;
81.w. daily, monthly, and annual Plant Site Emission Limit calculations for criteria pollutants, as required by condition 73;
81.x. records of emission factor verification testing as required by condition 74;
81.y. records of ambient monitoring as required by condition 78;
NESHAPS RECORDKEEPING REQUIREMENTS
82. Recordkeeping under the Primary Aluminum Reduction NESHAP. [40 CFR 63.10 and 63.850] The permittee shall maintain files of all information (including all reports and notifications) required by conditions 82.a through 82.c. Until the Administrator under 40 CFR 63.10(f) has granted a waiver of a recordkeeping requirement, the permittee of an affected source remains subject to the requirements of condition 82.
82.a. General recordkeeping requirements. [40 CFR 63.10(b)]
82.a.i. The permittee must retain each record for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The most recent 2 years of records must be retained at the facility. The remaining 3 years of records may be retained offsite;
82.a.ii. The permittee may retain records on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche;
82.a.iii. The permittee may report required information on paper or on a labeled computer disc using commonly available and compatible computer software; and
82.a.iv. For each affected source subject to the provisions of 40 CFR part 63 subpart LL, the permittee shall maintain relevant records for such source of--
82.a.iv.1. The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment);
82.a.iv.2. The occurrence and duration of each malfunction of the air pollution control equipment;
82.a.iv.3. All maintenance performed on the air pollution control equipment;
82.a.iv.4. 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 29.c];
82.a.iv.5. All information necessary to demonstrate conformance with the affected source’s startup, shutdown, and malfunction plan [see condition 29.c] 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);
82.a.iv.6. Each period during which a CMS is malfunctioning or inoperative (including out-of-control periods);
82.a.iv.7. All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to, 15-minute averages of CMS data and raw performance testing measurements, that support data that the source is required to report);
82.a.iv.8. All results of performance tests;
82.a.iv.9. All measurements as may be necessary to determine the conditions of performance tests;
82.a.iv.10. All CMS calibration checks;
82.a.iv.11. All adjustments and maintenance performed on CMS;
82.a.iv.12. 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 40 CFR 63.10(f);
82.a.iv.13. 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
82.a.iv.14. All documentation supporting initial notifications and notifications of compliance status under condition 90 and 40 CFR 63.9.
82.b. Additional recordkeeping requirements for sources with continuous monitoring systems. [40 CFR 63.10(c)] In addition to complying with the requirements specified in conditions 82.a.i through 82.a.iv, if using a CMS to demonstrate compliance with 40 CFR part 63 subpart LL for an affected source, the permittee shall maintain records for such source of--
82.b.i. All required CMS measurements (including monitoring data recorded during unavoidable CMS breakdowns and out-of-control periods);
82.b.ii. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks;
82.b.iii. The date and time identifying each period during which the CMS was out of control;
82.b.iv. 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 under condition 65, that occurs during startups, shutdowns, and malfunctions of the affected source;
82.b.v. 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;
82.b.vi. The nature and cause of any malfunction (if known);
82.b.vii. The corrective action taken or preventive measures adopted;
82.b.viii. The nature of the repairs or adjustments to the CMS that was inoperative or out of control;
82.b.ix. The total process operating time during the reporting period; and
82.b.x. In order to satisfy the requirements of conditions 82.b.vi through 82.b.viii 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 29.c, provided that such plan and records adequately address the requirements of conditions 82.b.vi through 82.b.viii. [40 CFR 63.10(c)]
82.c. In addition to the general records required by 82.a, the permittee shall maintain records of the following information: [40 CFR 63.850(e)(4)]
82.c.i. Daily production rate of aluminum;
82.c.ii. Daily production rate of green anode material placed in the anode bake furnace;
82.c.iii. A copy of the startup, shutdown, and malfunction plan;
82.c.iv. Records of design information for paste production plant capture systems;
82.c.v. 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;
82.c.vi. Records supporting a request for reduced sampling of potlines;
82.c.vii. Records supporting the correlation of emissions measured by a continuous emission monitoring system to emissions measured by manual methods and the derivation of the alternative emission limit derived from the measurements;
82.c.viii. The current implementation plan for emission averaging and any subsequent amendments;
82.c.ix. Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the exhaust stack for each control device has been performed as required in condition 65.f, including the results of each inspection;
82.c.x. For a potline equipped with an HF continuous emission monitor, records of information and data required by condition 82.b;
82.c.xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established under condition 46.f were exceeded, when visible emissions indicating abnormal operation were observed from a control device stack during a daily inspection required under condition 65.f.
82.c.xii. Records documenting any POM data that are invalidated due to the installation and startup of a cathode; and
82.c.xiii. 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. [40 CFR 63.850(e)]
REPORTING REQUIREMENTS [OAR 340-025-0285 AND 340-028-2130(3)(C)]
83. The permittee shall submit to the Department a report containing the following information within 30 days of the end of each calendar month:
83.a. Twelve-hour concentrations of gaseous fluoride, as hydrogen fluoride, in ambient air expressed in micrograms/cubic meter (mg/m3 or gr/scf) of air and parts per billion (ppb) at station numbers 1 and 4 (results of ambient monitoring as required by condition 78), but only during the period from April 1 through November 30, required by condition 78;
83.b. For the potrooms primary collection system emissions, CD20:
83.b.i. monthly particulate emissions, reported as pounds per ton of aluminum produced as required by condition 57. Particulate data shall be reported as total particulate and the percentage of fluoride ion;
83.b.ii. monthly fluoride emissions (total and gaseous fluoride), reported as pounds of fluoride ion per ton of aluminum produced, as required by condition 57;
83.c. For the potroom roof vent, EU21, emissions:
83.c.i. monthly particulate emissions, reported as pounds per ton of aluminum produced as required by condition 57. Particulate data shall be reported as total particulate and the percentage of fluoride ion;
83.c.ii. monthly fluoride emissions (total and gaseous fluoride), reported as pounds of fluoride ion per ton of aluminum produced, as required by condition 57;
83.d. For the carbon bake ESP, CD07, emissions:
83.d.i. monthly particulate emissions, reported as pounds per ton of aluminum produced as required by condition 57. Particulate data shall be reported as total particulate and the percentage of fluoride ion;
83.d.ii. monthly fluoride emissions (total and gaseous fluoride), reported as pounds of fluoride ion per ton of aluminum produced, as required by condition 57;
83.e. Total monthly average fluoride emissions, and annual average fluoride emissions, reported as pounds of fluoride ion per ton of aluminum produced, as required by condition 57;
83.f. Total monthly average particulate emissions, and annual average particulate emissions, reported as pounds of particulate per ton of aluminum produced, as required by condition 57;
83.g. Changes in collection efficiency of any portion of the collection or control system that resulted from equipment or process changes.
84. The permittee shall submit four (4) copies of the semi-annual monitoring report, using Department approved forms, by July 30, unless otherwise approved in writing by the Department. One copy of the report shall be submitted to the Air Quality Division, two copies to the regional office, and one copy to the EPA. The semi-annual monitoring report shall include the semi-annual compliance certification.
85. The permittee shall submit four (4) copies of the annual monitoring report, using Department approved forms, by February 15, unless otherwise approved in writing by the Department. One copy of the report shall be submitted to the Air Quality Division, two copies to the regional office, and one copy to the EPA.
86. The semi-annual certification periods for this facility are January 1 through June 30, and July 1 through December 31, unless otherwise approved in writing by the Department. [OAR 340-028-2130(3)(c)(A)]
87. With each semi-annual compliance certification, the permittee shall submit a CAM monitoring report for monitoring under conditions 67 and 68. The CAM monitoring report shall include, at a minimum, the following information:
87.a. Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken;
87.b. Summary information on the number, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable); and
87.c. If applicable, a description of the actions taken to implement a QIP during the reporting period. Upon completion of a QIP, the owner or operator shall include in the next summary report documentation that the implementation of the plan has been completed and reduced the likelihood of similar levels of excursions or exceedances occurring.
88. The annual monitoring report shall consist of:
88.a. specific annual reporting requirements:
88.a.i. annual records of fuels used;
88.a.ii. annual records of primary aluminum production;
88.a.iii. annual records of green carbon production;
88.a.iv. quantities and sulfur content (percent by weight) of the baked anodes on a monthly basis;
88.a.v. hours of operation;
88.b. the emission fee report, OAR 340-028-2650;
88.c. the excess emissions upset log, OAR 340-028-1440; and
88.d. the second semi-annual compliance certification, OAR 340-028-2160.
88.e. the annual notification of changes to the QAP, as required by condition 77.
89. Other reporting requirements include emission factor verification testing summaries for the year in which testing is done.
NESHAPS NOTIFICATION AND REPORTING REQUIREMENTS
90. Notifications required under the Primary Aluminum Reduction Plants NESHAP. [40 CFR 63.850 and 40 CFR 63.9]
The permittee shall submit the following written notifications:
90.a. After October 7, 1997, if the permittee intends to construct a new affected source or reconstruct an affected source subject to 40 CFR part 63 subpart LL, or reconstruct a source such that it becomes an affected source subject to such standard, the permittee shall notify the Administrator, in writing, of the intended construction or reconstruction. The notification shall be submitted as soon as practicable before the construction or reconstruction is planned to commence. The notification shall include all the information required for an application for approval of construction or reconstruction as specified in 40 CFR 63.5(d). The application for approval of construction or reconstruction may be used to fulfill the requirements of this condition. [40 CFR 63.9(b)(5) and 63.850(a)(4)]
90.b. Notification of initial performance test. [40 CFR 63.9(e) and 63.850(a)(5)]
90.b.i. For each affected source, the permittee shall notify the Administrator in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is scheduled to begin to allow the Administrator, upon request, to review and approve the site-specific test plan required under condition 46.b and to have an observer present during the test. Observation of the performance test by the Administrator is optional.
90.b.ii. In the event the permittee is unable to conduct the performance test on the date specified in the notification requirement specified in condition 90.b.i, due to unforeseeable circumstances beyond his or her control, the permittee shall notify the Administrator within 5 days prior to the scheduled performance test date and specify the date when the performance test is rescheduled. This notification of delay in conducting the performance test shall not relieve the permittee of legal responsibility for compliance with any other applicable provisions of this part or with any other applicable Federal, State, or local requirement, nor will it prevent the Administrator from implementing or enforcing this part or taking any other action under the Act.
90.c. Notification of initial compliance status. [40 CFR 63.9(h) and 63.850(a)(6)] The permittee shall submit to the Department and the Administrator a notification of compliance status, signed by the responsible official who shall certify its accuracy, attesting to whether the source has complied with 40 CFR part 63 subpart LL. The notification shall be sent before the close of business on the 60th day following the completion of the relevant initial compliance demonstration activities specified in condition 46. For example, the notification shall be sent before close of business on the 60th (or other required) day following completion of the initial performance test and again before the close of business on the 60th(or other required) day following the completion of any subsequent required performance test. The notification shall list:
90.c.i. The methods that were used to determine compliance;
90.c.ii. The results of any performance tests, visible emission observations, and/or other monitoring procedures or methods that were conducted;
90.c.iii. The methods that will be used for determining continuing compliance, including a description of monitoring and reporting requirements and test methods;
90.c.iv. The type and quantity of hazardous air pollutants emitted by the source, reported in units and averaging times and in accordance with the test methods specified in this permit;
90.c.v. An analysis demonstrating whether the affected source is a major source or an area source (using the emissions data generated for this notification);
90.c.vi. A description of the air pollution control equipment (or method) for each emission point, including each control device (or method) for each hazardous air pollutant and the control efficiency (percent) for each control device (or method); and
90.c.vii. A statement by the permittee as to whether each affected source has complied with the relevant standard or other requirements.
90.d. If the permittee submits estimates or preliminary information in the application for approval of construction or reconstruction required in 40 CFR 63.5(d) in place of the actual emissions data or control efficiencies required in 40 CFR 63.5(d)(1)(ii)(H) and (d)(2), the permittee shall submit the actual emissions data and other correct information as soon as available but no later than with the notification of initial compliance status. [40 CFR 63.9(h)(5)]
90.e. The permittee shall submit a one-time notification for each affected source of the intent to use an HF continuous emission monitor. [40 CFR 63.850(a)(7)]
90.f. Notification of compliance approach. [40 CFR 63.850(a)(8)] 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 27 and 28.
90.g. Change in information already provided. [40 CFR 63.9(j)] Any change in the information already provided under this condition 90 shall be provided to the Administrator in writing within 15 calendar days after the change.
91. NESHAP Reporting requirements. Until a waiver of a reporting requirement has been granted by the Administrator under 40 CFR 63.10(f), the permittee of an affected source remains subject to the requirements of condition 91.
91.a. Reporting requirements under the NESHAP General Provisions. [40 CFR 63.10(d)]
91.a.i. Progress reports. If required to submit progress reports for an affected source as a condition of receiving an extension of compliance under 40 CFR 63.6(i), the permittee shall submit such reports to the Administrator (or the State with an approved permit program) by the dates specified in the written extension of compliance.
91.a.ii. 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 29.c], 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 this part, 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) 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 40 CFR 63.10(e), 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 allowance in the preceding sentence shall be the same as the procedures specified in condition 40 CFR 63.10(e)(3).
91.a.iii. Immediate startup, shutdown, and malfunction reports. Notwithstanding the allowance to reduce the frequency of reporting for periodic startup, shutdown, and malfunction reports under condition 91.a.ii, 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 owner or operator 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 40 CFR 63.9(i).
91.b. Additional reporting requirements for sources with continuous monitoring systems.
91.b.i. General. When more than one CEMS is used to measure the emissions from one affected source (e.g., multiple breechings, multiple outlets), the permittee shall report the results as required for each CEMS.
91.b.ii. Excess emissions report. 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.
Reporting requirements under the Primary Aluminum Reduction NESHAP
91.c. Performance test reports. The permittee shall report the results of the initial performance test as part of the notification of initial compliance status required in condition 90.c. Except as provided in condition 91.b.ii, 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)]
91.d. Startup, shutdown, and malfunction plan and reports. The permittee shall develop and implement a written plan as described in condition 29.c 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. The plan does not have to be submitted with the permit application or included in the operating permit. The permitting authority may review the plan upon request. In addition to the information required condition 29.c, the plan shall include:
91.d.i. Procedures, including corrective actions, to be followed if a monitoring device measures an operating parameter outside the limit(s) established under condition 46.f, 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 65.f, and
91.d.ii. The permittee shall also keep records of each event as required by condition 82.a and record and report, as required in conditions 91.a.ii and 91.a.iii, if an action taken during a startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in condition 29.c.iv. [40 CFR 63.850(c)]
92. Addresses of regulatory agencies are the following, unless otherwise instructed:
DEQ-Northwest Region DEQ-Air Quality Division Air Operating Permits
2020 SW 4th Ave., #400 811 SW Sixth Ave. US Environmental Protection Agency
Portland, OR 97201 Portland, OR 97204 1200 Sixth Avenue M/S OAQ-108
(503) 229-5263 (503) 229-5359 Seattle, WA 98101
93. Notwithstanding general condition G6.a of this permit, the permittee shall make initial report of excess emissions due to startup, shutdown, maintenance, breakdown or upset condition other than those due to pre-approved startup, shutdown, or scheduled maintenance, to the Department within 24 hours after the permittee becomes aware of the excess emission. [OAR 340-028-1430(2)(a)
NON-APPLICABLE REQUIREMENTS [OAR 340-028-2190]
Air quality Oregon Administrative Rules and federal rules currently determined not applicable to the permittee are listed below:
94. The following OARs are not applicable because the source is not in the source category cited in the rules:
340-022-0104 through 340-022-0403, 340-022-0460 through 340-022-0640,
340-024-0025, 340-024-0306,
340-025-0015 through 340-025-0234, 340-025-0310 through 340-025-0430, 340-025-0535 through 340-025-0608, 340-025-0610 through 340-025-0735, 340-025-0850 through 340-025-0905
340-028-0500 through 340-028-0520, 340-028-0800 through 340-028-0820, 340-028-1040, 340-028-2170, 340-028-2180,
340- Division 31,
340-032-0250, 340-032-0300 to 340-032-0380, 340-032-0500, 340-032-5000, 340-032-5510, 340-032-5530 through 340-032-5585.
95. The following OARs are not applicable because the source does not have specific emissions units cited in the rules:
340-021-0040,
340-022-0055, 340-022-0415,
340-025-0265(3)(b),
340-028-1030.
96. The following OARs are not applicable because the source is outside the special control area, non-attainment area or county cited in the rules:
340-021-0200 through 340-021-0245
340-025-0270,
340-030-0012 through 340-030-0230, 340-030-0600 through 340-030-0620.
97. The following OARs are not applicable because the source does not burn the fuel type cited in the rules:
340-022-0010, 340-022-0020.
98. The following OARs are not applicable because the rules applied in the past and the fees have been paid:
340-028-2400 through 340-028-2550, 340-028-2570.
99. The following OARs are not applicable because the source was constructed before January 1, 1973:
340-025-0265(1), 340-025-0265(2), 340-025-0280(2).
100. The following OARs are not applicable because the source made no changes that would trigger the rule procedural requirements:
340-025-0609, 340-025-0800, 340-025-0805,
340-032-4500.
101. Federal applicable requirements currently determined not applicable to the permittee because the source is not in the source category are listed below:
40 CFR Part 55,
40 CFR Part 57,
40 CFR Part 60 (except subpart A and appendices),
40 CFR Part 61 (except subparts A and M and appendices),
40 CFR Part 63 (except subparts A, LL, and appendices),
40 CFR Parts 72, 73, 75, 76, 77, and 78,
40 CFR Part 82 (except subpart F),
40 CFR Parts 85 through 89,
Section 129 of the FCAA, Solid Waste,
Section 183(e) of the FCAA, Consumer and commercial products,
Section 183(f) of the FCAA, Tank Vessels.
GENERAL CONDITIONS
G1. General Provision
Terms not otherwise defined in the permit shall have the meaning assigned to such terms in the referenced regulation.
G2. Reference materials
Where referenced in this permit, the version of the following materials are effective as of the dates noted unless otherwise specified in the 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 340-028-2120(3)(n)(C), 340-028-2130(6), and 340-028-2160(4)]
a. The permittee shall comply with all conditions of the federal operating 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 shall be supplemental to, and shall 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 shall meet such requirements on a timely basis unless a more detailed schedule is expressly required by the applicable requirement.
G4. Compliance Monitoring and Enforcement [OAR 340-028-0300, 340-028-1100, 340-028-1120, 340-028-1130, 340-028-1140, 340-028-2130(3), 340-028-2160, 340-032-0270]
a. For the purpose of submitting semi-annual compliance certification reports, the permittee shall use, at a minimum, the information obtained from the monitoring requirements of this permit. The permittee shall not knowingly falsify or render inaccurate any monitoring device or method required to be maintained or followed by the permit.
b. The information obtained from the monitoring required by this permit can be used directly for enforcement except as otherwise provided by this permit.
G5. Certification [OAR 340-028-0300, 340-028-2120(5), 340-028-2130(3)(d), and 340-028-2160(2)]
Any document submitted to the Department pursuant to this permit shall contain certification by a responsible official of truth, accuracy and completeness. All certifications shall 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 shall promptly, upon discovery, report to the Department a material error or omission in these records, reports, plans, or other documents.
G6. Excess Emissions Reporting [OAR 340-028-1400 through 340-028-1460]
a. The permittee shall report all excess emissions in accordance with OAR 340-028-1400 through 340-028-1460. In summary, the permittee shall immediately (i.e., as soon as possible but in no case more than one hour after the beginning of the 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 shall, 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 shall be made in accordance with Department direction and OAR 340-028-1430(2) and 340-028-1440.
b. Notification shall be made to the appropriate regional office. Current Departmental telephone numbers are:
Portland (503) 229-5554 Medford (541) 776-6010
Bend (541) 388-6146 Pendleton (541) 276-4063
Salem (503) 378-8240
c. 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 shall immediately notify the Department by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.
d. If startups, shutdowns, or scheduled maintenance may result in excess emissions, the permittee shall submit startup, shutdown, or scheduled maintenance procedures used to minimize excess emissions to the Department for prior authorization, as required in OAR 340-028-1410 and 340-028-1420. New or modified procedures shall be received by the Department in writing at least 72 hours prior to the first occurrence of the excess emission event. The permittee shall abide by the approved procedures and have a copy available at all times.
e. The permittee shall 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.
f. The permittee shall maintain and submit to the Department a log of planned and unplanned excess emissions, on Department approved forms, in accordance with OAR 340-028-1440.
G7. Permit Deviation Reporting [OAR 340-028-2130(3)(c)(B)]
The permittee shall promptly report, by telephone or in person, any 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 preventative measures taken. Deviations are instances when any permit condition is violated. “Prompt” is defined as within seven (7) days of the deviation.
G8. Open Burning [OAR Chapter 340, Division 023]
The permittee is prohibited from conducting open burning, except as may be allowed by OAR 340-023-0025 through 340-023-0115.
G9. Asbestos [40 CFR Part 61, Subpart M (federally enforceable), OAR 340-032-5600 through 340-032-5650 and OAR Chapter 340, Division 033 (state-only enforceable)]
The permittee shall comply with OAR 340-032-5600 through 340-032-5650, OAR Chapter 340 Division 033, and 40 CFR Part 61, Subpart M when conducting any renovation or demolition activities at the facility.
G10. Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-022-0420]
The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, Recycling and Emissions Reduction.
G11. Permit Shield [OAR 340-028-2190]
a. Compliance with the conditions of the permit shall be 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 shall alter or affect 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 340-028-2230(1)(h), or significant permit modification.
G12. Inspection and Entry [OAR 340-028-2160(3)]
Upon presentation of credentials and other documents as may be required by law, the permittee shall 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.
G13. Fee Payment [OAR 340-028-2560, and 340-028-2580 through 340-028-2740]
The permittee shall 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 shall 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 shall be submitted in writing to the Department of Environmental Quality. Payment shall be made regardless of the dispute. User-based fees shall be charged for specific activities (e.g., computer modeling review, ambient monitoring review, etc.) requested by the permittee.
G14. Off-Permit Changes to the Source [OAR 340-028-2220(2)]
a. The permittee shall 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 340-028-0110.
b. A contemporaneous notification, if required under OAR 340-028-2220(2)(b), shall be submitted to the Department and the EPA.
c. The permittee shall 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 G11 shall not extend to off-permit changes.
G15. Section 502(b)(10) Changes to the Source [OAR 340-028-2220(3)]
a. The permittee shall 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 shall be submitted to the Department and the EPA in accordance with OAR 340-028-2220(3)(b).
c. The permit shield of condition G11 shall not extend to section 502(b)(10) changes.
G16. Administrative Amendment [OAR 340-028-2230]
Administrative amendments to this permit shall be requested and granted in accordance with OAR 340-028-2230. The permittee shall 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.
G17. Minor Permit Modification [OAR 340-028-2250]
The permittee shall submit an application for a minor permit modification in accordance with OAR 340-028-2250.
G18. Significant Permit Modification [OAR 340-028-2260]
The permittee shall submit an application for a significant permit modification in accordance with OAR 340-028-2260
G19. Construction/Operation Modification [OAR 340-028-2270 and 340-032-0230 (state only)]
No permittee shall construct or make modifications required to be reviewed under OAR 340-028-2270 and 340-032-0230 (HAP sources only), the construction/operation modification rules, without receiving a Notice of Approval in accordance with OAR 340-028-2270. The permittee should allow 60 days for Department review of applications for a construction/operation modification if public notice is not required, or 180 days if public notice is required.
G20. New Source Review Modification [OAR 340-028-1900]
No permittee shall construct or make modifications required to be reviewed under New Source Review (OAR 340-028-1900(1)) without receiving an Air Contaminant Discharge Permit (ACDP) (OAR 340-028-1700). The permittee should allow 180 days for Department review of an ACDP application for New Source Review.
G21. Need to Halt or Reduce Activity Not a Defense [OAR 340-028-2130(6)(b)]
It shall 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 340-028-2130(6)(e) and OAR 340-028-300]
The permittee shall 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 shall also furnish to the Department copies of records required to be retained by the permit.
G23. Reopening for Cause [OAR 340-028-2130(6)(c) and 340-028-2280]
a. The permit may be modified, revoked, reopened and reissued, or terminated for cause as determined by the Department.
b. 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.
c. A permit shall be reopened and revised under any of the circumstances listed in OAR 340-028-2280(1)(a).
d. Proceedings to reopen and reissue a permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts of the permit for which cause to reopen exists.
G24. Severability Clause [OAR 340-028-2130(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 340-028-2120(1)(a)(D) and 340-028-2210]
a. This permit shall expire at the end of its term. Permit expiration terminates the permittee’s right to operate unless a timely and complete renewal application is submitted as described below.
b. Applications for renewal shall 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 shall provide no less than six (6) months for the owner or operator to prepare an application. Provided the permittee submits a timely and complete renewal application, this permit shall remain in effect until final action has been taken on the renewal application to issue or deny the permit.
G26. Permit Transference [OAR 340-028-2230(1)(d)]
The permit is not transferable to any person except as provided in OAR 340-028-2230(1)(d).
G27. Property Rights [OAR 340-028-0110(9)(c) and 340-028-2130(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 340-028-2190.
G28. Permit Availability [OAR 340-028-0110(9)(c) and 340-028-2200(2)]
The permittee shall have available at the facility at all times a copy of the Oregon Title V Operating Permit and shall provide a copy of the permit to the Department or an authorized representative upon request.
ALL INQUIRIES SHOULD BE DIRECTED TO:
Department of Environmental Quality
Northwest Region
2020 SW 4th Ave., Suite 400
Portland, OR 97201-4987
(503) 229-5263
26-1851P.doc
RDB: DPK
October 8, 2025