Department of Environmental Quality

Air Quality Division

OREGON TITLE V OPERATING PERMIT APPLICATION REVIEW REPORT

Reynolds Metals Company

5100 NE Sundial Road

Troutdale, OR 97060

TABLE OF CONTENTS

FACILITY/OPERATING SCENARIO DESCRIPTION  2

PERMITTED ACTIVITIES  11

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION  11

EMISSION LIMITS STANDARDS  13

PLANT SITE EMISSION LIMITS  17

HAZARDOUS AIR POLLUTANTS  21

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT)  22

STRATOSPHERIC OZONE-DEPLETING SUBSTANCES  23

TESTING Requirements  23

MONITORING REQUIREMENTS  25

Compliance Assurance Monitoring  28

GENERAL BACKGROUND INFORMATION  32

COMPLIANCE HISTORY  33

PUBLIC NOTICE  34

PERMITTEE IDENTIFICATION

1.  Reynolds Metals Company (RMC) operates a center work pre-bake (CWPB) primary aluminum plant located on Sundial Road in Troutdale, Oregon. The capacity of the plant is approximately 143,500 tpy aluminum produced in the potrooms and approximately 170,000 tpy aluminum alloy cast in the casting facility. The plant has five pot lines with each pot line containing 140 pots (2 rows of 70 pots with each row housed in a pot room). Four of the potlines were constructed with original facility in 1941. Potline #5 was constructed in 1970, and is not subject to the New Source Performance Standard (NSPS) promulgated in 1974. Potline #5 was initially started up October 8, 1972. This followed a complete shutdown of the facility from November 26, 1971 to September 1 1972, due to market conditions.

FACILITY/OPERATING SCENARIO DESCRIPTION

2.  The major processes include:

Ø  carbon facility producing baked carbon from recycled spent carbon, coke, and coal tar pitch (anode paste plant, 3 bakes (rooms));

Ø  reduction facility producing molten aluminum from alumina ore and baked carbon (10 rooms of 70 pots each); and

Ø  casting facility producing alloyed sheet, foundry, and unalloyed cast products (4 sheet furnaces, 2 foundry furnaces).

A refined high purity alumina ore (Al₂O₃) is electrochemically reduced to aluminum in the reduction facility which consists of 700 cells (or pots). The reaction also involves the generation of CO₂ from the oxidation of carbon. The amount of aluminum produced is proportional to the amperage passed through the cell and the current efficiency of the cell. The reaction between carbon and alumina takes places in a molten bath consisting of cryolite (Na₃AlF₆) and various additives (AlF₃, LiF, MgF₂, CaF₂). The carbon is produced in the carbon plant in the form of prebaked blocks which are replaced in the cells as they are consumed. Due to the density of aluminum, it settles to the bottom of cell where it is siphoned off periodically and sent to the casthouse for possible alloying and casting.

The controlling reaction is:

       _amperage

 2 Al₂O₃ (dissolved) + 3 C (s) =======> 4 Al + 3 CO₂.

           ^{molten bath}

CARBON PLANT OVERVIEW

The carbon plant utilizes calcined coke, recycled carbon (butts), and a coal tar or petroleum pitch as raw materials. The coke and recycled butts are sized into fractions and weighed out, mixed with molten pitch, and formed in hydraulic presses. The blocks are baked to approximately 1,100°C, cleaned and sent to the rodding room for attachment of copper rods used to mount the carbon block in the cell and conduct the current necessary for the reaction to take place.

A) CARBON PLANT UNLOADING DOCK - PROCESS P01

Calcined coke purchased from outside vendors is unloaded from railcars. The material is moved via enclosed belts, screws, and elevators to storage silos inside the mill for later use. If insufficient capacity in the silos exists to unload the railcars, the material is stored in piles inside a storage building from where it can later be loaded into the same material handling system. The coke is purchased with a "dedusting" agent added to it. In addition, a baghouse system ventilates the unloading equipment and material handling system in the area of the coke dock.

Solid "pencil pitch" (usually arriving via trucks), is unloaded into the same material handling systems. It can also be stored in piles inside the storage building for later use.

   EU01 - COKE UNLOADING DOCK VENTILATION (PM/PM₁₀)

   EU02 - COKE UNLOADING DOCK (PM/PM₁₀)

   EU03 - COKE & PITCH STORAGE BUILDING (PM/PM₁₀)

B) ANODE PASTE PLANT - PROCESS P02

The anode paste plant serves to size the coke and recycled carbon (butts) into four fractions which are then mixed with the optimal amount of pitch necessary to coat the material and bind it together. The coke/butt fractions are mixed with molten pitch and pressed at approximately 2,400 psi in hydraulic presses into block form.

The coke is moved from storage silos through enclosed, ventilated, screws, elevators, and redlers (drag chain like device used in the anode paste plant to move coke or pitch from one point to another along a horizontal plane) through a sizing system which crushes the material in hammer mill(s), screens it and sends it to storage tanks (1st fraction). The overflow is recrushed, while the underflow is ground in a ball mill and moved to a separate group of storage silos (2nd fraction).

The recycled carbon (butts) are shaken to remove bath material to later reduce fluoride emissions in the bake, crushed, sized and transferred to another group of storage silos (3rd fraction).

The dust from the crushing and handling operations is collected in a cyclone/baghouse and mixed back into the ball mill fraction where it serves as a "super fine" fraction of the mix (4th fraction).

The fractions of coke/butts and pitch are weighed out on scales and transferred to steam heated mixers. The mixers serve to melt the solid pitch, coating the coke particles and forming a paste like substance. This paste is cooled to about 120°C and pressed into blocks with hydraulic presses.

The anode paste plant also has the capability of sizing packing material coke used in the bakes to cover the baking anodes and seal the pits. Recycled packing material coke is fed back into the anode paste plant and mixed into the same handling streams described previously.

The material collected in the anode paste plant baghouse can originate from a wide variety of equipment depending on what is being used. However, it is all similar in nature (PM/PM₁₀). The fugitives in the anode paste plant which escape capture and do not settle out on the floors, originate from the same basic group of material sizing, and handling devices. The POM (polycyclic organic matter from pitch volatiles) and PM/PM₁₀ emissions from the mixers, spreaders, cooling belts, and presses will be collected in a dry coke scrubber. This control device will be installed for primary aluminum MACT compliance between 1997 and 2000. Engineering will begin in 1997. Physical installation of the control device will be between CD07 and CD04.

 EU04 - ANODE PASTE PLANT VENTILATION (PM/PM₁₀)

 EU05 - ANODE PASTE PLANT BUILDING (PM/PM₁₀/POM/VOC)

 EU06 - BUTT SHAKER, CRUSHERS (PM/PM₁₀/F)

 EU36 - ANODE PASTE PLANT DRY COKE SCRUBBER (PM/PM₁₀/F/POM) (future)

C) BAKES - PROCESS P03

The pressed "green" carbon blocks are transferred into the bakes. The bakes consist of 3 rooms, which have the capability of supporting 4 "fires" each. The blocks are stacked in layers in baking pits with a thin layer of packing material coke between the layers. The pits are 114 inches deep and can hold 50 blocks each (5 blocks deep x 2 blocks wide x 5 blocks across). Packing material is poured in around the blocks and a thick layer covers the pits to seal in the carbon and prevent air infiltration. The walls of the pit consist of hollow brick flues which are heated via natural gas burners. The flues are held under negative static pressure via a manifold connected to the wet electrostatic precipitator (ESP). The gasses discharging from the baking blocks vent into the flues and are drawn out through the exhaust manifold into ductwork and scrubbed at the ESP. The vast majority of pitch volatiles (POM/VOC) discharging from the baking blocks are burnt by the high temperatures in the flues.

Each group of pits moves through several firing sections during the bake cycle. During these movements, the blocks are gradually raised in temperature reaching approximately 1,100°C in the final firing section. The group of pit sections which is being cycled up in temperature is referred to as a "fire". The hollow brick flue temperatures necessary to create these final temperatures are in the range of 1,250°C.

After approximately 126 hours, the blocks reach their final bake temperature. At this point, cooling air is injected into the flues and the blocks are gradually cooled. When the blocks are cooled enough to handle, they are removed from the pits and sent through a cleaning device which blasts them with coke to remove any packing material adhering to the baked block. The baked carbon block is a strong, electrically conductive material which is ready to be rodded and sent to the potrooms.

The material vented to the ESP consists of unburnt pitch volatiles (POM/VOC), fluoride from bath material in the butt fraction, sulfur dioxide from the partial volatilization of sulfur in the coke and pitch, and particulate matter from condensed pitch volatiles, ashed material, entrained packing material, and brick materials.

The collection efficiency of the furnaces is relatively high. Some particulate fugitives escape the baking rooms due to the packing/unpacking operations. This is minimized by dedusting agents and particle size selection of the coke used for packing material. (Note: Natural gas emissions are accounted for in plant fuel combustion section.)

EU07 - CARBON BAKE ESP (PM/PM₁₀/CONDENSIBLES/F/SO₂/CO/POM/HF)

EU08 - CARBON BAKE BUILDING (PM/PM₁₀/CONDENSIBLES/F/SO₂/VOC/NO_x/CO/POM/HF)

EU09 - CARBON CLEANERS (PM/PM₁₀)

D) RODDING ROOM - PROCESS P04

The rodding room receives the cleaned, baked carbon blocks from the bakes and attaches copper rods to them. Stub holes in the center of the carbon blocks are cleaned and heated. The steel stubs are ground and buffed to ensure a clean electrical contact face. The stubs, which are coated with graphite, are centered in the holes. Molten cast iron is poured around the stub, fixing it in place and providing an electrical connection. Copper rods are bolted to the cleaned stub face. The rodded carbon blocks are then sprayed with molten aluminum to provide a resistance to air burning of the carbon in the reduction cells. The rodded, sprayed carbon blocks are then placed on wagons for potrooms use.

 EU10 - CAST IRON FURNACES (PM/PM₁₀,CO)

 EU11 - STUB BUFFER/GRINDERS (PM/PM₁₀)

 EU12 - STUB GRAPHITE STATION (PM/PM₁₀)

 EU13 - RODDING ROOM BUILDING (PM/PM₁₀)

The butts are removed from the reduction cells and returned to the anode paste plant for recycling after the rod assembly is broken off. The rods are placed on wagons and returned to the rodding room. The bolted rod-stub connection is disassembled. The cast iron is pressed off of the stub and placed in a tumble mill for cleaning prior to being reused in the cast iron furnaces. The rods are run through a shot blast cabinet and cleaned for reuse.

   EU14 - CAST IRON TUMBLE MILL (PM/PM₁₀)

   EU15 - ROD BLAST CABINETS (PM/PM₁₀)

The sources of the particulate matter emissions are fumes from the cast iron furnaces, particulate matter from stub buffing and grinding, particulate matter from the graphite dipping operation, particulate matter from cleaning the cast iron in the tumble mill, particulate matter from the rod blast operations, and particulate matter from the aluminum spraying operation. Natural gas emissions are accounted for in plant fuel combustion section.

POTROOM OVERVIEW

The potrooms utilize the carbon blocks from the carbon plant, alumina which is purchased from outside vendors, and D.C. amperage from plant rectifiers to electrochemically produce aluminum. On a theoretical weight basis, 1.89 pounds of alumina and 0.33 pounds of carbon produce 1.0 pound of aluminum in a time period of 74.3 seconds when 65,000 amps are passed through a reduction cell. This assumes 100% reaction efficiencies which are not possible. On a more realistic basis, 1.91 pounds of alumina, 0.5 pounds of carbon, and 79.9 seconds are needed to produce 1.0 pound of aluminum at the same amperage.

A) POTLINING - PROCESS P05

Reduction cells last anywhere from 700 to 3000 days. During this time, they gain approximately 10,000 pounds in weight from the absorption of bath materials. The cells consist of a steel shell, insulating materials, vapor barriers, cathode blocks/rods, silicon carbide sidewall brick and a rammed mix (anthracite and low temperature pitch). The rammed mix fills in between the cathode blocks and over the sidewall brick. Construction variations use different insulating materials, barriers, rammed mix paste types (hot or cold), cathode block types, and wall types. This process consumes about 520 tons/year of rammed mix and other related products (cathode blocks and rods, insulation, castable, silicon carbide brick, steel plate).

The newly relined pots are transferred to the potrooms and normally "baked out" (heated up for use) via gas bake although metal bake or resistance bake are also sometimes used. The baking process generates emissions of pitch volatiles from the ramming mix for a period of about 18 hours until the pot is loaded and put on line. Natural gas emissions from bakeout are combined into the single source. Both hot ramming material made in the Reynolds Metals facility and cold ramming material purchased outside can be used in lining rebuilt pots.

A containment facility which meets the EPA requirements for handling spent potlining has been installed. The spent potliner is disposed of at a hazardous waste facility or treated by a Reynolds facility in Arkansas which meets the EPA requirements.

 EU16 - POTLINING (MILLING) (PM/PM₁₀)

 EU17 - POTLINING (RAMMING) (POM)

 EU18 - POTLINING (BAKEOUT) (POM)

 EU19 - POTLINING (DIGGING-DISPOSAL) (PM/PM₁₀/CYANIDE/FLUORIDE)

B) REDUCTION PROCESS - PROCESS P06

The Troutdale reduction facility consists of 700 reduction cells. 580 cells normally run about 68,000 amps while the remainder (line 5 - a larger, newer cell design) run at about 79,000 amps. Annual reduction capacity is approximately 143,500 tons of metal per year.

 Two rooms (140 cells) are electrically connected in series. Alumina is supplied via a hopper on top of the cell and dumped directly into the cell. Normally the pot is "fed" alumina based on a computer controlled algorithm (demand feed). The alumina dissolves in the molten bath (approximately 950°C). Amperage passes through the molten bath primarily via sodium ions. During this process, the electrochemical reaction takes place oxidizing the carbon to CO₂ and reducing the alumina to molten aluminum and depositing it at the cathode. If the concentration of alumina dissolved in the bath falls below about 2%, an anode effect will occur. An anode effect is caused by side reactions becoming predominant at low alumina concentrations, creating gas bubbles (CF₄ and CO) beneath the carbon anodes which drastically increase the voltage of the cell and the temperature of the bath. Troutdale (and RMC corporately) has a ongoing program aimed at minimizing anode effects, their emissions, and their undesired side effects.

After the carbon block is mostly consumed (about 35 shifts), it is removed and replaced with a new carbon block. The butts (spent carbon block) are cleaned and recycled back to the carbon plant to be reused in the mix to produce new carbon blocks.

The molten bath is mostly cryolite (Na₃AlF₆). However it is also modified with LiF, MgF₂, and AlF₃ to help improve the reaction efficiency and control temperature and related emissions. The bath chemistry is analyzed twice a week. Modifier additions are made on a weekly or bi-weekly basis.

Normally the reaction is about 91 to 93% efficient. The inefficiency is produced by a back reaction which reoxidizes aluminum and creates CO. For production reasons and energy conservation reasons, it is highly desirable to keep the reaction efficiency as high as possible. This results in higher metal production and at the same time, lower overall emissions.

A baghouse system is connected to the potrooms. Alumina is injected into the gas stream coming off the potrooms to scrub and adsorb HF emissions. The "reacted alumina" is collected in baghouses along with particulate emissions from the potrooms. The "reacted alumina" is then sent to the potrooms to be reduced to aluminum. Recycling the collected emissions, reduces the need for addition of makeup components. To some extent, the purity of the metal produced is degraded because of this type of emission control system.

Fluoride emissions originate from volatilized bath components. Sulfur dioxide emissions originate from the sulfur content left in the carbon blocks after baking. Carbon monoxide emissions originate from the back reaction which degrades the overall process efficiency. Particulate/HAP emissions result primarily from fine reacted alumina components (recycled emissions and fine alumina particles). POM emissions result from the approximately 18 hour bakeout process on cells. Natural gas emissions are accounted for in plant fuel combustion section.

EU20 -  POTROOMS PRIMARY COLLECTION SYSTEM (CRITERIA: PM/PM₁₀, SO₂, CO, F, Pb; HAPS: Se, Ni, Mn, Co, Cr, Cd, Sb, POM, COS; NESHAPS: HF, Hg, Be, As)

EU21 -  POTROOM ROOF VENTS (CRITERIA: PM/PM₁₀, SO₂, CO, F, Pb; HAPS: Se, Ni, Mn, Co, Cr, Cd, Sb, POM, COS; NESHAPS: HF, Hg, Be, As)

ALUMINA HANDLING SYSTEM - PROCESS P07

The ore (alumina) transfer system handles 268,000 tons of ore a year. Normally ore is unloaded via truck at the dry system. Alternately, ore can be unloaded via truck at the ore dock or by rail at the ore dock. The ore transfer system is used to unload and store ore, move ore from storage and inject it into potroom gases for HF absorption, remove reacted ore from baghouses and store it, and move ore from storage at the baghouse complex to storage in the potrooms. In addition, it has the capability of screening floor sweepings from the potroom and recycling the products. Aluminum fluoride is also transferred from railcars to a storage silo at the ore dock.

The system has baghouses in many different areas to control fugitive emissions from the airlifts and airslides used to move alumina. The auxiliary baghouses (2) ventilates air from baghouse complex air slides and from the reacted ore tank. Each air lift has a separate baghouse (4) which ventilates the lift air. The fresh ore tank has baghouses (2) which ventilate the unloading system air discharged into the tank. The ore dock has baghouses (2) which ventilate air slides, air lifts, and a rail unloading area. The main plant ore belt has a baghouse (1) which ventilates the discharge from the N-S belt to the E-W belt. The floor sweeping system has a baghouse (1) which ventilates this operation.

 EU22 - ALUMINA VENTILATION SYSTEM (PM/PM₁₀, F)

 EU23 - FRESH ORE TANK (PM/PM₁₀)

 EU24 - 200 TON AIR LIFTS (PM/PM₁₀, F)

 EU25 - 60 TON AIR LIFTS (PM/PM₁₀, F)

 EU26 - ORE DOCK (PM/PM₁₀, F)

 EU27 - ORE BELT CROSSOVER (PM/PM₁₀, F)

 EU28 - FLOOR SWEEPING/SCREENINGS (PM/PM₁₀, F)

CASTHOUSE - PROCESS P08

At full production, approximately 143,500 tons of aluminum per year are produced in the reduction process in the potrooms. This metal is sent to the cast house for alloying. In addition, the casthouse has the capability of alloying and casting metal purchased from the outside bringing it's total capacity to 170,000 tons of aluminum per year. The potroom metal is siphoned from the reduction cells, skimmed and poured into a furnace either directly or through a charcoal filter to remove bath components. The furnace temperature is brought to 1,300°F to 1,400°F. Alloying metals are added and mixed in.

The molten metal is transferred from the pots to the casthouse furnace in a large crucible. In the process of tapping the pots, a small amount of the molten bath material is carried into the crucible with the aluminum. The bath material cools and hardens on the crucible or “cruce”, and must be removed on a regular basis. To perform this task, Reynolds installed a “Cruce Cleaning” station in 1999.

The furnace is fluxed with a mixture of nitrogen and chlorine gases to remove dissolved hydrogen and float oxides to the surface. Fluxing also reduces unwanted bath components via the formation of chlorides. Fluxing time can vary widely and is a product of atmospheric moisture, furnace fuel combustion moisture, and possibly other sources of moisture. Chlorine reacts with the molten metal to form metal salts and HCl. The primary product is aluminum chloride which quickly decomposes into HCl and aluminum oxides.

The oxides, chlorides, and nitrides which form during fluxing are floated to the surface and removed via skimming. The material is referred to as dross. Salt may be added to the dross to cool it and stop the oxidation process which creates oxide fumes. The treated material is either placed into a dross press which further retards the reaction and produces a solid block of material or moved as is to a dross pile for eventual transfer to a metal reprocessor. The dross press greatly reduces dross emissions and enhances reprocessing recovery rates. The first press was put in place in 1995.

When the furnace is on grade and the metal gases reduced to acceptable limits, the furnace is poured. The alloyed metal may pass through ceramic and/or spinning nozzle filters prior to being cast. The spinning nozzle filters use mainly argon but are also capable of using chlorine. These filters remove inclusions and gases and to some extent, reduce the need to flux (total chlorine usage).

Up to 5,000 tons total per year of alloying agents (magnesium, silicon, manganese, copper, chromium, titanium, strontium, sodium, boron, beryllium, and iron) are added to create the aluminum alloys needed. In addition, up to 20,000 tons per year of metal may be imported from outside of the plant to supplement the production in the potrooms (and provide higher grade metal). The variety of alloys produced varies substantially from month to month.

The casthouse has four 165,000 pound holding furnaces which are used for sheet metal production, and two 65,000 pound furnaces which are used for foundry production. The smaller furnaces feed three 35 pound foundry ingot machines. The larger furnaces feed two 200-inch direct chill casting pits capable of producing sheet in sizes from 13,000 to 32,000 pounds, depending on the mold size used. In addition, the casthouse has a pouring wheel capable of producing 1,000 pound ingots.

Particulate matter emissions in the form of metal oxides and chlorides are produced during fluxing and dross removal. A small amount of chlorine is passed unreacted from the furnaces while the vast bulk of it ends up as HCl gas. Minor amounts of HAPS (Mn, Cr, Be) may be produced during this process. Natural gas emissions are accounted for in plant fuel combustion section.

 EU29 - CASTHOUSE HOLDING FURNACES (PM/PM₁₀, Cl₂, HCl, HAPS: Mn, Cr, Be)

 EU30 - CASTHOUSE ROOF (PM/PM₁₀, Cl₂, HCl, HAPS: Mn, Cr, Be)

 EU39 - CRUCE CLEANING (PM/PM₁₀, F)

PLANT FUEL COMBUSTION

This section describes the fuel combustion process in the plant. The plant operates entirely on natural gas except during curtailments which may occur during the winter.

FUEL COMBUSTION - P09

NATURAL GAS USAGE, EU31, (YEARLY) - 9,500,000 THERMS/YEAR TOTAL

 Carbon Bake Flue Burners - 4,700,000 THERMS/YEAR

 Cast House - 3,000,000 THERMS/YEAR

 Cast House Furnace Burners

 Cast House Pig Preheat Burners

 Cast House Crucible Heat Burners

 Mold Preheat Burners

 Trough Preheat Burners

 Boiler - 900,000 THERMS/YEAR

 Miscellaneous - 900,000 THERMS/YEAR

 Rodding Room Cathode Preheaters

 Rodding Room Crucible Heater

 Rodding Room Stub Hole Heater

 Potroom Pot Bakeout Heaters

 Potroom Siphon Heaters

BACKUP FUEL - P10

PROPANE USAGE, EU32, @ 0.92 therms/gallon - 200,000 gallons (184,000 THERMS; 22 days)

 Cast House Backup Fuel

#2 DIESEL OIL USAGE, EU33, @ 1.4 therms/gallon - 200,000 gallons (280,000 THERMS; 18 days)

 Carbon Bake Backup Fuel

 Boiler Backup Fuel  

 EU31 - NATURAL GAS COMBUSTION (PM/PM₁₀, SO₂, NO_x, CO, VOC;

  HAP: Hg, formaldehyde, toluene, hexane, benzene)

 EU32 - PROPANE COMBUSTION (PM/PM₁₀, SO₂, NO_x, CO, VOC)

 EU33 - #2 DIESEL COMBUSTION (PM/PM₁₀, SO₂, NO_x, CO, VOC)

OUTSIDE MATERIAL STORAGE FUGITIVES & ROAD FUGITIVES

The plant paved road system is inside an urban growth boundary. The gravel roads consist of a perimeter fence road, a road to the metal scrap recycle holding area, a road to an ambient air monitoring station, and a road to the NPDES discharge sampling station. The gravel roads are generally short and lightly traveled.

The outside material storage site consists of a dross storage bunker and charcoal storage piles. The dross storage emissions are eliminated due to the installation of a dross press in the casthouse. Material handling emissions for both the dross and charcoal still exist. All other material handling fugitives are within the buildings and included as estimates in their particular area.

 EU34 - GRAVELED ROAD SYSTEM (PM/PM₁₀)

 EU35 - DROSS/CHARCOAL HANDLING (PM/PM₁₀)

VARIATIONS IN BASE OPERATING SCENARIO

Under the base operating scenario, RMC may employ process variations in order to meet customer specifications and optimize process parameters. These variations will not, however, trigger any new applicable requirements, change compliance demonstration methods, cause different regulated pollutants to be emitted or cause higher emissions.

Such variation may include changes in the following:

* Production levels (<= 143,500 tons aluminum per year)

* Any commercially available raw materials

* Production startup/shutdown needs

* Carbon block mix parameters

* Carbon block size

* Butt cleaning system replacement/enhancement

* Bake construction and materials

* Baking firing & control parameters

* Rodding methodology/materials

* Bath temperature & chemistry control

* Cell construction and materials

* Voltage and amperage levels in potrooms

* Cell feed technology/methodology (Point Feed)

* Anode effect suppression systems

* Anode cover system

* Replacement of manual control with PID's, PLC's, or computers on various processes

* Casting filter technology (SNIFF)

* Metal treatment systems (TAC)

* Dross treatment systems (Presses)

* Flux composition and time

* Crucible cleaning system

* Potroom scrubber system ore feed

* Potroom baghouse system operational parameters

* Replacement of baghouse/baghouse components with equal or superior technology in lieu of repair

* Installation of equipment to comply with the EPA regulations on handling of potlining

* Temporary activities involved with the EPA directed superfund site cleanup

* Installation of new equipment to comply with future EPA MACT standards

PERMITTED ACTIVITIES

3.  This section acknowledges that RMC is allowed to discharge regulated air pollutants in accordance with the limits established in the federal operating permit.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

4.  The emissions units regulated by the permit are the following:

EMISSION LIMITS STANDARDS

RESCINDED FEDERAL OPERATING PERMIT CONDITIONS

5.  The following conditions of the 11/03/97 Title V Operating Permit for Reynolds have been rescinded;

5.a.  Condition 10, (old ACDP condition to record control device downtime) was removed as this information is collected in the maintenance records required for monitoring.

5.b.  Condition 15 (SERP condition) was removed because the Portland Air Quality Maintenance was redesignated as a Maintenance Area and the SERP requirement no longer applies.

5.c.  Condition 19 was removed because the monthly emission limit requirement was removed from 340-25-265. The NESHAP limit is more restrictive.

5.d.  Condition 27 (Wet ESP operating condition) was removed because it is redundant to the MACT requirement for Highest and Best Operation under 40 CFR 63.6(e).

5.e.  Conditions 30, 31 and 32 were removed because they are redundant to the MACT requirements of 40CFR63.848(h) which require the permittee to take corrective action when an operating parameter for a control device leaves the approved operating range.

5.f.  Conditions 19 and 35 were removed because the requirement (OAR 340-25-265(3)(a)(C))was removed from the rule to during the 1998 rule revisions.

5.g.  Condition 53 was removed as it is redundant to the maintenance records required by the permit for baghouses and other control devices.

5.h.  Condition 5 (forage fluoride concentration limit) was removed at the request of the permittee. The limits in this permit condition were not based on rule requirements. Monitoring results reported by the permittee have shown that the facility is unlikely to exceed the limitations in condition 5 as the facility is currently configured and operated. The requirements of the MACT standard assure that the future emissions of the facility will be less than or equal to historical levels. If the facility is modified such that the facility emissions are increased or altered significantly, the Department may re-institute the requirement to do forage monitoring. A summary of ambient Monitoring and forage monitoring data for 1991 and 1992, and from the time that aluminum production was re-started in 1998, is included below.

*  average for any 30 consecutive days.

**  monthly average for any twelve consecutive months.

5.i.  Conditions 74, 78.a, 78.b, 78.c were also removed because they were reporting for condition monitoring and 5, and are no longer necessary in their absence.

5.j.  Condition 55 requiring a certification for gasoline tanks to have submersible fill devices was removed because this requirement only applies to insignificant activities, and therefore no monitoring is necessary.

5.k.  Condition 56 was removed because the SERP requirement no longer applies. The Portland Air Quality Maintenance Area has been redesignated from non-attainment to a maintenance area.

5.l.  Condition 72 contained a requirement to update the QAP which has been satisfied and therefore was removed. The requirement to review the QAP and notify the Department one time per year was retained.

REVISED FEDERAL OPERATING PERMIT CONDITIONS

6.  The following conditions of the 11/03/97 Title V Operating Permit for Reynolds have been revised;

6.a.  Conditions 6 and 7 were merged to become one condition because they stem from the same rule requirement, OAR 340-021-0060.

6.b.  Condition 12 was moved to the insignificant activities section of the permit. This condition needs no monitoring as the requirement is also a State Fire Marshall requirement for Underground Storage Tanks.

6.c.  Conditions 17 and 30 were revised to reflect the current version of 340-025-0265 which rescinds the monthly Fluoride emission limit when the more restrictive NESHAP limit becomes effective.

6.d.  Condition 44 was revised to require testing to begin no later than 60 days after the start-up of an individual potline.

6.e.  Condition 46 was revised to dovetail with the NESHAP testing requirements, and to add a one time testing requirement for EU36.

6.f.  Condition 47 was revised to clarify the applicability of OR method 5, 7 and 8 testing for emission units not normally tested.

6.g.  Condition #58 was revised to dovetail with the NESHAP Requirements and the requirements for EU04 were removed. EU04 was added to conditions 64 and 65 with the other baghouses.

6.h.  Condition 59 was also revised to dovetail with the changes to the NESHAP testing requirements.

6.i.  Conditions 60, 61, 62 and 63 were also revised to dovetail with the NESHAP requirements. These monitoring system requirements will be replaced by the NESHAP requirements when they become effective.

6.j.  Conditions 64 and 65 were revised to clarify that some of the devices referenced are filter units which operate using hard filter cartridges instead of filter bags. The requirement to develop the operating ranges was removed as this has been completed.

6.k.  Condition 67 was revised to remove the monthly log requirement for opening of the furnace draft. The required audible alarm has been installed.

6.l.  Condition 68 the plant site emissions limit condition was updated to include the airslide 21 baghouse and the crucible cleaner which are being added.

6.m.  Condition 73 was revised to remove the Ambient Air Particulate sampling at the permittee’s request because it is not required by rule. There is no ambient particulate concentration standard that applies to point sources; the National Ambient Air Quality Standards (NAAQS) do not apply to sources, but are used for airshed management.

6.n.  Condition 76, the recordkeeping requirements, has been revised and updated to reflect the changes to the permit

6.o.  Condition 78, the reporting requirements, has been revised and updated to reflect the changes to the permit

NEW FEDERAL OPERATING PERMIT CONDITIONS

7.  The following conditions have been added;

7.a.  Condition 13 was added as an elective condition to assure compliance with the NESHAP standard during the period that a compliance extension is in effect for potlines #1, 2, and 4.

7.b.  Conditions 24, 25, 26, 27, 28, 29, 46, 47, 48, 66, 67, 83, 91, and 92 were added to the permit to include the requirements of the NESHAP for Primary Aluminum Production facilities.

7.c.  Condition 41 was added to clarify that the testing requirements do not apply during periods of shut down.

7.d.  Condition 58 was added to clarify that the regular particulate source testing will be used for monitoring for the particulate concentration standard for emissions units EU07, EU20, and EU21.

Compliance Assurance Monitoring Applicability

8.  The requirements of 40 CFR Part 64 “Compliance Assurance Monitoring” or (CAM) apply to this facility because it is a Major Source, there are several Emission units that have potential emissions greater than the major source thresholds (not including controls) which use a control device to comply with an emission limitation. The requirement to incorporate the CAM requirements is triggered by the permit renewal process, which is happening at this time. Conditions 68, 69, 70, 71, 72, 73, and 88 were added to incorporate the CAM requirements.

PLANT SITE EMISSION LIMITS

HISTORY OF CHANGES TO THE FACILITY

9.  The Plant Site Emission Limits are different from the baseline emission limits because of the following reasons:

9.a.  .production increase from 11,619 TAP/month and 133,141 TAP/year to 12,200 TAP/month and 143,500 TAP/year

9.b.  .reduced emission factor because of process improvements

9.c.  .increased SO₂ emissions because of higher sulfur content of coke

Reynolds Metals has asked for a production increase from 11,619 TAP/month and 133,141 TAP/year to 12,200 TAP/month and 143,500 TAP/year. Usually a production increase of this kind increases the emissions of all pollutants. Reynolds Metals has asked for an increase of emissions for F, PM/PM₁₀, and VOC since the last ACDP was issued. For the other pollutants, CO, NO_x, and SO₂, the emissions have remained the same as in the last ACDP issued. Reynolds has been able to increase production without increasing emissions of CO, NO_x, and SO₂ because of process efficiency improvements made.

The increases in Plant Site Emission Limits over the baseline emissions for PM/PM₁₀ and VOC are less than significant emission rates. Therefore, no further additional air quality analysis was necessary.

The increase in the SO₂ PSEL over the baseline emissions was approved in the 05/27/88 ACDP after a computer modeling study was approved by the Department. The increase in SO₂ emissions was due to a higher sulfur content of the coke. A physical change does not include use of an alternative fuel or raw material. Therefore, a physical modification was not done, therefore, the increase in SO₂ emissions did not trigger New Source Review/Prevention of Significant Deterioration.

The increase in the F PSEL over the baseline emissions is equal to the F significant emission rate, 3 tons/year. This increase in the F PSEL is due to a production increase using existing capacity. No physical modification was done, therefore, the increase does not trigger New Source Review/Prevention of Significant Deterioration. The PSEL rules, OAR 340-028-1020(1)(a), require an assessment of the air quality impact pursuant to procedures specified in OAR 340-028-1930 to 340-028-1940. A demonstration that no air quality standard or PSD increment will be violated in an attainment area shall be sufficient to allow an increase in the PSEL to an amount no greater than the plant's demonstrated need to emit as long as no physical modification is involved. There are no fluoride ambient air quality standards or PSD increments, therefore, there is no basis of comparison for the computer modeling air quality impacts. No air quality analysis is required and Reynolds Metals may increase F emissions by 3 tons/year.

The emission detail sheets are attached.

AGGREGATE INSIGNIFICANT EMISSIONS

10.  The emissions from the activities included in the aggregate insignificant emissions are the following:

10.a.  Criteria Pollutants:

10.b.  Hazardous Air Pollutants:

CATEGORICALLY INSIGNIFICANT ACTIVITIES

11.  RMC has the following categorically insignificant activities onsite:

•  Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound regulated under Divisions 20 through 32 of this chapter, or less than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

•  Evaporative and tail pipe emissions from on-site motor vehicle operation

•  Distillate oil, kerosene, and gasoline fuel burning equipment rated at less than or equal to 0.4 million Btu/hr

•  Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr

•  Office activities

•  Janitorial activities

•  Personal care activities

•  Groundskeeping activities including, but not limited to building painting and road and parking lot maintenance

•  On-site recreation facilities

•  Instrument calibration

•  Maintenance and repair shop

•  Automotive repair shops or storage garages

•  Air cooling or ventilating equipment not designed to remove air contaminants generated by or released from associated equipment

•  Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment associated with such systems

•  Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical analysis, including associated vacuum producing devices but excluding research and development facilities

•  Temporary construction activities

•  Warehouse activities

•  Accidental fires

•  Air vents from air compressors

•  Demineralized water tanks

•  Pre-treatment of municipal water, including us of deionized water purification systems

•  Electrical charging stations

•  Fire brigade training

•  Process raw water filtration systems

•  Blueprint making

•  Routine maintenance, repair, and replacement such as anticipated activities most often associated with and performed during regularly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

•  Electric motors

•  Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual fuels, lubricants, and hydraulic fluids

•  On-site storage tanks not subject to any New Source Performance Standards (NSPS), including underground storage tanks (UST) storing gasoline or diesel used exclusively for fueling of the facility's fleet of vehicles

•  Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment

•  Pressurized tanks containing gaseous compounds

 Fire suppression training

•  Paved roads and paved parking lots within an urban growth boundary

•  Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those sources that have processes or activities that contribute to the deposition and entrainment of hazardous air pollutants from surface soils

•  Health, safety, and emergency response activities

•  Emergency generators and pumps used only during loss of primary equipment or utility service

•  Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems

•  Non-contact steam condensate flash tanks

•  Non-contact steam vents on condensate receivers, deaerators and similar equipment

•  Boiler blowdown tanks

•  Oil/water separators in effluent treatment systems

•  Combustion source flame safety purging on startup

HAZARDOUS AIR POLLUTANTS

12.  The following hazardous air pollutants are estimated by RMC to be emitted:

13.  PSELs were established for hydrogen chloride and polycyclic organic matter emissions for fee purposes since they would not be included in the particulate or volatile organic compound PSELs. Hydrogen fluoride (gaseous fluoride) emissions are already included in the fluoride PSEL.

14.  The following toxic substances are used at RMC in the approximate quantities listed below:

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT)

15.  Reynolds Metals is a major source of Hazardous Air Pollutants (HAPs) and is subject to the National Emissions Standard for Hazardous Air Pollutants (NESHAP) for Primary Aluminum Production 40CFR63 Subpart LL. In this re-issuance, the applicable requirements of Subpart LL are being incorporated into the permit.

The following changes will be made at the facility to comply with the Subpart LL requirements:

15.a.  A dry coke scrubber will be installed to control POM emissions from the anode paste plant. An extensive emissions collection system will also be added to the paste plant to collect fugitive emissions to be routed to the dry coke scrubber.

15.b.  Emissions sampling manifolds will be added to at least two of the five potlines to collect samples of emissions from the potlines in accordance with EPA Method 14 protocol. If approved by the EPA as an alternative monitoring method, an “Open Path” continuous monitoring system will be installed on Potlines 1, 2 and 4

A compliance extension has been granted for 1 year for compliance with the NESHAP requirements for the anode bake furnace. The compliance extension request was approved because the current emissions control system must be modified to achieve compliance. While preliminary tests have shown that the system is capable of meeting the NESHAP emission limits at times, compliance is not continuous, and further work must be done.

A compliance extension has been granted for 1 year for compliance with the NESHAP requirements for potlines 1, 2, and 4. Potlines 3 and 5 must be in full compliance with the NESHAP requirements on October 7, 1999. The purpose of the compliance extension is to allow Reynolds additional time to receive approval for and to install “open path” monitoring equipment as an alternative to the EPA Method 14 manifolds required for compliance with the NESHAP. The Department believes that the “open path” monitoring systems are superior to the Method 14 monitoring because they can be operated continuously and measure emissions over a much greater length of the potline. As emissions from all five potlines are similar, requiring full compliance at two of the potlines, will provide a reasonable indication that the NESHAP emissions limits are being met at all of the operating lines. The monthly monitoring required by Oar 340-25-280 will remain in effect on potlines 1, 2, and 4 until the NESHAP compliance date.

The requirements of the NESHAP have been incorporated into the permit so as to provide as much of the flexibility provided within Subpart LL as possible. Where the NESHAP provides the opportunity for the permittee to use alternate test methods or monitoring (after Department and EPA approval) this has been carried into the permit. The intent here is that making use of this flexibility provided in the Subpart and carried into the permit through the public review process will not require subsequent modifications to the permit.

The Start-up, Shutdown Maintenance (SSM) Plan requirement of the NESHAP General Provisions includes specific procedures for the revision of the SSM Plan. This was intended to provide flexibility to update the plan as necessary. In some cases these specific procedures are in apparent conflict with the more general revision requirements for Title-V permits. Language was added to condition 29.c to clarify that changes that affect only the SSM plan are not considered changes or modifications to the permit.

STRATOSPHERIC OZONE-DEPLETING SUBSTANCES

16.  Reynolds Metals uses the following stratospheric ozone-depleting substances:

 ozone-depleting substance   class type  replacement chemical

 CFC-12 (WATER COOLER)    I    HFC-134a

 CFC-114 (CRANE AC's)      I    HCFC-124

 R-500 (CFC-12) (HVAC UNITS)    I    HFC-134a

 R-502 (CFC-115) (HVAC UNITS)    I    R-407A

 R-502 (CFC-115) (ICE MACHINE)  I    R-407A

 CFC-113 (LAB EPA METHOD)    I    METHOD 1664 n-hexane  

 HCFC-123 (WATER COOLER)    II

 HCFC-22 (HVAC UNITS)    II

The Class I refrigerants will be replaced with the above mentioned replacement chemicals from the EPA's list of acceptable substitute refrigerants under the Significant New Alternative Policy (SNAP) Program. The requirements of 40 CFR Part 82, Subpart F for recycling and emission reduction are included in the permit as a general condition.

TESTING REQUIREMENTS

17.  Compliance source testing:

17.a.  The permittee is required to perform source tests for measuring particulate matter (PM) and fluoride emissions from emissions units EU07, EU20, and EU21 each month until the NESHAP requirements are effective. At that time, the fluoride testing will be performed as required by NESHAP. PM testing will continue at the same frequency as the testing required by the NESHAP for each emissions unit. In addition EU36 will be tested within 60 days after startup. The results from these tests will be used to determine compliance with the particulate matter limits, including the particulate concentration limitations (gr/dscf) and the particulate emissions standards for Primary Aluminum Production (lbs-PM/TAP). In general, the Department requires at least one particulate matter test during the permit term for any emissions unit that emits more than 5 tons per year. (See the Department’s Compliance Monitoring Guidance Document for additional guidelines)

17.b.  The permit does not require PM source tests for emissions units EU31, EU32, and EU33 because these units primarily operate on natural gas or propane, and oil is only used for brief periods of time when natural gas is curtailed. It is the Department’s experience that it is very unlikely that the particulate matter limits would be exceeded while operating on natural gas..

17.c.  The permit does not require source testing of emissions units EU01, EU04, EU06, EU08, EU09, EU10, EU11, EU12, EU14, EU15, EU16, EU19, EU600, EU28, EU24, EU25, EU27, EU37, EU38, EU29, EU39, or EU40. Tests are not required for these emissions units because the emissions are controlled by baghouses or cartridge filter units that are generally expected to control emissions well below the 0.1 or 0.2 gr/dscf limit. Instead of testing, the permit requires the permittee to perform routine visible inspections and take corrective action any time there is any visible emissions observed. This monitoring is intended to be a surrogate for actually measuring the grain loading emissions.

18.  Emission factor verification source tests:

In general, emission factors are used to establish Plant Site Emissions Limits (PSELs). They are also used to demonstrate compliance with the PSEL. Since most emission factors are not based on actual emissions data from the specific source, the Department is requiring that some emission units be tested to verify that the emission factors are reasonably accurate. The Department’s Compliance Monitoring Guidance Document is used for determining which emissions units should be tested. In general, those emissions units with greater than 5 tons per year of PM or 10 tons per year of any gaseous pollutant are required to have an emission factor verification test.

The results of emission factor verification tests will also be used to determine compliance with any requirements that may apply to the emissions units, such as a PM grain loading limit. For purposes of the PSEL, however, the results are not necessarily used for compliance determinations. Emission factors are designed to represent normal, average emissions. As such, they do not reflect normal process variations or errors in source test methodologies. Therefore, the Department will use the data to determine if the emission factor is reasonable keeping in mind the potential variables.

In most cases, a measured value plus or minus 20% of the emission factor would be sufficient grounds for considering the factor reasonable. If the results are considerably higher or lower, the Department may inquire as to the reason for the difference and possibly request additional testing. If it is shown that the test result was considerably different than the emission factor and the difference cannot be justified, the Department may conclude that the emissions unit was being improperly operated, resulting in an enforcement action. If justification can be provided that the measured value is more indicative of the actual emissions, then the Department may change the PSEL to reflect the new and better information. The PSEL may be changed by an administrative amendment or at permit renewal. In either case, the baseline emission rate will also be corrected and any increases or decreases re-evaluated.

See the PSEL Monitoring for the specific emission factor verification testing requirements for this facility.

19.  The “Testing Requirements” section of the permit also includes the test methods that would be used to demonstrate compliance with the standards in the permit in the event that testing is performed even though the permit does not require testing for some specific emissions units. Although the permit does not specifically require testing for some emissions units because the emissions are less than 10 tons/yr and are not considered to have a significant environmental impact, the Department may request testing and/or the permittee may elect to voluntarily test a source. If so, the methods identified in this section would be used for compliance testing.

MONITORING REQUIREMENTS

20.  Section 70.6(a)(3)(i) of 40 CFR Part 70 requires that all monitoring and analysis procedures or test methods required under applicable requirements be contained in the Title V permits. In addition, where the applicable requirement does not require periodic testing or monitoring, periodic monitoring must be prescribed that is sufficient to yield reliable data from the relevant time period that is representative of the source’s compliance with the permit. The requirement to include in a permit testing, monitoring, recordkeeping, reporting, and compliance certification sufficient to assure compliance does not require the permit to impose the same level of rigor with respect to all emissions units and applicable requirement situations. It does not require extensive testing or monitoring to assure compliance with the applicable requirements for emissions units that do not have significant potential to violate emissions limitations or other requirements under normal operating conditions. Where compliance with the underlying applicable requirement for an insignificant emission unit is not threatened by a lack of a regular program of monitoring and where periodic testing or monitoring is not otherwise required by the applicable requirement, then in this instance, the status quo (i.e., no monitoring) will meet 40 CFR 70.6(a)(3)(i).

Insignificant emissions units include both categorically insignificant activities and aggregate insignificant emissions. The Department is not requiring monitoring for the categorically insignificant activities that Reynolds identified in the application because these were identified by the Department during the Title V program development and included in the rules as activities that do not have any potential for causing significant environmental impacts. The activities generate trivial emissions (less than 1 ton per year) and there are no control devices.

The Department is also not requiring monitoring for the aggregate insignificant emissions, which are those activities that are not identified in the rule as categorically insignificant but the combined emissions are less than one ton per year. In most cases, these are simple uncontrolled activities or pieces of equipment that do not have any potential to cause a significant impact on the environment. For a list of the activities identified by Reynolds as Aggregate Insignificant this facility, see the section above labeled Aggregate Insignificant Emissions.

The permit does include specific monitoring requirements for emissions units other than insignificant activities. In most cases, the monitoring is not a direct measure of compliance because the emissions are either not measured or they are measured with methods or procedures other than reference test methods. Even though the monitoring consists of procedures other than reference test methods, the monitoring has been developed such that it should be capable of providing a reasonable assurance that the emissions units are in compliance with the underlying emissions limits and standards and the information may be used for enforcement purposes pursuant to the credible evidence rules recently promulgated by EPA.

20.a.  The primary aluminum plant rules [OAR 340-025-0255 through 340-025-0285] establish limits for particulate and fluoride for "all sources." The definition of "all sources" means sources including, but not limited to, the reduction process, alumina plant, anode plant, anode baking plant, cast house, and collection, treatment, and recovery systems. The definition of "all sources" does not address fugitive emissions, nor does the rule adoption staff report. The Department believes that fugitive emissions are not included in the limits established for "all sources" because of the following reasons:

20.a.i.  OAR 340-025-0265(3) states “exhaust gases from each primary aluminum plant” (bold added). Fugitive emissions are not considered “exhaust gases”.

20.a.ii.  The New Source Performance Standards for Primary Aluminum Reduction Plants [40 CFR 60, Subpart S] does not mention fugitive emissions either.

In order to monitor compliance with the rule limits, fugitive emissions must be measured. As stated in the definition of fugitive emissions, measurement is not easily done. Therefore, the Department has exempted the fugitive sources (EU2, EU3, EU5, EU8, EU13, EU17, EU30, EU34, and EU35) from the fluoride, particulate, and sulfur dioxide pound/ton of aluminum produced/month and pound/ton of aluminum produced/year limits.

20.b.  RMC is being required to maintain a complaint log to monitor compliance with fugitive emissions requirements. Receipt of a complaint does not necessarily mean noncompliance with this condition. If the RMC's investigation determines that a violation has occurred, this will be reported in the semi-annual compliance certification. The Department may examine the complaint log during inspections to check on the responsiveness of RMC.

20.c.  The Department believes that baghouses and filter units, which are properly maintained, easily meet the state-wide grain loading and opacity limits. Therefore, rather than requiring source testing or visible emissions observations as methods to monitor compliance, the Department is requiring RMC to monitor pressure drop and perform inspection and maintenance activities for all baghouses.

20.c.i.  For emissions units EU20 and EU21, RMC plans to reduce emissions by reducing the -20mm fraction of alumina. RMC cannot guarantee purchase of alumina with low levels of -20 micron but will attempt to do so; however, in no case will RMC use alumina with an average level of more than 10% -20 micron.

20.c.ii.  For emissions units EU20 and EU21, RMC intends to use the computer system to control the pots whenever possible. Of the 70 pots in a room, up to six pots may be off computer control and are being fed manually because of the type of alumina used or problems with the computer pot feeding system. A pot can be off computer control for five minutes or up to several hours per day, depending on the problem.

20.d.  The Department is requiring RMC to perform an emission factor verification source test for NO_x from the potroom baghouse complex even though RMC did not estimate any NO_x emissions from this source. Based on past experience at Northwest Aluminum, the Department believes that NO_x may be emitted from the potrooms and is therefore requiring the source test. If the emission factor verification tests reveal significant quantities of NO_x, Reynolds may apply for an administrative modification to the permit to correct the Plant Site Emission Limit based on the better information provided by the source test

20.e.  RMC is required to maintain records of any changes in collection efficiency resulting from equipment or process changes for all pollution control devices. The Department believes that more significant changes such as adding baghouses, redesigning the roof collection system, etc., should be reported. Minor changes such as modifying the ore feeders or cell construction and materials, increasing the carbon block size, changing the bath temperature and chemistry control, etc., are not required to be reported.

21.  The definition of applicable requirement includes "any national ambient air quality standard or increment or visibility requirement under part C of title I of the Act, but only as it would apply to temporary sources permitted pursuant to section 504 of the Act." The preamble to Part 70 explains that temporary sources must comply with the national ambient air quality standards (NAAQS) because the SIP is unlikely to have performed an attainment demonstration on a temporary source. To require such demonstrations on every permitted source would be unduly burdensome, and in the case of area-wide pollutants like ozone where a single source's contribution to any NAAQS violation is extremely small, performing the demonstration would be meaningless. Under the Act, NAAQS implementation is a requirement imposed on states in the SIP; it is not imposed directly on a source.

Therefore, the national ambient air quality standard for PM_2.5 does not apply to Reynolds Metals, even though Reynolds Metals has agreed to continue performing the ambient monitoring for PM_2.5. The Department will use the data to assess the status of the area and not the compliance status of Reynolds Metals.

22.  The permittee is required to maintain a Quality Assurance Plan (QAP) which includes all elements required to insure the integrity of all required emissions and ambient monitoring data. At least annually, Reynolds will notify the Department of any changes to the QAP. The QAP is available for review at the DEQ Northwest Regional Office in Portland, DEQ headquarters office, and EPA Region X office.

23.  Plant Site Emissions Limit monitoring:

The permittee is required to monitor production parameters (e.g., fuel usage, aluminum production, and raw materials used) and calculate the pollutant emissions using pre-determined emission factors, and also to calculate emissions from emissions monitoring data As previously mentioned when discussing the emission factor verification testing, the calculated number is used for compliance determinations and the emission factor is not an enforceable limit. If data is provided that shows that the factor is incorrect, the Department will incorporate the corrected PSELs and emission factors either as a permit revision or at permit renewal.

COMPLIANCE ASSURANCE MONITORING

24.  Compliance Assurance Monitoring, or “CAM,” plans are required for all “pollutant-specific emissions units” (PSEUs) that meet the following criteria:

24.a.  The emission unit is subject to an emission limitation for the applicable regulated air pollutant,

24.b.  Uses an air pollution control device to achieve compliance with the limitation, and

24.c.  Pre-control potential emissions from the unit exceed the “major source threshold” of the pollutant in question.

Reynolds Metals Company has several emissions units that meet these three criteria at Troutdale Reduction. However, many of the “control devices” at this facility meet the CAM rule’s definition of “inherent process equipment,” and are thus exempt from CAM because they are not considered “control devices” under CAM.

The definition of “inherent process equipment” under the CAM rule is

“Equipment that is necessary for the proper or safe functioning of the process, or material recovery equipment that the owner or operator documents is installed and operated primarily for purposes other than compliance with air pollution regulations. Equipment that must be operated at an efficiency higher than that achieved during normal process operations in order to comply with the applicable emission limitation or standard is not inherent process equipment. For the purposes of this part, inherent process equipment is not considered a control device.”

25.  Listing of All Control Devices

The following table contains a listing of all of the equipment listed in the Title V application as “air pollution control devices.”

Following the table, is a discussion of the determination of applicability or non-applicability for the CAM program.

25.a.  Coke Unloading Dock Baghouse (CD01)

This baghouse removes coke dust from the coke unloading area. This unit’s potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. This baghouse also qualifies as inherent process equipment. Therefore, CAM does not apply to this unit.

25.b.  Green Mill Control System (CD04, CD04a, and CD04b)

These three control devices are installed at the green mill. All three perform or performed the task of raw material conservation. They were installed to capture carbon dust in the green mill and return this valuable raw material to the process. They all meet one critical aspect of the inherent process equipment definition: they are used for material recovery and they were not installed to comply with any air pollution regulation. The original control device (ESP – CD04b) was installed in 1941, predating the 1970 Clean Air Act, and for the purpose of material recovery. The multiclone, CD04a, was constructed as a replacement of the ESP and the baghouse, CD04, was constructed as additional material collection after the multiclone.

25.c.  Butt Shaker Baghouse (CD06)

Once the anodes are used, they are returned to the recovery area for reprocessing. The remaining carbon anode butt is shaken to remove bath contamination and crushed for re-use in the anode production. This unit controls the dust that is generated from the shaking process. The dust is returned to the process. This unit’s potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀ and it would also qualify as inherent process equipment. Therefore, CAM does not apply to this unit.

25.d.  Carbon Bake ESPs (CD07)

These units were installed to control opacity, particulate matter, fluoride and organic matter generated by the anode bake furnaces. They meet the CAM definition of control equipment. These units have potential uncontrolled emissions that exceed the major source thresholds for both criteria pollutants (PM/PM₁₀) and HAPs (hydrogen fluoride and polycyclic organic matter (POM)). CP709 is attached for this emission unit.

25.e.  Carbon Cleaner Baghouse (CD09)

This unit was installed in 1941, which predates any air pollution control limitations. The material collected in this baghouse is returned to the process. Although this unit’s potential uncontrolled emissions of PM/PM₁₀ exceed the major source threshold, we believe that it clearly was not installed to meet air pollution control standards and that it is part of the material recovery system. Therefore, CAM does not apply to this unit.

25.f.  Cast Iron Furnace Baghouses (CD 10N & 10S)

These units were installed to control the emissions from the small iron foundries used in the anode rodding process. These units would not qualify as inherent process equipment. However, their potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to these units.

25.g.  Stub Cleaner Baghouse (CD11)

This baghouse is used on the process for cleaning the anode stubs before the stubs are re-used. This unit would not qualify as inherent process equipment. However, its potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to this unit.

25.h.  Stub Graphite Filter Unit (CD12)

This filter unit is used in the anode rodding process and would not qualify as inherent process equipment. However, its potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to this unit.

25.i.  Tumble Mill Filter Unit (CD14)

This filter unit is used in the anode rodding process and would not qualify as inherent process equipment. However, its potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to this unit.

25.j.  Rod Blast Cabinet Filter Units (CD 15N & 15S)

These units are used on shotblasting cabinets. These units would not qualify as inherent process equipment. However, their potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to these units.

25.k.  Potlining Baghouse (CD16)

This baghouse is used in the process of pot relining and screening materials. In some instances this unit may as inherent process equipment as the materials collected are often returned to the process from which they were generated. However, its potential uncontrolled emissions are less than the major source threshold for PM/PM₁₀. Therefore, CAM does not apply to this unit.

25.l.  Potlining Disposal Building Filter Unit (CD19)

This filter unit controls the emissions from the building used for potdigging. The potential uncontrolled emissions from this operation are much less than 100 tons per year of PM/PM₁₀, therefore, CAM will not apply to this unit.

25.m.  Potroom Baghouse Complex (CD20)

The baghouse complex is the main air pollution control device for the facility. It controls the emissions generated by the pots during normal operations. This unit has potential uncontrolled emissions that exceed the major source thresholds for both criteria pollutants (PM/PM₁₀) and HAPs (hydrogen fluoride). The potroom baghouse complex is subject to CAM and CP709 is attached.

25.n.  Auxiliary Baghouse (Ore Handling) (CD600)

This unit is installed on the ore (alumina) handling system for the potroom baghouse complex. This unit qualifies as inherent process equipment. All material collected by this baghouse is returned to the process. This unit was not installed for the express purpose of meeting air pollution limits; it was installed to conserve raw materials. Therefore, CAM does not apply to this unit.

25.o.  Fresh Ore Tank Baghouses (2) (CD 28A & 28B)

These units are installed on the silo that is used for alumina storage. Since the silo is pneumatically filled, these units are necessary to keep the alumina in the silos. These units qualify as inherent process equipment. All material collected by these baghouses is returned to the process. These units were not installed for the express purpose of meeting air pollution limits; they were installed to conserve raw materials. Therefore, CAM does not apply to these units.

25.p.  200-Ton Air Lift Baghouses (CD 2C & 3C)

These units are part of the pneumatic transfer system for the alumina. Since this is a pneumatic system, these baghouses are necessary to prevent material loss. These units qualify as inherent process equipment. All material collected by these baghouses is returned to the process. These units were not installed for the express purpose of meeting air pollution limits; they were installed to conserve raw materials. Additionally, CD 2C and 3C do not have potential uncontrolled emissions greater than the major source threshold for PM/PM₁₀. For both of the above reasons, CAM does not apply to these units.

25.q.  60-Ton Air Lift Baghouses (CD 4C & 5C)

These units are part of the pneumatic transfer system for the alumina. Since this is a pneumatic system, these baghouses are necessary to prevent material loss. These units qualify as inherent process equipment. All material collected by these baghouses is returned to the process. These units were not installed for the express purpose of meeting air pollution limits; they were installed to conserve raw materials. Therefore, CAM does not apply to these units.

25.r.  Ore Dock Baghouses (CD 27B & 27C)

These units are also used to conserve alumina. These units qualify as inherent process equipment. All material collected by these baghouses is returned to the process. These units were not installed for the express purpose of meeting air pollution limits; they were installed to conserve raw materials. Therefore, CAM does not apply to these units.

25.s.  Crossover Filter (CD37)

This unit is used at a conveyor transfer point and is used to conserve alumina. This unit qualifies as inherent process equipment. This unit was not installed for the express purpose of meeting air pollution limits; it was installed to conserve raw materials. Additionally, CD37 does not have potential uncontrolled emissions greater than the major source threshold for PM/PM₁₀. For both of the above reasons, CAM does not apply to this unit.

25.t.  Screening System Baghouse (CD38)

This is a particle sizing system. This unit collects the dust generated by that sizing and the dust is returned to the process. This unit qualifies as inherent process equipment. This unit was not installed for the express purpose of meeting air pollution limits; it was installed to conserve raw materials. Therefore, CAM does not apply to this unit.

25.u.  Cast House Baghouse (CD29)

This unit was installed to control opacity from the cast house. It meets the CAM definition of control equipment. However, its potential uncontrolled emissions do not exceed 100 tons per year of PM/PM₁₀. Therefore, CAM does not apply to this unit.

25.v.  Anode Paste Scrubber (CD 36S & 36B)

This unit is under installation. It is being installed as a direct result of the primary aluminum MACT standard. The potential uncontrolled emissions of POMs from this scrubber exceed the HAP threshold of 10 tons per year. The anode paste scrubber is subject to CAM and CP709 is attached.

25.w.  Crucible Cleaning Filter Unit (CD39)

This filter unit controls the emissions from the crucible cleaner. The potential uncontrolled emissions from this operation are much less than 100 tons per year of PM/PM₁₀, therefore, CAM will not apply to this unit.

25.x.  Airslide 21 Filter Unit (CD40)

This filter unit will be installed in the future. It will control the emissions from the transfer point from the alumina belt conveyor to airslide 21. The material collected from this transfer point will be returned to the process and the filter unit will meet the definition of inherent process equipment. Additionally, the potential uncontrolled emissions from this operation are much less than 100 tons per year of PM/PM₁₀. For both of the above reasons, CAM will not apply to this unit.

26.  Three devices are therefore subject to the CAM requirements: The Anode Paste Scrubber (CD 36S & 36B), the Potroom Baghouse Complex (CD20), and the Carbon Bake ESPs (CD07). All three of these devices are subject to monitoring requirements under the 40 CFR 63 Subpart LL and in accordance with OAR 340-028-1220(2)(d) the Subpart LL monitoring is presumed to be acceptable, and no further justification is required.

GENERAL BACKGROUND INFORMATION

27.  The proposed permit is a permit renewal and re-opening for a Oregon Title V Operating Permit which was issued on 11/03/97 and was originally scheduled to expire on 10/01/01.

28.  Other permits issued or required by the Department of Environmental Quality for this source include an NPDES permit (NPDES 100757). Reynolds Metals is also registered with the Department as a large quantity hazardous waste generator, ORD 009412677.

29.  This source is located in a maintenance area for ozone and is in attainment for all other pollutants except carbon monoxide.

30.  The source is located within 50 kilometers of a Class I air quality protection area, the Mount Hood Wilderness Area.

31.  The maximum hourly production is 16.4 tons aluminum at the potrooms and 19.4 tons of aluminum at the casthouse. The annual production is 143,500 tons aluminum at the potrooms and 170,000 tons aluminum at the casthouse.

32.  The reduction facility, carbon bakes, and casting facility are operated 24 hours per day, 365 days per year. The anode paste plant facility is operated approximately 16 hours per day, 5 days per week, 52 weeks per year. The normal operating schedule for the rodding room is 8 hours per day, 5 days per week, 52 weeks per year.

COMPLIANCE HISTORY

33.  The facility was inspected on 09/01/99, 08/12/98, and 03/24/97 and was found to be in compliance with Department regulations and permit conditions on all three occasions.

A Semi-Annual Compliance Certification Report for the period January 1 through June 30 1999 was submitted by Reynolds on July 26, 1999. Several permit deviations were reported including seven incidences of excess emissions due to process upsets. In addition, the particulate and fluoride 12 month rolling average limits were exceeded. These deviations were due to process upsets reported during previous compliance certification periods and although they technically occurred during this period, they do not reflect on the operation of the facility during this compliance certification period. The events were considered to be excess emissions due to process upset and these deviations are being treated the same. These excess emissions due to process upset are granted a positive defense against enforcement by Department rule allowing the Department discretion in enforcement.

Three deviations were reported which were not excess emissions. On three occasions, the permittee failed to report excess emissions events within the one-hour period required by permit condition G6.a. A Notice Of Non-Compliance will be issued for these failures after the annual inspection is completed.

A Semi-Annual Compliance Certification Report for the period July 1 through December 31, 1998 was submitted by Reynolds on February 12, 1999. Several permit deviations were reported including addition deviations from the same recordkeeping requirements reported in the previous Semi-Annual Compliance Certification. These deviations occurred before the previous Semi-Annual Compliance Certification was completed, but after July 31, the end of the previous compliance certification period. After these recordkeeping deviations were discovered, there were no addition deviations of those conditions. The Department believes that these deviations are part of the previous violations and are now corrected and no further action was necessary to address these recordkeeping violations.

Three violations of the fluoride emission performance standard were also reported, for months, June, July and August. While these are violations of the permit limits, the Department has determined that the excess emissions were caused by a process upset and were unavoidable, and enforcement action is not warranted under Oregon’s Excess Emissions rules. OAR 340-028-1450 sets out six criteria for determining whether enforcement action is warranted. The Department believes that these criteria have been met because:

1. The first criteria does not apply (this applies to emergency situations only).

2. Reynolds provided immediate notification as required.

3. Reynolds provided the Department with the required information regarding the time and duration of the event, the equipment involved, the steps taken to mitigate emissions and corrective actions taken, and the magnitude and duration of the event.

4. Reynolds took all reasonable precautions to minimize the excess emissions.

5. Reynolds took appropriate remedial action.

6.The event was not due to negligent or intentional operation.

The Department believes that in this situation Reynolds operated and maintained the air pollution control equipment in a manner consistent with good practice for minimizing emissions.

While this event did result in emissions in excess of the performance standard (Lb.-fluoride/ton of Aluminum produced), emissions of fluoride from the facility did not exceed the tons/month permit limits.

A Notice Of Noncompliance # AQ-NWR-98-099 was issued on November 3, 1998 for permit deviations reported in a Semi-Annual Compliance Certification Report for the period January 1 through June 30, as required by the Oregon Title-V Operating Permit. In the Semi-Annual Compliance Certification Report, Reynolds reported numerous permit deviations. Five of the deviations were unavoidable Excess Emissions due to process upsets and the deviation from the Fluoride emissions performance standard for the month of June is due to the start-up of Line 3. These deviations have an affirmative defense against enforcement. No enforcement action followed due to those deviations.

In addition, seven permit monitoring conditions regarding various recordkeeping requirements were violated. These are Class II violations of the permit. The Department considers these violations to be resolved as Reynolds has taken steps to prevent the reoccurrence of these deviations, and no additional action was required.

An annual report and Semi-Annual Compliance Certification Report was submitted by Reynolds on February 13, 1998, for the period November 3 (permit issuance) through December 31, 1997. The permittee certified compliance with all permit conditions, no deviations were reported. The aluminum production facility did not operate during 1997, only the cast house was operating.

34.  During the prior permit period, no nuisance complaints were received.

PUBLIC NOTICE

35.  The draft permit was placed on public notice from November 9, 1999 to December 13, 1999. No comments were received from the public. Reynolds submitted two comments regarding typographical errors in the permit. These errors were corrected.

36.  The proposed permit was sent to the EPA for their 45 day review period and was received by EPA Region 10 on December 22, 1999. The EPA responded on February 15, 1999 stating that they did not object to this permit action, and that the permit was eligible for issuance.

RDB:GFD

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