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Home My WebLink About20093402.tiffSTATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us December 17, 2009 Mr. Steve Moreno Weld County Clerk 1402 N. 17111 Ave. Greeley, CO 80631 Dear Mr. Moreno: Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Colorado Department of Public Health and Environment On December 23, 2009, the Air Pollution Control Division will publish a public notice for Golden Aluminum. Inc. in the Fort Lupton Press. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the date the public notice is published. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B 1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Jacquie N. Barcla Regards, Jacqueline N. Barela Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure i L-1.c.c-ms v/e 1 x'381// 0 9 2009-3402 NOTICE OF A PROPOSED RENEWAL TITLE V OPERATING PERMIT WARRANTING PUBLIC COMMENT NOTICE is hereby given that an application to renew an Operating Permit has been submitted to the Colorado Air Pollution Control Division, 4300 Cherry Creek Drive South, Denver, Colorado 80246-1530, for the following source of air pollution: Applicant Golden Aluminum, Inc. 1405 E. 14th St. Ft. Lupton, CO 80621 Facility: Golden Aluminum, Inc. 1405 F. 14th St. Ft. Lupton, CO 80621 Golden Aluminum, Inc. has applied for an Renewal Operating Permit for their facility in Weld County, CO. This facility manufactures coiled aluminum sheet by recycling Rigid Can Stock (RCS) using prime aluminum and other alloying materials. A copy of the applications, including supplemental information, the Division analysis, and a draft of the Renewal Operating Permit 96OPWE125 has been filed with the Weld County Clerk's office. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Jackie Joyce at the Division at 303-692-3267 to obtain additional information. Any interested person may submit written comments to the Division concerning 1) the sufficiency of the preliminary analysis, 2) whether the permit application should be approved or denied, 3) the ability of the proposed activity to comply with applicable requirements, 4) the air quality impacts of, alternatives to, and control technology required on the source or modification, and 5) any other appropriate air quality considerations. Any interested person may submit a written request to the Division for a public comment hearing before the Colorado Air Quality Control Commission (Commission). If requested, the hearing will be held before the Commission at their regularly scheduled meeting within 60 days of its receipt of the request for a hearing unless a longer time period is agreed upon by the Division and the applicant. The hearing request must: 1) identify the individual or group requesting the hearing, 2) state his or her address and phone number, and 3) state the reason(s) for the request, the manner in which the person is affected by the proceedings, and an explanation of why the person's interests are not already adequately represented. The Division will receive and consider the written public comments and requests for any hearing for thirty calendar days after the date of this Notice. RELEASED TO: Fort Lupton Press on PUBLISHED: December 23, 2009 December 17, 2009 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 96OPWE125 AIRS ID #: 1230089 DATE: December 17, 2009 APPLICANT: Golden Aluminum, Inc. REVIEW ENGINEER: Jacqueline Joyce SOURCE DESCRIPTION Golden Aluminum, Inc. has applied for renewal of their Operating Permit issued for their facility located at 1405 East 14th Street, Ft. Lupton, CO in Weld County. This facility is an aluminum sheet manufacturing plant and is classified under SIC 3353. This facility is located in an area designated as attainment for all criteria pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1. Rocky Mountain National Park, a Federal Class I designated area, is within 100 km of this facility. There are no affected states within 50 miles of this facility. This facility is not categorized as a major stationary source for the purposes of Non -Attainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) review requirements. This facility is not subject to 112(r), the Accidental Release Requirements. The delacquering kiln and the melt area baghouse are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64. FACILITY EMISSION SUMMARY Emission Unit Potential (Permitted) Emissions (tons/yr) PM PM,o NOx CO VOC Lead HAPs S001 — preheaters, shredders, cyclones 9.8 9.8 0.03 S002 — delaquering kiln 1.54 1.54 4.97 3.33 2.28 0.32 0.44 S003 -S005 — Melters # 1 thru 3 37.6 37.6 70.6 23.85 8.06 0.53 S006 — Melt Area Baghouse 11.90 11.90 3.26 S008 — Hot Mill 3.9 3.9 S009 — Two (2) Annealling Furnaces 1.38 1.38 4.22 3.54 4.21 0.08 S010 — Cold Mill 9.15 9.15 67.38 S011 — Coil Coating Line 0.86 0.86 11.28 9.47 14 8.21 Total 76.13 76.13 91.07 40.19 95.93 0.32 12.55 EMISSION SOURCES The following discussion identifies the significant changes that were made in the renewal permit. General Section II Changes — Many of the Conditions were reformatted to make the requirements more clear. The permit was revised to require the source to maintain 12 -month rolling totals of emissions for all emission units. In addition, the opacity monitoring language was revised to make it clear when the Method 9 observation was to be conducted and to specify that the Method 9 shall be conducted by a certified observer and that records of the method 9 observations be kept on site. Section 11.1: Prebreakers, Shredders and Cyclones with Baghouses — The short term (lb/hr) PM emission limitation was corrected. Section 11.3 and 4: Melters and Melt Area Baghouse — The permit was revised to allow coated charge to be processed in any of the three melter sidewells and allows coated charge to be processed in any two sidewells at the same time provided a performance test is conducted. Section 11.6 and 7: Annealing Furnaces and Cold Mill — Corrected the short-term (lb/hr) PM emission limitations citation and equation. Section 11.8: Coil Coating— Condition 8.5 was revised to more appropriately address the NSPS TT requirements and Condition 8.9 was revised because it repeats most of the NSPS TT requirements. Section 11.9: Facility Wide HAP limits — To be more consistent with other permits and Division policy, the facility wide HAP limits were set at 8 tons/yr of any single HAP and 20 ton/yr of combined HAPS rather than the current permit limits of less than 10 tons/yr (single HAP) and 25 tons/yr (combined HAPS). Section 11.10 - Secondary Aluminum MACT Requirements — The permit included many requirements that did not apply to equipment at this facility and excluded other requirements that do apply. Therefore, the permit was revised to reflect the MACT requirements that apply to the facility. The technical review document provides more information on the specific changes to this section of the permit. Section 11.11 and Appendix H — CAM requirements — Since daily visible emission observations and pressure drop readings are included in Section II of the permit as periodic monitoring, these indicators were removed from the CAM plan (for the PM and PM10 emission limitations). The CAM requirements were combined into one table and the plan was revised to be more clear and consistent with the MACT requirements. ALTERNATIVE OPERATING SCENARIOS Removed the alternative operating scenario (AOS) for processing coated charge in the sidewell of Melter #2 (S004) as an alternative to the sidewell of Melter #3 (S005). Section II. 3 of the permit clearly indicates that all Melter sidewells can process coated charge; therefore this AOS is not necessary. l• TECHNICAL REVIEW DOCUMENT for RENEWAL / MODIFICATION TO OPERATING PERMIT 96OPWE125 Golden Aluminum, Inc. Weld County Source ID 1230089 Prepared by Jacqueline Joyce April, August and September 2009 I. Purpose: This document establishes the decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewal and modification of the Operating Permit for Golden Aluminum, Inc. The current Operating Permit for this facility was issued on July 1, 2005 and expires on July 1, 2010. The source submitted a renewal application on July 1, 2009. Prior to submittal of the renewal application, the source submitted applications on April 1 and 6, 2009 requesting that the permit be modified to allow coated charge to be processed in all three sidewells of the melters and to allow coated charge to be processed in the sidewells of two melters at the same time. This document is designed for reference during review of the proposed permit by EPA and for future reference by the Division to aid in any additional permit modifications at this facility. The conclusions made in this report are based on the renewal application submitted on July 1, 2009 and the modification applications submitted on April 1 and 6, 2009, previous inspection reports and various e-mail correspondence, as well as telephone conversations with the applicant. Please note that copies of the Technical Review Document for the original permit and any Technical Review Documents associated with subsequent modifications of the original Operating Permit may be found in the Division files as well as on the Division website at http://www.cdphe.state.co.us/ap/Titlev.html. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Any revisions made to the underlying construction permits associated with this facility made in conjunction with the processing of this operating permit application have been reviewed in accordance with the requirements of Regulation No. 3, Part B, Construction Permits, and have been found to meet all applicable substantive and procedural requirements. This operating permit incorporates and shall be considered to be a combined construction/operating permit for any such revision, and the permittee shall be allowed to operate under the revised conditions upon issuance of this operating permit without applying for a revision to this permit or for an additional or revised construction permit. II. Description of Source This facility is an aluminum sheet manufacturing plant, which falls into the Standard Page 1 Industrial Classification 3353. Golden Aluminum manufactures coiled aluminum sheet by recycling Rigid Can Stock (RCS) using prime aluminum and other alloying materials. The RCS is shredded to expose the coating, then sent to a delaquering kiln to remove the coatings. The shreds are then melted in two of three furnaces, plant scrap is melted in any of the three furnaces.--The-shreds are -then -mixed with prime aluminum and alloying elements. The molten aluminum goes through a series of degassing boxes. The aluminum is solidified at the caster, then the cast sheet is sent to the hot mill where it is coiled then to either the annealing processes or to the cold mill. The coils are processed to customer specifications then sent to the tab wash line or coating line. After the tab wash the coils are then slit and packaged. After the coating line the coils are cured in a five oven process, cooled and lubricated. The coils are then slit and packaged. The facility is located in Fort Lupton, Weld County. This facility is located in an Area classified as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. The following Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park. Accidental Release Prevention Program (112(r)) This facility is not subject to the provisions of the Accidental Release Prevention Program (112(r)). MACT Requirements This facility is not a major source for hazardous air pollutant (HAP) emissions. However, the facility is subject to the area source (minor source) requirements in 40 CFR Part 63 Subpart RRR, "National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production" The appropriate requirements from 40 CFR Part 63 Subpart RRR have been included in the permit. Compliance Assurance Monitoring (CAM) Requirements The delaquering kiln (S002) is subject to CAM for the HAP (HCI) emission limitations and the melt area baghouse (S006) is subject to CAM for the PM, PM10 and HAP (HCI) limitations. CAM requirements for these units were included in the July 1, 2005 renewal permit. The summary of emissions that was presented in the Technical Review Document for the previous renewal permit has been modified to reflect the updated potential to emit (PTE) due to changes that may have occurred in emission limitations and/or the removal of equipment since the previous permit was issued. Emissions (in tons/yr) at the facility are as follows: Page 2 Emission Unit Potential (Permitted) Emissions (tons/yr) PM PKo NOx CO VOC Lead HAPs S001 — preheaters, shredders, cyclones 9.8 9.8 See Table on Page 13 S002 — delaquering kiln 1.54 1.54 4.97 3.33 2.28 0.32 S003 -S005 — Melters # 1 thru 3 37.6 37.6 70.6 23.85 8.06 S006 — Melt Area Baghouse 11.90 11.90 S008 — Hot Mill 3.9 3.9 S009 — Two (2) Annealling Furnaces 1.38 1.38 4.22 3.54 4.21 S010 — Cold Mill 9.15 9.15 67.38 S011 — Coil Coating Line 0.86 0.86 11.28 9.47 14 Total 76.13 76.13 91.07 40.19 95.93 0.32 12.55 Potential to emit is based on permitted emissions. The source reports PTE as actual emissions; therefore, actual emissions are not shown. In the above table, the breakdown of HAP emissions by emission unit and individual HAP is provided on page 13 of this document. Except for the coil coating line, HAP emissions are based on the emission factors included in the permit and permit limits for material processing and/or fuel consumption. For the coil coating line, emissions from coatings are based on the estimates provided in the synthetic minor permit application submitted on October 29, 2002 and emissions from fuel burning are based on the permitted fuel consumption limit and the emission factors included in the permit. Note that the facility is subject to a facility wide HAP limit to keep emissions below the major source levels (10 tpy of any individual HAP and 25 tpy of combined HAPs). It should be noted that a Title V Operating Permit for this facility is not required, since the source is not major for criteria pollutants and the source took limits on HAP emissions to become a minor (area) source for HAPS (less than 10 tpy of any individual HAP and less than 25 tpy of combined HAPS) in a facility wide construction permit issued on March 21, 2003. At the time of that construction permit issuance, area sources were (and still are) subject to some requirements in the Secondary Aluminum Production MACT (40 CFR Part 63 Subpart RRR), but could be deferred from filing a Title V permit application until December 9, 2004. Therefore, at the time of issuance of the construction permit to make the facility a minor source for HAPS, the Title V permit could have been cancelled. EPA recently promulgated revisions to 40 CFR Part 63 Subpart RRR to completely exempt area sources from the obligation to obtain a Title V permit (published in the Federal Register on December 19, 2005). Therefore, at this time, the source is not required to have a Title V permit. The source has elected to retain their Title V permit. Page 3 III. Discussion of Modifications Made Source Requested Modifications In their modification applications submitted on April 1 and 6, 2009, the source requested that the permit be revised to allow coated charge to be processed in the sidewell of the third melter (processing coated charge is currently allowed in the sidewells of two melters) and that the permit allow for processing of coated charge in two sidewells at the same time. No increase in permitted emissions has been requested with this application. In their application, the source indicated that this modification met the requirements for a minor permit modification and requested that the minor permit modification procedures in Colorado Regulation No. 3, Part C, Section X be used. Colorado Regulation No. 3, Part C, Section X.A identifies those modifications that can be processed under the minor permit modification procedures. Specifically, minor permit modifications "are not otherwise required by the Division to be processed as a significant modification" (Colorado Regulation No. 3, Part C, Section X.A.6). The Division requires that "any change that is considered a modification under Title I of the Federal Act" be processed as a significant permit modification (Colorado Regulation No. 3, Part C, Section I.A.7). Part G of Regulation 3 Section I.L, revisions adopted July 15, 1993, Subsection I.G for modifications) describes more specifically what constitutes a modification under Title I of the Federal Act and it indicates that a modification which triggers either Section 111 (NSPS) or 112 (MACT) requirements is considered a Title I modification. The third sidewell is not currently subject to MACT requirements, however, allowing the third sidewell to process coated charge will make that sidewell subject to MACT requirements. Although the third sidewell is not currently subject to MACT requirements, the other two sidewells are and the appropriate MACT requirements are included in the permit. Therefore, since the MACT requirements are already in the permit, the Division considers that no new MACT requirements are triggered and this modification can be processed as a minor modification. Modeling No changes to emission limitations are being made with this modification; therefore, no modeling is required. The requested modification was addressed in the permit as follows: Section 1.2 (Alternative Operating Scenarios) As long as the permit addresses processing of coating charge in any of the three melter sidewells, the Division doesn't consider that it is necessary to consider the processing of coated materials in melters #1 and #2 to be an AOS, in lieu of using melter #3. Sections 11.3 and 4 Page 4 Conditions 3.8 and 3.9 were combined. The melters are only subject to MACT requirements when the melter sidewells are processing coated charge. Conditions 3.9.1 (not necessary and sidewell throughput and emission limitations are addressed in Section 11.4) and 3.9.4 (no longer considered an AOS) were removed. In addition the "note" regarding the melt area baghouse in Condition 3.9.3 was removeri,._a_condition regarding MACT requirements was added to Section 11.4 of the permit. The new permit condition (Condition 3.8) specifies that coated charge only processed in one sidewell at a time (unless a performance test is conducted for two sidewells operating at the same time), requires that operation of the sidewells meet the MACT requirements and sets out specific recordkeeping requirements. The note under Condition 4.5 that referred to Condition 3.9 (regarding MACT conditions) was removed. The Division included the MACT language in Condition 3.8 of the permit in "new" Condition 4.6. July 1, 2009 Renewal Application In their renewal application, the source requested that the units in the summary table in Section 11.8 (coil coating line) be corrected. The source indicates that the units should be in kft2/yr, rather than ft2/yr. The Division reviewed our files and the APEN submitted with the October 29, 2002 application to revise their permits to take federally enforceable HAP limits and to make various other modifications to their facility (including increasing the coating line speed), indicated that the requested throughput limit for the coating line was indeed in the units of kft2/yr, rather than ft2/yr. Therefore, this error was corrected as requested. Other Modifications In addition to the requested modifications made by the source, the Division used this opportunity to include changes to make the permit more consistent with recently issued permits, include comments made by EPA on other Operating Permits, as well as correct errors or omissions identified during inspections and/or discrepancies identified during review of this modification. The Division has made the following revisions, based on recent internal permit processing decisions and EPA comments on other permits, to the Golden Aluminum, Inc. Operating Permit with the source's requested modifications. These changes are as follows: Section I — General Activities and Summary • Revised the description under Condition 1.1 to address the attainment status of the area in which the facility is located. • Added Section IV, 3.d as state -only conditions to Condition 1.4. Note that Section IV, Condition 3.d (affirmative defense provisions for excess emissions during malfunctions) is state -only until approved by EPA in the SIP. Page 5 • Made minor revisions to the language in Condition 3.1 to be more consistent with other permits and to correct citations that changed based on revisions to Reg 3. In addition, revised this condition to address the attainment status of the area in which the facility is located. • Added a column to the table in Condition 5.1 indicating the date the equipment commenced operation. In addition revised the descriptions of the baghouses to indicate they are lime injected. Added a note to the table indicating that emissions from the melter sidewells are routed to the melt area baghouse. Section II — General • For permit conditions requiring twelve month rolling totals, the language "shall be maintained for demonstration of compliance" was replaced with "shall be used to monitor compliance". • Indicated the source of the emission factors included in the permit. Section 11.1 — Prebreakers, Shredders and Cyclones with Baqhouse • The language in this condition was reformatted to make the requirements more apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • Removed the language in the table under Condition 1.1 regarding a performance test. No performance test requirements for these units are included in the permit. • Added a requirement to calculate emissions on a 12 -month rolling total. The Division typically requires emission calculations at for purposes of APEN reporting. For emission units with permitted emissions, the calculations are typically on a twelve month rolling total. • The PM short term (lb/hr) limit is incorrect, this has been revised. • Combined "old" conditions 1.1.1 and 1.1.2 ("new" condition 1.1.3.1). • Revised the language in "old" condition 1.1.3 ("new" condition 1.1.3.2) to indicate specifically when a Method 9 will be conducted and to specify that the Method 9 be conducted by a certified observer and that records of the Method 9 observations be kept on site. • Minor revisions to the monitoring language for the opacity requirements (Conditions 1.3 and 1.4) were made in both the table and text. Section 11.2 — Delaquerinq Kiln • The language in this condition was reformatted to make the requirements more Page 6 apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • _Removed thfianguage in the table under Condition 2.1 regarding a source test. No performance test requirements for this unit are included in the permit. • Combined "old" conditions 2.1.2.1 and 2.1.2.2 ("new" condition 2.1.4.1). • Revised the language in "old" condition 2.1.2.3 ("new" condition 2.1.4.2) to indicate specifically when a Method 9 will be conducted and to specify that the Method 9 be conducted by a certified observer and that records of the Method 9 observations be kept on site. • Added language to Condition 2.3 to indicate that fuel allocation shall be conducted in accordance with Appendix G. • Minor revisions to the monitoring language for the opacity requirements (Conditions 2.4 and 2.5) were made both in the table and text. • Added the MACT emission limitation in the table under condition 2.6. Section 11.3 — Main Hearths (Melters) • Added language to clarify that the PM and aluminum consumption limits only apply to the main hearths, not the melter sidewells. • Revised Condition 3.5 to indicate that fuel consumption is determined by the fuel meter, rather than the allocation calculation. This condition was to be corrected with the last permit modification but was inadvertently left unchanged. • Conditions 3.8 and 3.9 have been combined. The melters are only subject to MACT requirements when the melter sidewells are processing coated charge. Section 11.4 — Melt Area Baghouse • Revised the title of this section to add (Melters #1, #2 and #3 sidewells), to make it clear that the baghouse controls emissions from these units. • The language in this condition was reformatted to make the requirements more apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • Removed Condition 4.1.3 and included requirements (in "new" Condition 4.1.2) to calculate emissions on a twelve month rolling total, as this is more consistent with other Title V permits. • Combined "old" conditions 4.1.1.1 and 4.1.1.2 ("new" condition 4.1.3.1). Page 7 • Revised the language in "old" condition 4.1.1.3 ("new" condition 4.1.3.2) to indicate specifically when a Method 9 will be conducted and to specify that the Method 9 be conducted by a certified observer and that records of the Method 9 observations be kept on site. • Minor revisions to the monitoring language for the opacity requirements (Conditions 4.3 and 4.4) were made both in the table and text. Section 11.5 — Hot Mill • The language in this condition was reformatted to make the requirements more apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • Removed Condition 5.1.2 and included requirements (in "new" Condition 4.1.2) to calculate emissions on a twelve month rolling total, as this is more consistent with other Title V permits. • Combined "old" conditions 5.1.1.1 and 5.1.1.2 ("new" condition 5.1.3.1). • Revised the language in "old" condition 5.1.1.3 ("new" condition 5.1.3.2) to indicate specifically when a Method 9 will be conducted and to specify that the Method 9 be conducted by a certified observer and that records of the Method 9 observations be kept on site. • Removed "old" condition 5.1.1.4 as the requirements in this condition are really covered by "new" condition 5.1.3.1. • Minor revisions to the monitoring language for the opacity requirements (Conditions 5.4 and 5.5) were made both in the table and text. Section 11.6 — Annealing Furnaces • The language in this condition was reformatted to make the requirements more apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • Corrected the short-term (lbs/hr) PM emission limitations citation and equation. Section 11.7 — Cold Mill • The language in this condition was reformatted to make the requirements more apparent. In addition, some minor language changes were made in this process. It should be noted that with the formatting change, the numbers of several permit conditions will also change. • Corrected the short-term (lbs/hr) PM emission limitations citation and equation. Page 8 • Removed "old" Condition 7.1.2 and included requirements (in "new" Condition 7.1.2) to calculate emissions on a twelve month rolling total, as this is more consistent with other Title V permits. • Combined "old" conditions 7.1.1.1 and 7.1.1.2 ("new" condition] 'L3_1)__ • Revised the language in "old" condition 7.1.1.3 ("new" condition 7.1.3.2) to indicate specifically when a Method 9 will be conducted and to specify that the Method 9 be conducted by a certified observer and that records of the Method 9 observations be kept on site. • Removed "old" condition 7.1.1.4 as the requirements in this condition are really covered by "new" condition 7.1.3.1. • Minor revisions to the monitoring language for the opacity requirements (Conditions 7.3 and 7.4) were made both in the table and text. Section 11.8 — Coil Coating • Minor language changes were made to Conditions 8.1 through 8.4. • Revised Condition 8.5 to more appropriately address the NSPS TT requirements. • Based on EPA's response to a petition on another Title V operating permit, minor language changes were made to Conditions 8.7 and 8.8 to clarify that only natural gas is permitted to be used as fuel for the thermal oxidizer. • The language in Condition 8.9 was revised as this language appears to repeat many of the NSPS requirements. Section 11.9 — Facility Wide HAP Limits • In order to be more consistent with the way Division sets synthetic minor HAP limits, the facility wide HAP limits were revised to be set at 8 tons/yr for any individual HAP and 20 tons/yr of combined HAPS. • Other minor language changes were made in both the table and the text. Section 11.10 - Secondary Aluminum MACT requirements There are several requirements included in this section that don't apply to the Golden Aluminum facility. In addition, there are requirements that do apply that are not included. Therefore, the appropriate sections have been added and removed. Sections that were removed include the following: • Under monitoring requirements (63.1510): Conditions 10.16 (group 1 furnaces), 10.17 (scrap inspection program for group 1 furnaces) and 10.18 (monitoring of Page 9 scrap contamination level by calculation method for group 1 furnace) were removed since the group 1 furnaces are equipped with add-on air pollution control device. • Under monitoring requirements -(6S.-1-5-1-0): Condition 10.20 was removed since the source demonstrates compliance with the alternative method specified in 63.1510(u), which is included in Condition 10.21. • Under performance test/compliance demonstration general requirements (63.1511): Removed Condition 10.26 (repeat tests) since it only applies to major sources. Removed Condition 10.27 (testing of representative emission units) since this condition only applies to group 1 furnaces without add-on control devices. • Under performance test/compliance demonstration requirements and procedures (63.1512): Removed Condition 10.30 (secondary aluminum processing units), since the performance testing required by this condition is used to determine the emission rates to be used in 63.1510(t) (Condition 10.20), which is not the compliance method the source is following (see above under "monitoring requirements (63.1510)"). Sections that were added include the following: • Under monitoring requirements (63.1510): Added requirements for fabric filters and lime -injected fabric filters (63.1510(0), fabric filter inlet temperature (63.1510(h)), lime injection (63.15100)), total reactive flux injection rate (63.1510(j)) and alternative monitoring method for lime addition (63.1510(v)). • Under performance test/compliance demonstration general requirements (63.1511): Added requirements for the initial performance test (63.1511(b)). • Under performance test/compliance demonstration requirements and procedures (63.1512): Added requirements for group 1 furnace with add-on air pollution control devices (63.1512(d)), afterburner (63.1512(m)), inlet gas temperature (63.1512(n)), flux injection rate (63.1512(o)), lime injection (63.1512(p)) and bag leak detection system (63.1512(q)). • Added a new condition for the applicability of general conditions (63.1518). Other corrections were made to this section as follows: • In Condition 10.1, removed the reference to Conditions 10.3.1 through 10.3.5, there are no such conditions in this permit and the limitations in § 63.1505(d) were not included in the permit. • Replaced "SAPU" in Condition 10.2 with "secondary aluminum processing unit (SAPU)". • Added the requirements in § 63.1505(1)(7) as Condition 10.2.3. Page 10 • Removed the second paragraph under "§ 63.1506 Operating Requirements" as the language in this paragraph (63.1506(a)(2)) has been revised in the regulation and is no longer applicable to this facility. • Moredetailed information the appropriate regulations were added to Conditions 10.7, 10.8, 10.9. Section 11.11 and Appendix H — CAM requirements • Since daily visible emission observations and pressure drop reading are included in Section II of the permit as periodic monitoring, these indicators were removed from the CAM plan (for PM and PM10 emission limitations). The CAM plan will be based on the bag leak detection system (for PM and PM10 emission limitations). • Combined CAM requirements into one table. Revised the language somewhat to be more clear as to what excursions are (the previous permit used the term deviation, as well as excursion) and to be more consistent with the MACT requirements. • Other minor language changes were made to the CAM requirements. Section III — Permit Shield • Due to formatting changes and renumbering of some permit conditions, the condition numbers in Section 111.3 (Streamlined Conditions) were corrected. • Revised the table for Streamlined Conditions (Section 111.3) to indicate the different short term (lbs/hr) PM limitations) Section IV — General Conditions • Added a version date to the General Conditions. • The title for Condition 6 was changed from "Emission Standards for Asbestos" to "Emission Controls for Asbestos" and in the text the phrase "emission standards for asbestos" was change to "asbestos control". • The upset requirements in the Common Provisions Regulation (general condition 3.d) were revised December 15, 2006 (effective March 7, 2007) and the revisions were included in the permit. Note that these provisions are state -only enforceable until approved by EPA into Colorado's state implementation plan (SIP). • Replaced the reference to "upset" in Condition 5 (emergency provisions) and 21 (prompt deviation reporting) with "malfunction". Appendices Page 11 • On the first page of the appendices, changed the descriptions of Appendices B and C to match the header titles for these appendices. • Replaced Appendices B and C with the latest versions. • Changed the mailing address for EPA in Appendix D. • Corrected Appendix G to indicate that Units S003 - S005 and S007 do not use the fuel allocation methodology. Units S003 - S005 have individual fuel meters and S007 has been removed from the facility. Page 12 Total HAP Emissions (tons/yr) N o W CO N M 0.28 2.08 co co co U) r~ O) 0.44 r O W 00 N O W M cO 0 W N" O ) W a ,n in S011 Coil Coating* I. O N CO N in O rn O 0.44 T O W 0O N c O W 47 O ir O W CO N O O_ W p .= N 00 O O -O (/) O U Q O O S009 Annealing N O I W o co r1 M O I W r` T 6 cr O I W co Q) tri V' O W v.) v. T OD Q O c) C Q O O 2 Q O O S006 Melt Baghouse N Q W 0 O c) In Q) N O N O CD N (h S003 - S005 Melters r C? W r T tri N O W M T N V O W CO CS) In V- O W CO (D Q) Ln CJ S002 Dela . Kiln I W M co cn C7 W UC) 2.25E-03 1 W O cc) co W p r O .``.. Soo1 Shredders N O W (,) cO N M o O C c0 z Metal HAPs HCI HF methyl ethyl ketone a) c a) >-, Eethyl benzene 2-butoxyethanol methyl isobutyl ketone hexane I formldehyde benzene toluene O N (� Q) co C C Q) 0 E O n� LL N O Cr) N 0 c 0 a) .2• ) O CI c1 E d • C 28 O N E -o U ) a) E L ` C � >. 0- w C .C w C 'D f0 o (i) Q. U) r C N O_ ( • (0 • I - a) C D rn • M a c N O C 8 in E o O � N • c C O O_ •N g N E a) Q N) d N Q a 2Q Colorado Department of Public Health and Environment OPERATING PERMIT Golden Aluminum, Inc. First Issued November 1, 1999 Renewed: DRAFT AIR POLLUTION CONTROL DIVISION COLORADO OPERATING PERMIT FACILITY NAME: Golden Aluminum Inc. FACILITY ID: 1230089 RENEWED: EXPIRATION DATE: MODIFICATIONS: See Appendix F of Permit OPERATING PERMIT NUMBER 96OPWE125 Issued in accordance with the provisions of Colorado Air Pollution Prevention and Control Act, 25-7-101 et sec . and applicable rules and regulations. ISSUED TO: Golden Aluminum Inc. 1405 East 14`x' Street Fort Lupton, CO 80621 PLANT SITE LOCATION: 1405 East 14`t' Street Fort Lupton, CO 80621 Weld County INFORMATION RELIED UPON Renewal Operating Permit Application Received: And Additional Information Received: July 1, 2009 April 1 and 6, 2009 Nature of Business: Aluminum Sheet Manufacturing Primary SIC: 3353 RESPONSIBLE OFFICIAL Name: Title: Phone: Mark Selepack V. P. of Operations (303) 654-8384 FACILITY CONTACT PERSON Name: Don Forchette Title: Environmental Engineer Phone: (303) 654-8366 SUBMITTAL DEADLINES Semi -Annual Monitoring Period: Semi -Annual Monitoring Report: Annual Compliance Period: Annual Compliance Certification: EXAMPLE (November 1 - April 30, May 1 - October 31) EXAMPLE (December 1, 2005 & June I, 2006 and subsequent years) EXAMPLE (Begins November 1 to October 31) EXAMPLE (December 1, 2005 and subsequent years) Note that the Semi -Annual Monitoring Report and the Annual Compliance Certification must be received at the Division office by 5:00 p.m. on the due date. Postmarked dates will not be accepted for the purposes of determining the timely receipt of those reports. TABLE OF CONTENTS: SECTION I General Activities and Summary -L — 1. Permitted Activities 1 2. Alternate Operating Scenarios 2 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (P SD) 2 4. Accidental Release Prevention Program (112(r)) 2 5. Summary of Emission Units 3 6. Compliance Assurance Monitoring (CAM) 4 SECTION II - Specific Permit Terms 5 1. S001 - Prebreakers, Shredders and Cyclones w/Baghouse 5 2. S002 - Delaquering Kiln w/ Multicyclone, Thermal Oxidizer, and Lime Injected Baghouse 8 3. S003, S004 and S005 - Melters #1, #2 and #3 - Main Hearths 12 4. S006 - Melt Area Baghouse (Melters #1, #2 and #3 Sidewells) 16 5. S008 - Hot Mill w/ Air Purifier 20 6. S009 - Two Annealing Furnaces 22 7. SO10 - Cold Mill w/ Air Purifier 25 8. S011 - Coil Coating Line w/Thermal Oxidizer 28 9. Facility Wide HAP Emission Limits 33 10. National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production 33 11. Compliance Assurance Monitoring 46 SECTION III - Permit Shield 52 1. Specific Non -Applicable Requirements 52 2. General Conditions 52 3. Streamlined Conditions 53 SECTION IV - General Permit Conditions 54 1. Administrative Changes 54 2. Certification Requirements 54 3. Common Provisions 54 4. Compliance Requirements 58 5. Emergency Provisions 59 6. Emission Controls for Asbestos 59 7. Emissions Trading, Marketable Permits, Economic Incentives 59 8. Fee Payment 59 9. Fugitive Particulate Emissions 60 10. Inspection and Entry 60 11. Minor Permit Modifications 60 12. New Source Review 60 13. No Property Rights Conveyed 60 14. Odor 60 15. Off -Permit Changes to the Source 61 16. Opacity 61 TABLE OF CONTENTS: 17. Open Burning 61 18. Ozone Depleting Compounds 61 19. Permit Expiration and Renewal 61 20. Portable Sources 61 21. Prompt Deviation Reporting 61 22. Record Keeping and Reporting Requirements 62 23. Reopenings for Cause 63 24. Section 502(b)(10) Changes 63 25. Severability Clause 63 26. Significant Permit Modifications 64 27. Special Provisions Concerning the Acid Rain Program 64 28. Transfer or Assignment of Ownership 64 29. Volatile Organic Compounds 64 30. Wood Stoves and Wood burning Appliances 65 APPENDIX A - Inspection Information 1 Directions to Plant: 1 Safety Equipment Required- 1 Facility Plot Plan: 1 List of Insignificant Activities- 1 APPENDIX B 1 Reporting Requirements and Definitions 1 Monitoring and Permit Deviation Report - Part I 5 Monitoring and Permit Deviation Report - Part II 7 Monitoring and Permit Deviation Report - Part III 9 APPENDIX C 1 Required Format for Annual Compliance Certification Reports 1 APPENDIX D 1 Notification Addresses 1 APPENDIX E 1 Permit Acronyms 1 APPENDIX F 1 Permit Modifications 1 APPENDIX G 1 Fuel Allocation 1 APPENDIX H 1 Compliance Assurance Monitoring Plan 1 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 1 1. Permitted Activities 1.1 SECTION I - General Activities and Summary This facility is an aluminum sheet manufacturing plant, which falls into the Standard Industrial Classification 3353. Golden Aluminum manufactures coiled aluminum sheet by recycling Rigid Can Stock (RCS) using prime aluminum and other alloying materials. The RCS is shredded to expose the coating, then sent to a delaquering kiln to remove the coatings. The shreds are then melted in two of three furnaces, plant scrap is melted in any of the three furnaces. The shreds are then mixed with prime aluminum and alloying elements. The molten aluminum goes through a series of degassing boxes. The aluminum is solidified at the caster, then the cast sheet is sent to the hot mill where it is coiled then to either the annealing processes or to the cold mill. The coils are processed to customer specifications then sent to the tab wash line or coating line. After the tab wash the coils are then slit and packaged. After the coating line the coils are cured in a five oven process, cooled and lubricated. The coils are then slit and packaged. The facility is located in Fort Lupton, Weld County. This facility is located in an Area classified as attainment for all pollutants except ozone. It is classified as non -attainment for ozone and is part of the 8 -hr Ozone Control Area as defined in Regulation No. 7, Section II.A.1. There are no affected states within 50 miles of the plant. The following Federal Class I designated area is within 100 kilometers of the plant: Rocky Mountain National Park. 1.2 Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air pollutants from this facility in accordance with the requirements, limitations, and conditions of this permit. 1.3 This Operating Permit incorporates the applicable requirements contained in the underlying construction permits, and does not affect those applicable requirements, except as modified during review of the application or as modified subsequent to permit issuance using the modification procedures found in Regulation No. 3, Part C. These Part C procedures meet all applicable substantive New Source Review requirements of Part B. Any revisions made using the provisions of Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This Operating Permit incorporates the applicable requirements (except as noted in Section II) from the following Colorado Construction Permit(s): 03WE0032 (facility wide permit issued March 21, 2003 incorporating the provisions of 82WE250-2, 3, 4, 6 thru 8, & 12, 84WE342, 90WE247, and 91 WE864). 1.4 All conditions in this permit are enforceable by US Environmental Protection Agency, Colorado Air Pollution Control Division (hereinafter Division) and its agents, and citizens unless otherwise specified. State -only enforceable conditions are: Permit Condition Number(s): Section IV — Conditions 3.d, 3.g (last paragraph), 14 and 18 (as noted). Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 2 1.5 All information gathered pursuant to the requirements of this permit is subject to the —Recordkeeping and Reporting requirements listed under Condition 22 of the General Conditions in Section IV of this permit. 2. Alternate Operating Scenarios 2.1 The permittee shall be allowed to make the following changes to its method of operation without applying for a revision of this permit. 2.1.1 No separate operating scenarios have been specified. 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 3.1 Based on the information provided by the applicant, this source is categorized as a minor stationary source (Potential to Emit < 250 tons/yr) for PSD as of the issuance date of this permit. Any future modification at this facility which is major by itself (i.e. Potential to Emit of > 250 tons/year) for any pollutant listed in Regulation No. 3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. In addition, future modifications at this facility may result in the facility being classified as a major stationary source for PSD. Once that threshold is exceeded, future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Section II.A.26 and 42) for any pollutant as listed in Regulation No. 3, Part D, Section II.A.42 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. 3.2 Based on the information provided by the applicant, this facility is categorized as a minor stationary source (Potential to Emit of neither VOC nor NOx > 100 Tons/Year) for NANSR. Any future modification at this facility, which is major by itself (Potential to Emit > 100 TPY of either VOC or NOx) may result in the application of the NANSR review requirements. In addition, future modifications at this facility may result in the facility being classified as a major stationary source for NANSR. Once that threshold is exceeded, future modifications at this facility resulting in a significant net emissions increase (see Regulation No. 3, Part D, Section II.A.26 and 42) for either VOC or NOx may result in the application of the NANSR review requirements. 3.3 There are no other Operating Permits associated with this facility for purposes of determining applicability of NANSR or PSD review regulations. 4. Accidental Release Prevention Program (112(r)) 4.1 Based on the information provided by the applicant, this facility is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act). Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 3 5. Summary of Emission Units 5.1 The emissions units regulated by this permit are the following: Emission Unit Number AIRS Stack Number Facility Identifier Description Startup Date Pollution Control Device S001 016 P001 Three Modified Miller Shredders and Fisher- Klosterman Cyclones XQ240, Design Rated at 3 TPH each, Baghouse Controlled. 1990 Day Co., IG013831 Baghouse S002 002 P002 Custom Apros Delaquering Kiln, 14 MMBtu Natural Gas Fired Burner, Design Rated at 10 TPH, SN: BIN221, Controlled by a Multicyclone, a Thermal Oxidizer, and a Lime Injected Baghouse. 1983 Lime -Injected Baghouse 2002/2003 Apros Thermal Oxidizer and Lime Injected Baghouse S003 003 P003 Custom Melter # 1 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. 1982 Burners Replaced 2006 Uncontrolled* S004 003 P004 Custom Melter # 2 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. 1982 Burners Replaced 2006 Uncontrolled* S005 003 P005 Gillespie/Powers Metter # 3 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas- Fired), Design Rated at 14.95 TPH, SN: 0286. 1984 Burners Replaced 2006 Uncontrolled* S006 019 P006 Melt Area Baghouse for Sidewell Melting, Degassing and Filtration, Design Rated at 15 TPH. 1992 Interel Co., #2.5/7.5/2.0 Lime -Injected Baghouse S008 006 P008 Hot Mill, Design Rated at 13.5 TPH, Controlled with an Air Purifier Centrifugal Separator. 1982 Busch Company, 42" Purifier S009 008 P009 Two Custom Secowarwick Annealing Furnaces, Two U -Tube 17.5 MMBtu Natural Gas Fired Burners, Design Rated at 78 TPH each. 1982 Uncontrolled SO10 007 P010 Davy -McKee Cold Rolling Mill 2 -STD, Design Rated at 35 TPH, Controlled with a Air Purifier Centrifugal Separator. 1982 Busch Company, 54" Purifier S011 018 P011 Custom Hunter Coil Coating Line, 26.1 MMBtu Grace Tec Natural Gas Fired Burner, Controlled with a Thermal Oxidizer. 1982 Thermal Oxidizer 1996 Line Speed Increased 2002/2003 Grace Tec Systems: Shadow TM S- 144 Thermal Oxidation Unit missions from the inciter sidewells are vented to the Melt Area Baghouse (S006) Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 4 6. Compliance Assurance Monitoring (CAM) 6.1 The following emission points at this facility use a control device to achieve compliance with an emission limitation or standard to which they are subject and have pre -control emissions that exceed or are equivalent to the major source threshold. They are therefore subject to the provisions of the CAM program as set forth in 40 CFR Part 64 as adopted by reference into Colorado Regulation No. 3, Part C, Section XIV: S002 — Delacquering Kiln (Condition 2.7) S006 — Melt Area Baghouse (Condition 4.5) See Section II, Condition 11 for specific CAM requirements. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 5 SECTION II - Specific Permit Terms 1. 5001 - Prebreakers, Shredders a�cn Cyelies w/Bighouse Parameter Permit Condition Number Limitations (for all three together) Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 1.1 For each shredder: 7.09 lbs/hr 9.80 tons/yr 0.522 lb/Ton Al Processed Recordkeeping and Calculation and Filter Media Roll and Baghouse Maintenance Monthly See Conditions 1.1.3 and 1.1.4 PM10 NA 9.80 tons/yr 0.522 lb/Ton Al Processed Production Rate 1.2 NA 37,500 tons/yr NA Recordkeeping Monthly Opacity 1.3 Except as provided for in Condition 1.4, below, not to exceed 20% NA Visible Emission Observations Daily 1.4 During certain operating conditions, not to exceed 30% 1.1 Particulate Matter emissions are subject to the following limitations: PM emissions from each shredder shall not exceed the short term (lbs/hr) limit stated above (Colorado Regulation No. 1, Section III.C.I.a). In the absence of credible evidence to the contrary, compliance with the short term PM limit is presumed provided that the requirements in Conditions 1.1.3 and 1.1.4 are met. Note that the numeric PM standards were determined using the design rate for the shredders (3 tons/hr per shredder) in the following equation: PE = 3.59 x (P)o.62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 1.1.2 Emissions of PM and PMIo from all three shedders together shall not exceed the annual limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 90WE247) as modified under the provisions of Section I, Condition 1.3). Monthly emissions from all three shredders together shall be calculated by the end of the subsequent month, using the emission factors in the above table (from 10/29/02 synthetic minor (HAP) permit application — factors based on calculation) in the following equation: Tons/mo = Quantity of Al processed (tons/mo) x EF (lbs/ton Al) 2000 lbs/ton Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 6 Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 1.1.3 Routine maintenance of the filter media roll shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 1.1.3.1 and 1.1.3.2 and record in a log the opacity observations and any action taken as a result of the observations. The baghouse pressure drop shall be monitored and recorded daily. Should the daily recorded baghouse pressure drop be outside the manufacturer's recommendations, the source shall follow the steps in 1.1.3.1, 1.1.3.4, and 1.1.3.5, within one hour of the recorded pressure drop. 1.1.3.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 1.1.3.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 1.1.3.3 Perform any maintenance or adjustments needed on the filter media roll. 1.1.3.4 If the filter media roll pressure drop remains outside of manufacturer's specifications, the filter media roll shall be internally inspected for integrity and overall mechanical efficiency. Necessary repairs shall be made prior to bringing the equipment back on line. Any action taken as a result of pressure drop shall be recorded in a daily log. 1.1.4 The filter media roll shall be internally inspected for integrity and overall mechanical efficiency annually. Records of inspections and results and any corrective actions taken shall be maintained for Division inspection upon request. Operating Permit Number: 96OP W E 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 7 1.2 The processing of recycled aluminum shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 90WE247) as modified under the provisions of Section I, Condition 1.3). Processing rates from all three shredders together shall be measured and recorded each month, and made available to the Division for inspection upon request. Monthly quantities of material processed shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months' data. 1.3 Except as provided for in Condition 1.4, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. I. (Construction Permit 90WE247, and Colorado Regulation No. 1, Section II.A.1) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 1.1.3. 1.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 1.1.3. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 8 2. S002 - Delaquering Kiln w/ Multicyclone, Thermal Oxidizer, and -Lime Injected Baghouse, Parameter Permit Condition Number Limitations Short Tenn Long Term Compliance Emission Factor Monitoring Method Interval PM 2.1 14.97 lbs/hr 1.54 tons/yr Operating: 0.08 lb/ton Al Idle: 7.6 lb/MMscf Recordkeeping and Calculation and Control Equipment Maintenance Monthly See Conditions 2.1.3 through 2.1.5 PMio NA 1.54 tons/yr Operating: 0.08 lb/ton Al Idle: 7.6 lb/MMscf NOx NA 4.97 tons/yr Operating: 0.24 lb/ton Al Idle: 100 lb/MMscf CO NA 3.33 tons/yr Operating: 0.157 lb/ton Al Idle: 84 lb/MMscf VOC NA 2.28 tons/yr Operating: 0.12 lb/ton Al Idle: 5.5 lb/MMscf Lead NA 0.32 tons/yr Operating: 0.0167 lb/ton Al Idle: Neg. Aluminum Consumption 2.2 NA 37,500 tons/yr NA Recordkeeping Monthly Fuel Use 2.3 NA 60.0 MMscf/yr NA Fuel Allocation (See Appendix G) Monthly Opacity 2.4 Except as provided for in Condition 2.5, below, not to exceed 20% NA Visible Emission Observations Daily 2.5 During certain operating conditions, not to exceed 30% MACT Requirements 2.6 5.0 pg of D/F TEQ per Mg of feed/charge See Conditions 2.6 and 10 CAM 2.7 See Conditions 2.7, 11 and Appendix H 2.1 Emissions of air pollutants are subject to the following limitations: 2.1.1 PM emissions shall not exceed the short term (lbs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.l.a). In the absence of credible evidence to the contrary, compliance with the short term PM limit is presumed provided that the requirements in Condition 2.1.4 are met. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 9 Note that the numeric PM standards were determined using the design rate for the kiln (10 tons Al/hr) in the following equation: PE = 3.59 x (P)°.62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 2.1.2 Emissions of air pollutants shall not exceed the annual limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-2), as modified under the provisions of Section I, Condition 1.3). Monthly emissions shall be calculated by the end of the subsequent month using the above emission factors in the above table (Operating factors: NOx, CO, VOC and Pb from 4/5/99 revised Title V application (calculated), PM and PMi° from 10/31/03 Title V renewal application (based on stack test), Idle factors: from AP -42, Section 1.4 (3/98), Tables 1.4-1 and 1.4-2) in the following equations: While kiln is delaquering: tons/month = Throughput (tons Al/month) x EF (lb/tons Al) / 2000 lbs/ton While kiln is idle (just burning natural gas): tons/month = Throughput Idle time only (MMscf/month) x EF (Ib/MMscf) / 2000 lbs/ton Total emissions = operating emissions + idle emissions 99.0% control efficiency for PM may be applied provided the baghouse is operated in accordance with the requirements in Condition 2.1.4, below. Monthly emissions shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be maintained for Division inspection upon request. 2.1.3 Routine maintenance of the thermal oxidizer shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. 2.1.4 Routine maintenance of the baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 2.1.4.1 and 2.1.4.2 and record in a log the opacity observations and any action taken as a result of the observations. The baghouse pressure drop shall be monitored and recorded daily. Should the daily recorded baghouse pressure drop be outside the manufacturer's recommendations, the Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit /4 96OPWE125 Golden Aluminum, Inc. Page 10 source shall follow the steps in 2.1.4.1, 2.1.4.3, and 2.1.4.4, within one hour of the recorded pressure drop. - 2.1.4.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 2.1.4.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 2.1.4.3 Perform any maintenance or adjustments needed on the baghouse. 2.1.4.4 If the baghouse pressure drop remains outside of manufacturer=s specifications, the baghouse shall be inspected for bag integrity and overall mechanical efficiency. Necessary repairs shall be made prior to bringing the equipment back on line. Any action taken as a result of baghouse pressure drop shall be recorded in a daily log, to be made available for Division inspection upon request. 2.1.5 The baghouse shall be inspected for bag integrity and overall mechanical efficiency annually. Powdered dye tests shall be performed as necessary to identify faulty bags. Necessary repairs shall be made prior to bringing the equipment back on line. An adequate inventory of replacement bags and parts shall be maintained on site. 2.2 The consumption of aluminum shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-2), as modified under the provisions of Section I, Condition 1.3). Consumption rates shall be measured and recorded each month. Monthly consumption rates shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of actual consumption shall be maintained for Division inspection upon request. 2.3 The consumption of natural gas shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-2) as modified under the provisions of Section I, Condition 1.3). Natural gas consumption rates shall be calculated by allocation as specified in Appendix G and recorded each month. Monthly fuel consumption shall be used in a twelve month rolling total to monitor compliance with the annual Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page I 1 limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of actual consumption shall be maintained for Division inspection upon request. 2.4 Except as provided for in Condition 2.5, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. I. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-2), and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 2.1.4. 2.5 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 2.1.4. 2.6 The delacquering kiln is subject to 40 CFR Part 63, Subpart RRR as set forth in Condition 10 of this permit. 2.7 This source is subject to the CAM requirements with respect to the facility wide HAP limits (Condition 9) as set forth in Condition 11 of this permit. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 960PWE125 Golden Aluminum, Inc. Page 12 3. S003, S004 and S005 - Melters #1, #2 and #3 - Main Hearths - ---- Unless Otherwise Specified the Limitations Apply to all Three Melters Combined Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 3.1 For each Melter: 19.20 lb/hr 37.6 tons/yr 0.611 lbs/ton Al Recordkeeping and Calculation Monthly PM,o NA 37.6 tons/yr 0.611 lbs/ton Al NOx 3.2. NA 70.6 tons/yr See Condition 3.2 Recordkeeping and Calculation Monthly CO 3.3. NA 23.85 tons/yr 84 lb/MMscf Recordkeeping and Calculation Monthly VOC 8.06 tons/yr 0.131 lbs/ton Al Aluminum Consumption 3.4. NA 123,100 tons/yr NA Recordkeeping Monthly Fuel Use 3.5 NA 568 MMscf/yr NA Fuel Meter Monthly Opacity— Applies to Each Metter 3.6 Except as provided for in Condition 3.7, below, not to exceed 20 % NA Visible Emission Observations Weekly 3.7 During certain operating conditions, not to exceed 30% MACT Requirements 3.8 From Sidewells, When Processing Coated Charge: 15 µg D/F TEQ per Mg of feed/charge See Conditions 3.8 and 10 3.1 Particulate Matter emissions are subject to the following limitations: 3.1.1 PM emissions from each melter shall not exceed the short term (Ibs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.1.a). In the absence of credible evidence to the contrary, compliance with the particulate matter standard for each melter is presumed based on maintaining a record of calculation demonstrating that with the combination of the emission factor and the quantity of aluminum charged to each melter precludes noncompliance. A copy of the calculation shall be made available for Division review upon request. Note that the numeric PM standards were determined using the design rate for the melters (14.95 tons Al/hr per melter) in the following equation: PE = 3.59 x (Ft 62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 13 3.1.2 PM and PMto emissions from all melters (main hearths) together shall not exceed the annual limitations stated above kfacility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Condition 1.3 to reflect requested emissions on the APEN submitted July 27, 2006). Monthly emissions from all melters (main hearths) together shall be calculated by the end of the subsequent month, using the above emission factors (based on performance test data) in the following equation: Tons/mo = Quantity Al processed (tons/mo) x EF (lbs/ton Al) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.2 Emissions of NOx for all melters combined shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Condition 1.3 to reflect requested emissions on the APEN submitted July 27, 2006). Monthly emissions from all melters together shall be calculated by the end of the subsequent month, using the appropriate emission factor from the table below in the following equation: Tons/month = Natural Gas Consumption (MMscf/month) x EF (lb/MMsct) 2000 lbs/ton The appropriate emission factor shall be determined based on the level of oxygen participation of all melters. All melters shall be operated at the same oxygen participation level for the entire month. The permittee shall maintain records of the monthly oxygen participation level for the melters and make such records available to the Division upon request. Oxygen Participation Level (%) NOx Emission Factor (lbs/MMscf) Emission Factor Source 0 100 AP -42, Section 1.4 (dated 3/98), Table 1.4-1 5 to 15 230 Manufacturer 16 to 25 250 26 to 50 350 51 to 95 400 100 50 Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.3 Emissions of CO and VOC for all melters together shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 14 permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Condition -1.3 to reflect requested emissions on the APEN submitted July 27, 2006). Monthly emissions from all melters together shall be calculated by the end of the subsequent month, using the above emission factors (VOC emission factor based on performance test data, CO emission factor from AP -42, Section 1.4 (dated 3/98), Table 1.4-1) in the following equation: For VOC, use equation in Condition 3.1.2. For CO Tons/month = Natural Gas Consumption (MMscf/month) x EF (Ib/MMscf) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.4 The consumption of aluminum for all melters (main hearths) together shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Condition 1.3 to reflect the requested production rate on the APEN submitted July 27, 2006). The aluminum consumption rates shall be measured and recorded each month. Monthly aluminum consumption rates shall be used in a rolling twelve month total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.5 The consumption of natural gas for all melters together shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Condition 1.3 to reflect the requested fuel consumption on the APEN submitted July 27, 2006). The natural gas consumption rate shall be determined using the fuel meters for the melters and recorded each month. Monthly natural gas consumption rates shall be used in a rolling twelve month total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 3.6 For each melter: Except as provided for in Condition 3.7, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 - second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342) and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting visual observation of emissions weekly. Such observations shall be made when the units are not operating during any of the specific activities specified in Condition 3.7. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 15 maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 3.7 For each melter: No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4). If any of these operating conditions persists for one hour or more, a visual observation of emissions shall be performed. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 3.8 The requirements in 40 CFR Part 63, Subpart RRR as set forth in Condition 10 of this permit apply when coated charge is processed in the melter sidewells. Coated charge may be processed in any of the melter sidewells provided that the following requirements are met: 3.8.1 Coated charge is processed in only one melter sidewell at a time. 3.8.2 The requirements in 40 CFR Part 63 Subpart RRR are met and the sidewell is operated in compliance with the operating parameters (e.g. charge weight, baghouse inlet temperature, lime injection rate, reactive chlorine flux injection rate) established during the performance test for that sidewell. 3.8.3 The permittee retain records of the dates and quantities of coated material charged in each melter sidewell. Coated charge may be processed in any two melter sidewells at the same time provided that a performance test is conducted within 90 days in accordance with the provisions in 40 CFR Part 63 Subpart RRR § 63.1511 (Conditions 10.24 through 10.28 of this permit) to determine compliance with the requirements in 40 CFR Part 63, Subpart RRR. Thereafter whenever coated Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 16 charge is processed in any two melter sidewells at the same time, the following requirements shall be met: 3.8.4 The requirements in 40 CFR Part 63 Subpart RRR are met and the sidewells are operated in compliance with the operating parameters (e.g. charge weight, baghouse inlet temperature, lime injection rate, reactive chlorine flux injection rate) established during the performance test conducted for two sidewells operating concurrently. 3.8.5 The permittee retain records of the dates coated material is processed in two sidewells concurrently, the quantities of coated material charged and in which two melter sidewells coated material is charged. 4. S006 - Melt Area Baghouse (Melters #1, #2 and #3 Sidewells) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 4.1 For each Metter: 19.20 lb/hr 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) Recordkeeping and Calculation and Baghouse Maintenance Monthly See Conditions 4.1.3 and 4.1.4 PM10 NA 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) Shredded and Plant Scrap Consumption 4.2 NA 68,166 tons/yr NA Recordkeeping Monthly Opacity 4.3 Except as provided for in Condition 4.4, below, not to exceed 20% NA Visible Emission Observations Daily 4.4 During certain operating conditions, not to exceed 30% CAM 4.5. See Conditions 4.5, 11 and Appendix H MACT Requirements 4.6 From Sidewells, When Processing Coated Charge: 15 µg D/F TEQ per Mg of feed/charge See Conditions 4.6 and 10. CAM 4.6 See Conditions 4.6, 11 and Appendix H 4.1 Particulate Matter emissions are subject to the following limitations: 4.1.1 PM emissions from each melter shall not exceed the short term (lbs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.1.a). In the absence or credible evidence to the contrary, compliance with the particulate matter standard is presumed provided that the requirements in Conditions 4.1.3 and 4.1.4 are met. Note that the numeric PM standards were determined using the design rate for the melters (14.95 tons Al/hr per melter) in the following equation: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 17 PE = 3.59 x (P)0 62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 4.1.2 Emissions of PM and PIVII0 from all melter sidewells combined shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 91 WE864) as modified under the provisions of Section I, Condition 1.3). Monthly emissions from all three melter sidewells together shall be calculated by the end of the subsequent month, using the emission factors in the above table (from 10/29/02 synthetic minor (HAP) permit application — factors based on calculation) in the following equation: Tons/mo = Quantity of shredded/scrap material charged (tons/mo) x EF (lbs/ton Al) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.1.3 Routine maintenance of the baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 4.1.3.1 and 4.1.3.2 and record in a log the opacity observations and any action taken as a result of the observations. The baghouse pressure drop shall be monitored and recorded daily. Should the daily recorded baghouse pressure drop be outside the manufacturer's recommendations, the source shall follow the steps in 4.1.3.1, 4.1.3.3, and 4.1.3.4, within one hour of the recorded pressure drop. 4.1.3.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 4.1.3.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 18 All observations shall be recorded and kept on site to be made available to the Division upon request. 4.1.3.3 Perform any maintenance or adjustments needed on the baghouse. 4.1.3.4 If the baghouse pressure drop remains outside of manufacturer's specifications, the baghouse shall be inspected for bag integrity and overall mechanical efficiency. Necessary repairs shall be made prior to bringing the equipment back on line. Any action taken as a result of baghouse pressure drop shall be recorded in a daily log, for Division inspection upon request. 4.1.4 The baghouses shall be inspected for bag integrity and overall mechanical efficiency annually. Powdered dye tests shall be performed as necessary to identify faulty bags. Necessary repairs shall be made prior to bringing the equipment back on line. An adequate inventory of replacement bags and parts shall be maintained on site. 4.2 The consumption of shredded and plant scrap in all three melter sidewells combined shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 91WE864), as modified under the provisions of Section I, Condition 1.3). Consumption rates from all three melter sidewells combined shall be measured and recorded each month, and maintained for Division inspection upon request. Monthly consumption rates shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.3 Except as provided for in Condition 4.4, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (Construction Permit 91WE864, and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 4.1.3. 4.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 4.1.3. 4.5 This source is subject to the CAM requirements respect to the particulate matter limits (Condition 4.1) and the facility wide HAP limits (Condition 9) as set forth in Condition 11. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 19 4.6 The requirements in 40 CFR Part 63, Subpart RRR as set forth in Condition 10 of this permit apply when coated charge is processed in the melter sidewells. Coated charge may be processed in any of the melter sidewells provided that the following requirements are met: 4.6.1 Coated charge is processed in only one melter sidewell at a time. 4.6.2 The requirements in 40 CFR Part 63 Subpart RRR are met and the sidewell is operated in compliance with the operating parameters (e.g. charge weight, baghouse inlet temperature, lime injection rate, reactive chlorine flux injection rate) established during the performance test for that sidewell. 4.6.3 The permittee shall retain records of the dates and quantities of coated material charged in each melter sidewell. Coated charge may be processed in any two melter sidewells at the same time provided that a performance test is conducted within 90 days in accordance with the provisions in 40 CFR Part 63 Subpart RRR § 63.1511 (Conditions 10.24 through 10.28 of this permit) to determine compliance with the requirements in 40 CFR Part 63, Subpart RRR. Thereafter whenever coated charge is processed in any two melter sidewells at the same time, the following requirements shall be met: 4.6.4 The requirements in 40 CFR Part 63 Subpart RRR are met and the sidewells are operated in compliance with the operating parameters (e.g. charge weight, baghouse inlet temperature, lime injection rate, reactive chlorine flux injection rate) established during the performance test conducted for two sidewells operating concurrently. 4.6.5 The permittee retain records of the dates coated material is processed in two sidewells concurrently, the quantities of coated material charged and which two melter sidewells coated material is charged. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 960PWE125 Golden Aluminum, Inc. Page 20 5. SODS - Hot Mill >v/ Air Purifier Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 5,1 18.03 lb/hr 3.9 tons/yr 0.0929 lb/ton Al pressed Recordkeeping and Calculation and Purifier Maintenance Monthly See Condition 5.1.3 EMI() NA 3.9 tons/yr 0.0929 Ib/ton Al pressed Aluminum Pressed 5.2 NA 84,722 tons/yr NA Recordkeeping Monthly Opacity 5.3 Except as provided for in Condition 5.4, below, not to exceed 20% NA Visible Emission Observations Daily 5.4 During certain operating conditions, not to exceed 30% 5.1 Particulate Matter emissions are subject to the following limitations: 5.1.1 PM emissions shall not exceed the short term (lbs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.1.a). In the absence of credible evidence to the contrary, compliance with the short term PM limit is presumed provided that the requirements in Condition 5.1.3 are met. Note that the numeric PM standards were determined using the design rate for the hot mill (13.5 tons Al/hr per melter) in the following equation: PE = 3.59 x (P)°'62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 5.1.2 PM and PIVII0 emissions shall not exceed the annual limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-6), as modified under the provisions of Section I, Condition 1.3). Monthly emissions from the hot mill shall be calculated by the end of the subsequent month, using the emission factors in the above table (from 4/5/99 revised Title V permit application — based on stack test plus 20%) in the following equation: Tons/mo = Quantity of aluminum pressed (tons/mo) x EF (lbs/ton Al) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall he calculated using the previous twelve months data.. Operating Permit Number: 96OPWEI25 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 21 5.1.3 Routine maintenance of the air purifier shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 5.1.3.1 and 5.1.3.2 and record in a log the opacity observations and any action taken as a result of the observations. 5.1.3.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 5.1.3.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 5.2 The amount of aluminum pressed shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-6). as modified under the provisions of Section I, Condition 1.3). Throughput rates shall be measured and recorded each month and maintained for Division inspection upon request. Monthly throughput rates shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 5.3 Except as provided for in Condition 5.4, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-6), and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 5.1.3. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 22 5.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 5.1.3. 6. S009 - Two Annealing Furnaces Parameter Permit Condition Number Limitations (for both together) Short Term Long Term Compliance Emission Factor (lb/ton Al) Limitations Short Term Long Term PM 6.1 For each Furnace: 34.5 lbs/hr 1.38 tons/yr HM: 0.0455 Inter: 0.0205 Stab: 0.0224 Recordkeeping and Calculation Monthly PM10 NA 1.38 tons/yr HM: 0.0455 Inter: 0.0205 Stab: 0.0224 NO, NA 4.22 tons/yr HM: 0.0978 Inter: 0.0976 Stab: 0.0986 CO NA 3.54 tons/yr HM: 0.0823 Inter: 0.0830 Stab: 0.0825 VOC NA 4.21 tons/yr HM: 0.0055 Inter: 0.1537 Stab: 0.1786 Aluminum Coil Throughput 6.2 NA 86,037 tons/yr NA Recordkeeping Monthly Fuel Use 6.3 NA 84.4 MMscf/yr NA Fuel Allocation (See Appendix G) Monthly Opacity 6.4 Except as provided for in Condition 6.5, below, not to exceed 20% NA Visual Observations Weekly 6.5 During certain operating conditions, not to exceed 30% 6.1 Emissions of air pollutants from both annealing furnaces together are subject to the following requirements: 6.1.1 PM emissions from each annealing furnace shall not exceed the short term (lbs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.I.b). In the absence of credible evidence to the contrary, compliance with the particulate matter standard for each annealing furnace is presumed based on maintaining a record of Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 23 calculation demonstrating that with the combination of the emission factor and the quantity of aluminum charged to each furnace precludes noncompliance. A _copy of the calculation shall be made available for Division review upon request. Note that the numeric PM standards were determined using the design rate for the furnaces (75 tons Al/hr per furnace) in the following equation: PE = 17.31 x (P)0'16 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 6.1.2 Emissions of air pollutants from both annealing furnaces together shall not exceed the annual limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-8), as modified under the provisions of Section I, Condition 1.3). Monthly emissions shall be calculated by the end of the subsequent month using the emission factors in the above table (from 4/5/99 revised Title V permit application — based on calculation) the following equations: For Hot Mill Annealing Tons/month = Throughput (tons Al HM/month) x EF (lbs/ton Al) / 2000 For Intermediate Annealing Tons/month = Throughput (tons Al Inter/month) x EF (lbs/ton Al) / 2000 For Stabilize Annealing Tons/month = Throughput (tons Al Stab/month) x EF (lbs/ton Al) / 2000 For Fuel Use Tons/month = Natural Gas Consumption (mmscf/month) x EF (lbs/mmscf) / 2000 Total emissions = Hot Mill + Intermediate + Stabilize + Fuel Use Monthly emissions shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be maintained for Division inspection upon request. 6.2 The throughput of aluminum coil for both annealing furnace together shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-8), as modified under the provisions of Section I, Condition 1.3). Rates for each process (hot mill, intermediate and stabilize) shall be measured and recorded each month and maintained for Division inspection upon request. Rates for each process shall then be summed and the total monthly throughput rate shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 24 6.3 The consumption of natural gas from both annealing furnaces together shall not exceed the limitation above (facility wide Colorado ConstructionPermit03_WF0032 (previously individual construction permit 82WE250-8), as modified under the provisions of Section I, Condition 1.3). Consumption rates shall be calculated by allocation as specified in Appendix G and recorded each month and maintained for Division inspection upon request. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 6.4 For each furnace: Except as provided for in Condition 6.5, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 - second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. I. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-8), and Colorado Regulation No. I, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting visual observation of emissions weekly. Such observations shall be made when the units are not operating during any of the specific activities specified in Condition 6.5. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 6.5 For each furnace: No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. If any of theses operating conditions persists for one hour or more, a visual observation of emissions shall be performed. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 25 valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. (Colorado Regulation No. 1, Section II.A.4)_ 7. SON - Cold Mill w/ Air Purifier Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 7.1 30.6 lb/hr 9.15 tons/yr Brkdown:0.0592 Inter: 0.1431 Finish: 0.2476 Recordkeeping and Calculation and Purifier Maintenance Monthlyy See Condition 7.1.3 PM1 NA 9.15 tons/yr Brkdown:0.0592 Inter: 0.1431 Finish: 0.2476 VOC NA 67.38 tons/yr Brkdown:0.4902 Inter: 1.212 Finish: 1.680 Aluminum Sheet Processed 7.2 NA 124,000 tons/yr NA Recordkeeping Monthly Opacity 7.3 Except as provided for in Condition 7.4, below, not to exceed 20% NA Visible Emission Observations Daily 7.4 During certain operating conditions, not to exceed 30% 7.1 Emissions of air pollutants are subject to the following requirements: 7.1.1 PM emissions shall not exceed the short term (lbs/hr) limitations stated above (Colorado Regulation No. 1, Section III.C.I.b). In the absence of credible evidence to the contrary, compliance with the short term PM limit is presumed provided that the requirements in Condition 7.1.3 are met. Note that the numeric PM standards were determined using the design rate for the cold mill (35 tons Al/hr) in the following equation: PE = 17.31 x (P)°16 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 7.1.2 Emissions of air pollutants shall not exceed the annual limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-7), as modified under the provisions of Section I, Condition 1.3). Monthly emissions from the hot mill shall be calculated by the end of the subsequent month, using the emission factors in the above table (per 4/5/99 revised Title V permit application - from stack tests) in the following equations: Breakdown Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 26 Tons/month = Throughput (tons Al breakdown/month) x EF (lbs/ton Al) / 2000 Intermediate Throughput (tons Al intermediate/month) x EF (lbs/ton Al) / 2000 Finish Throughput (tons Al finish/month) x EF (lbs/ton Al) / 2000 Total emissions = Breakdown + Intermediate + Finish Monthly emissions shall be used in a rolling twelve month total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be maintained for Division inspection upon request. 7.1.3 Routine maintenance of the air purifier shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 7.1.3.1 and 7.1.3.2 and record in a log the opacity observations and any action taken as a result of the observations. 7.1.3.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 7.1.3.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 7.2 The amount of aluminum sheet processed shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250- 7), as modified under the provisions of Section I, Condition 1.3). Production rates shall be measured and recorded each month and maintained for Division inspection upon request. Monthly material production rates shall be used in a twelve month rolling total to monitor Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Golden Aluminum, Inc. Colorado Operating Permit Permit # 96OPWE125 Page 27 compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 7.3 Except as provided for in Condition 7.4, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-7), and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 7.1.3. 7.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) Compliance with the opacity requirements shall be monitored by conducting daily visible emission observations in accordance with the requirements in Condition 7.1.3. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 28 8. SOH - Coil Coating Line w/Thermal Oxidizer Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 8.1 NA 0.86 tons/yr 7.6 lb/MMscf Recordkeeping and Calculations Monthly PM10 NA 0.86 tons/yr 7.6 lb/MMscf NOx NA 11.28 tons/yr 100 lb/MMscf CO NA 9.47 tons/yr 84 lb/MMscf VOC NA 14.00 tons/yr Fuel Burning: 5.5 lb/MMscf Coatings/Solvents: Mass Balance Coating of Aluminum Sheet 8.2 NA 1,235,140.5 ft2/yr NA Recordkeeping Monthly Natural Gas Consumption 8.3 NA 225 MMscf/yr NA Fuel Allocation (See Appendix G) Monthly Clean-up Solvent Consumption 8.4 NA 1495 gallons/yr NA Recordkeeping Monthly NSPS Requirements 8.5 VOC emissions not to exceed: 0.14 kg/I of coating solids OR 90% Reduction NA As required in Regulation No. 6, Part A, Subpart TT Thermal Oxidizer effluent temperature not less than 1267 ° F for more than 3 consecutive hours Reporting and Recordkeeping General Requirements 8.6 NA NA As required in Regulation No. 6, Part A, Subpart A Opacity 8.7 Except as provided for in Condition 8.8, below, not to exceed 20% NA Fuel Restriction Only Natural Gas is Permitted to be Used as Fuel 8.8 During certain operating conditions, not to exceed 30% Thermal Oxidizer Control Efficiency 8.9 99.0% NA See Condition 8.9 8.1 Emissions of air pollutants shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-12)). Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (AP -42, Section 1.4 (dated 3/98), Tables 1.4-1 and 1.4-2 ) in the following equations: For PM, PM1o, NOx ,CO and VOC emissions from natural gas consumption: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 29 Tons/month = Nat. Gas Consumption (MMscf/month) x EF (lbs/MMscf) / 2000 For VOC emissions from coating/solvents used in the coating line (controlled by thermal oxidizer): Tons l month = {Z[V,D;W ] } / 2000*(1- (1- Eff) 1=7 Where: n = each coating/solvent V = volume of coating/solvent used per month (gal/month) D = density of coating/solvent (lbs/gal) W = VOC content of coating (lbs VOC/lbs coating), use 1.0 for solvents Eff = Reduction efficiency of control device For VOC emissions from solvents used for clean-up (not controlled by thermal oxidizer Tons l month = {I [ViDi] } 12000 i=t Total VOC Emissions = fuel combustion + coating line + clean-up — materials sent off -site or recycled Monthly emissions shall be used in a twelve-month rolling total to monitor compliance with the annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of emission calculations shall be maintained for Division inspection upon request. 8.2 The coating of aluminum shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-12), as modified under the provisions of Section I, Condition 1.3). Throughput rates shall be measured and recorded each month and maintained for Division inspection upon request. Monthly throughput rates shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 8.3 The consumption of natural gas shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-12)). Natural gas consumption rates shall be calculated by allocation as specified in Appendix G and recorded each month and maintained for Division inspection upon request. Monthly natural gas consumption shall be used in a twelve month rolling total to monitor compliance with the annual limitation. Each month a new twelve month total shall be calculated using the previous twelve months data. 8.4 The consumption of clean-up solvent shall not exceed the limitation above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82 WE250- 12)). Consumption rates shall be measured and recorded each month and maintained for Division inspection upon request. Monthly consumption rates shall be used in a twelve month Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 30 rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 8.5 This unit is subject to 40 CFR 60, Subpart TT (as adopted by reference in Colorado Regulation No. 6, Part A, Subpart TT): Standards of Performance for Metal Coil Surface Coating Requirements as follows: Standards for Volatile Organic Compounds (§ 60.462) 8.5.1 Each owner or operating subject to this subpart shall not cause to be discharged into the atmosphere more than: 8.5.1.1 0.14 kg VOC/ / of coating solids applied for each calendar month for each affected facility that continuously uses an emission control device(s) operated at the most recently demonstrated overall efficiency (§ 60.462(a)(2)); or 8.5.1.2 10 percent of the VOC's applied for each calendar month (90 percent emission reduction) for each affected facility that continuously uses an emission control device(s) operated at the most recently demonstrated overall efficiency ((§ 60.462(a)(2)). Performance Test and Compliance Provisions (§ 60.463) 8.5.2 Section 60.8(d) and (0 do not apply to the performance test. (§ 60.463(a)) 8.5.3 The owner or operator of an affected facility shall conduct an initial performance test as required under §60.8(a) and thereafter a performance test for each calendar month for each affected facility according to the procedures in this section. (§ 60.463(b)) 8.5.4 An owner or operator shall use the procedures in § 60.463(c)(2) for each affected facility that continuously uses a capture system and a control device that destroys VOCs (e.g., incinerator) to comply with the emission limits specified under § 60.462(a)(2) or (3) (Condition 8.5.1). (§ 60.463(c)(2)) For the initial performance test, the overall reduction efficiency (R) shall be determined as prescribed in paragraphs (c)(2)(i) (A), (B), and (C) of this section. In subsequent months, the owner or operator may use the most recently determined overall reduction efficiency (R) for the performance test, providing control device and capture system operating conditions have not changed. The procedure in paragraphs (c)(2)(i) (A), (B), and (C) of this section, shall be repeated when directed by the Division or when the owner or operator elects to operate the control device or capture system at conditions different from the initial performance test. (§ 60.463(c)(2)(i)). If the overall reduction efficiency (R) is equal to or greater than 0.90, the affected facility is in compliance and no further computations are necessary. If the overall reduction efficiency (R) is less than 0.90, the average total VOC emissions to the Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 31 atmosphere per unit volume of coating solids applied (N) shall be computed as specified in § 60.463(c)(2)(ii)). ((§ 60.463(c)(2)(i)(C)). Note that the initial performance test conducted in July 1996 indicated that the destruction efficiency of the thermal oxidizer was over 99.9%, Monitoring of Emissions and Operations (( 60.464) 8.5.5 If thermal incineration is used, each owner or operator subject to the provisions of this subpart shall install, calibrate, operate, and maintain a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance with §60.462(a)(2), (3), or (4). This device shall have an accuracy of ±2.5 °C. or ±0.75 percent of the temperature being measured expressed in degrees Celsius, whichever is greater. Each owner or operator shall also record all periods (during actual coating operations) in excess of 3 hours during which the average temperature in any thermal incinerator used to control emissions from an affected facility remains more than 28 °C (50 °F) below the temperature at which compliance with §60.462(a)(2), (3), or (4) was demonstrated during the most recent measurement of incinerator efficiency required by §60.8. The records required by §60.7 shall identify each such occurrence and its duration. ((§ 60.464(c)) Note that the temperature measured during the July 1996 performance test indicated a temperature of 1,317 ° F, as a result temperature must remain above 1,267 ° F. 8.5.6 The permittee is subject to the Reporting and Recordkeeping requirements found in § 60.465, except that retention of the records specified in § 60.465(e) shall be retained for the time period specified in Section IV, Condition 22.b and c. 8.5.7 The permittee is subject to the Test Method and Procedures requirements found in § 60.466. 8.6 This unit is subject to the requirements of 40 CFR 60, Subpart A, General Provisions (as adopted by reference in Colorado Regulation No. 6, Part A, Subpart A) including but not limited to the following: 8.6.1 Notification and Recordkeeping as required in § 60.7. 8.6.2 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with good air pollution practice for minimizing emissions. (§ 60.11(d)) 8.6.3 No article, machine, equipment or process shall be used to conceal an emissions which would otherwise constitute a violation of an applicable standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 32 compliance with an opacity standard or with a standard which is based on the concentration of a pollutant in the gasses -discharged -to -the atmosphere. (§ 60.12) 8.7 Except as provided for in Condition 8.8, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-12), and Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with the 20% opacity limit shall be presumed since only natural gas is permitted to be used as fuel for the thermal oxidizer. 8.8 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) In the absence of credible evidence to the contrary, compliance with the 30% opacity limit shall be presumed since only natural gas is permitted to be used as fuel for the thermal oxidizer. 8.9 The VOC and HAP destruction efficiency of the thermal oxidizer shall be 99.0% or greater. A 99.0% control efficiency can be used in the emission calculations in Conditions 8.1 and 9 of this permit, provided that the thermal oxidizer is operated and maintained in accordance with the requirements in Condition 8.5. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 33 9. Facility Wide HAP Emission Limits Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval Each Individual HAP 9.1 NA 8 tons/year See below Recordkeeping and Calculation Monthly Total Facility Wide HAPs NA 20 tons/year See below 9.1 Emissions of HAPs shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032, as modified under the provisions of Section I, Condition 1.3 to set specific HAP limits of 8 tons/yr for any single HAP and 20 tons/yr of combined HAPS). HAP Emissions shall be calculated by the end of the subsequent month using actual throughputs and the following compliance emission factors. Emission Source Emission Factors Source of Emission Factor S00I 0.0014 lb HAP metals/ton production From 10/29/02 synthetic minor (HAP) permit application. S002 0.002 lb HAP metals/ton production 0.02 lb HCl/ton production (assumes 97% reduction for lime injection baghouse) From 10/31/03 renewal application — based on stack tests S006 0.0009 lb HAP metals/ton production 0.0865 lb HCl/ton production 0.0083 lb HF/ton production From 10/29/02 synthetic minor (HAP) permit application. S011 HAP emissions shall be calculated as for VOC calculations as set forth in Condition 8.1. Material Balance, 99 % control efficiency can be applied for the thermal oxidizer. Fuel Use 1.80 lbs hexane/mmscf 0.075 lb formaldehyde/mmscf 0.0021 lb benzene/mmscf 0.0034 lb toluene/mmscf AP -42, Section 1.4 (dated 3.98), Table 1.4-3 A twelve-month rolling total shall be used to monitor compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of calculations shall be maintained for Division inspection upon request. Control equipment shall be operated and maintained in accordance with the provisions set forth in the conditions for individual units, above. 10. National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production This facility is subject to the provisions of 40 CFR Part 63, Subpart RRR, as follows. The requirements of this subpart pertaining to dioxin and furan (D/F) emissions and associated operating, monitoring, reporting and recordkeeping requirements apply to the affected sources listed in 63.1500(c), located at a secondary aluminum facility that is an area source of HAPs. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 34 1-611505 Emission standards for affected sources and emission units 10.1 Scrap dryer/delacquering kiln/decoating kiln: alternative limits. The owner or operator of a scrap dryer/delacquering kiln/decoating kiln may choose to comply with the emission limits in paragraph 63.1505(e) as an alternative to the limits in 63.1505(d) if the scrap dryer/delacquering kiln/decoating kiln is equipped with an afterburner having a design residence time of at least 1 second and the afterburner is operated at a temperature of at least 750°C (1400°F) at all times. On and after the compliance date, the owner or operator of a scrap dryer/delacquering kiln/decoating kiln must not discharge or cause to be discharged to the atmosphere emissions in excess of: 10.1.1 5.0 µg of D/F TEQ per Mg (7.0 x 10 5 gr of D/F TEQ per ton) of feed/charge from a scrap dryer/delacquering kiln/decoating kiln at a secondary aluminum production facility that is a major or area source. (63.1505(e)(1)(iii)) 10.2 Group 1 furnace. The owner or operator of a group 1 furnace must use the limits in 63.1505(i) to determine the emission standards for a secondary aluminum processing unit (SAPU). 10.2.1 15 µg D/F TEQ per Mg (2.1 x 104 gr of D/F TEQ per ton) of feed/charge from a group 1 furnace at a secondary aluminum production facility that is a major or area source. This limit does not apply if the furnace processes only clean charge. (63.1505(i)(3)) 10.2.2 The owner or operator may determine the emission standards for a SAPU by applying the group 1 furnace limits on the basis of aluminum production weight in each group 1 furnace, rather than on the basis of feed/charge. (63.1505(i)(6)) 10.2.3 The owner or operator of a sidewell group 1 furnace that conducts reactive fluxing (except for cover flux) in the hearth, or that conducts reactive fluxing in the sidewell at times when the level of molten metal falls below the top of the passage between the sidewell and the hearth, must comply with the emission limit of paragraphs (i)(3) (Condition 10.2.1) of this section on the basis of the combined emissions from the sidewell and the hearth. 10.3 Secondary aluminum processing unit. On and after the compliance date, the owner or operator must comply with the emission limit calculated using the equation for D/F in 63.1505(k)(3) for each secondary aluminum production facility that is a major or area source. (63.1505(k)) The owner or operator of a SAPU at a secondary aluminum production facility that is an area source may demonstrate compliance with the emission limits of 63.1505(k)(3) by demonstrating that each emission unit within the SAPU is in compliance with the emission limit of 63.1505(1)(3) (Condition 10.2.1). (63.1505(k)(5)) § 63.1506 Operating Requirements Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 35 Summary. On and after the compliance date, the owner or operator must operate all new and existing affected sources and control equipment according to the requirements of 63.1506. (63.1506(a)(1)) 10.4 Labeling. The owner or operator must provide and maintain easily visible labels posted at each group 1 furnace, group 2 furnace, in -line fluxer and scrap dryer/delacquering kiln/decoating kiln that identifies the applicable emission limits and means of compliance, including: 10.4.1 The type of affected source of emission unit. (63.1506(b)(1)) 10.4.2 The applicable operational standard(s) and control method(s) (work practice of control device). This includes, but is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials and addition practices, and the applicable operating parameter ranges and requirements as incorporated into the OM&M plan. (63.1506(b)(2)) 10.4.3 The afterburner operating temperature and design residence time for a scrap dryer/delacquering kiln/decoating kiln. (63.1506(b)(3)) 10.5 Capture/collection systems. For each affected source or emission unit equipped with an add-on air pollution control device, the owner or operator must: 10.5.1 Design and install a.system for the capture and collection of emissions to meet the engineering standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists in chapters 3 and 5 of "Industrial Ventilation: A Manual if Recommended Practice." (63.1506(c)(1)) 10.5.2 Vent captured emissions through a closed system, except that dilution air may be added to emission streams for the purpose of controlling temperature at the inlet to a fabric filter. (63.1506(c)(2)) 10.5.3 Operate each capture/collection system according to the procedures and requirements in the OM&M plan. (63.1506(c)(3)) 10.6 Feed/charge weight. The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of feed charge must: 10.6.1 Except as provided in 63.1506(d)(3) (Condition 10.6.3, below) install and operate a device that measures and records or otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the performance test. (63.1506(d)(1)) 10.6.2 Operate each weight measurement system or other weight determination procedure in accordance with the OM&M plan. (63.1506(d)(2)) 10.6.3 The owner or operator may choose to measure and record aluminum production weight from an affected source or emission unit rather than feed/charge weight to an Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 36 affected source or emission unit provided that: (i) the aluminum production weight, rather than feed/charge weight is-measured_anrlrecorded for all emission units within a SAPU; and (ii) all calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum production weight rather than feed/charge weight. (63.1506(d)(3)) 10.7 Scrap dryer/delacquering kiln/decoating kiln. The owner or operator of a scrap dryer/delacquering kiln/decoating kiln with emissions controlled by an afterburner and a lime - injected fabric filter must: 10.7.1 For each afterburner (63.1506(g)(1)). 10.7.1.1 Maintain the 3 -hour block average operating temperature of each afterburner at or above the average temperature established during the performance test. (63.1506(g)(1)0)) 10.7.1.2 Operate each afterburner in accordance with the OM&M plan. (63.1506(g)(1)(ii)) 10.7.2 If a bag leak detection system is used to meet the fabric filter monitoring requirements in §63.1510 (63.1506(g)(2)). 10.7.2.1 Initiate corrective action within 1 -hour of a bag leak detection system alarm and complete any necessary corrective action procedures in accordance with the OM&M plan. (63.1506(g)(2)(i)) 10.7.2.2 Operate each fabric filter system such that the bag leak detection system alarm does not sound more than 5 percent of the operating time during a 6 - month block reporting period. In calculating this operating time fraction, if inspection of the fabric filter demonstrates that no corrective action is required, no alarm time is counted. If corrective action is required, each alarm shall be counted as a minimum of 1 hour. If the owner or operator takes longer than 1 hour to initiate corrective action, the alarm time shall be counted as the actual amount of time taken by the owner or operator to initiate corrective action. (63.1506(g)(2)(ii)) 10.7.3 Maintain the 3 -hour block average inlet temperature for each fabric filter at or below the average temperature established during the performance test, plus 14 °C (plus 25 °F). (63.1506(g)(3)) 10.7.4 For a continuous injection device, maintain free -flowing lime in the hopper to the feed device at all times and maintain the lime feeder setting at the same level established during the performance test. (63.1506(g)(5)) 10.8 Group 1 furnace with add-on air pollution control devices. The owner or operator of a group 1 furnace with emissions controlled by a lime -injected fabric filter must: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 37 10.8.1 If a bag leak detection system is used to meet the monitoring requirements in §63.1510, the owner or operator must: (63.1506(m)(1)) 10.8.1.1 Initiate corrective action within 1 hour of a bag leak detection system alarm. (63.1506(m)(1)(i)) 10.8.1.2 Complete the corrective action procedures in accordance with the OM&M plan. (63.1506(m)(1)(ii)) 10.8.1.3 Operate each fabric filter system such that the bag leak detection system alarm does not sound more than 5 percent of the operating time during a 6 - month block reporting period. In calculating this operating time fraction, if inspection of the fabric filter demonstrates that no corrective action is required, no alarm time is counted. If corrective action is required, each alarm shall be counted as a minimum of 1 hour. If the owner or operator takes longer than 1 hour to initiate corrective action, the alarm time shall be counted as the actual amount of time taken by the owner or operator to initiate corrective action. (63.1506(m)(1)(iii)) 10.8.2 Maintain the 3 -hour block average inlet temperature for each fabric filter at or below the average temperature established during the performance test, plus 14 °C (plus 25 °F). (63.1506(m)(3)) 10.8.3 For a continuous lime injection system, maintain free -flowing lime in the hopper to the feed device at all times and maintain the lime feeder setting at the same level established during the performance test. (63.1506(m)(4)) 10.8.4 Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the performance test at or below the average rate established during the performance test. (63.1506(m)(5)) 10.8.5 Operate each sidewell furnace such that: (63.1506(m)(6)) 10.8.5.1 The level of molten metal remains above the top of the passage between the sidewell and hearth during reactive flux injection, unless emissions from both the sidewell and the hearth are included in demonstrating compliance with all applicable emission limits. (63.1506(m)(6)(i)) 10.8.5.2 Reactive flux is added only in the sidewell, unless emissions from both the sidewell and the hearth are included in demonstrating compliance with all applicable emission limits. (63.1506(m)(6)(ii)) 10.9 Corrective action. When a process parameter or add-on air pollution control device operating parameter deviates from the value or range established during the performance test and incorporated in the OM&M plan, the owner or operator must initiate corrective action. Corrective action must restore operation of the affected source or emission unit (including the process or control device) to its normal or usual mode of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 38 Corrective actions taken must include follow-up actions necessary to return the process or — control device parameter level(s) - to the value or range of values established during the performance test and steps to prevent the likely recurrence of the cause of a deviation. (63.1506(p)) § 63.1510 Monitoring Requirements Summary. On and after the compliance date, the owner or operator of a new or existing affected source or emission unit must monitor all control equipment and processes according to the requirements in 63.1510. (63.1510(a)) 10.10 Operation, maintenance, and monitoring (OM&M) plan. The owner or operator must prepare and implement for each new or existing affected source and emission unit, a written OM&M plan. The owner or operator of an existing affected source must submit the plan to the Division no later than the compliance date. Each plan must contain the information as set forth in 63.1510(b). 10.11 Labeling. The owner or operator must inspect the labels for each group 1 furnace, group 2 furnace, in -line fluxer and scrap dryer/delacquering kiln/decoating kiln at least once per calendar month to confirm that posted labels as required by the operational standard in 63.2506(b) are intact and legible. (63.1510(c)) 10.12 Capture/collection system. The owner or operator must: 10.12.1 Install, operate, and maintain a capture/collection system for each affected source and emission unit equipped with an add-on air pollution control device. (63.1510(d)(1)) 10.12.2 Inspect each capture/collection and closed vent system at least once each calendar year to ensure that each system is operating in accordance with the operating requirements in 63.1506(c) and record results of each inspection. (63.1510(d)(2)) 10.13 Feed/charge weight. The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or µg/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the total weight of feed charge to, or the aluminum production from, the affected source or emission unit over the same operating cycle or time period used in the performance test, as set forth in 63.1510(e). Feed/charge or aluminum production within SAPUs must be measured and recorded on an emission unit -by -emission unit basis. As an alternative to a measurement device, the owner or operator may use a procedure acceptable to the Division to determine the total weight of feed/charge or aluminum production to the affected source or emission unit. (63.1510(e)) 10.14 Fabric filters and lime -injected fabric filters. The owner or operator of an affected source or emission unit using a fabric filter or lime -injected fabric filter to comply with the requirements of this subpart must install, calibrate, maintain, and continuously operate a bag leak detection system as required in paragraph (1)(1) of this section. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 39 10.14.1 These requirements apply to the owner or operator of a new or existing affected source or existing emission unit using a bag leak detection system. (63.1506(f)(I)) 10.14.1.1 The owner or operator must install and operate a bag leak detection system for each exhaust stack of a fabric filter. (63.1506(f)(1)(i)) 10.14.1.2 Each triboelectric bag leak detection system must be installed, calibrated, operated, and maintained according to the "Fabric Filter Bag Leak Detection Guidance," (September 1997). This document is available from the U.S. Environmental Protection Agency; Office of Air Quality Planning and Standards; Emissions, Monitoring and Analysis Division; Emission Measurement Center (MD -19), Research Triangle Park, NC 27711. This document also is available on the Technology Transfer Network (TTN) under Emission Measurement Technical Information (EMTIC), Continuous Emission Monitoring. Other bag leak detection systems must be installed, operated, calibrated, and maintained in a manner consistent with the manufacturer's written specifications and recommendations. (63.1506(f)(1)(ii)) 10.14.1.3 The bag leak detection system must be certified by the manufacturer to be capable of detecting PM emissions at concentrations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. (63.1506(f)(1)(iii)) 10.14.1.4 The bag leak detection system sensor must provide output of relative or absolute PM loadings. (63.1506(f)(1)(iv)) 10.14.1.5 The bag leak detection system must be equipped with a device to continuously record the output signal from the sensor. (63.1506(f)(1)(v)) 10.14.1.6 The bag leak detection system must be equipped with an alarm system that will sound automatically when an increase in relative PM emissions over a preset level is detected. The alarm must be located where it is easily heard by plant operating personnel. (63.1506(f)(1)(vi)) 10.14.1.7 For positive pressure fabric filter systems, a bag leak detection system must be installed in each baghouse compartment or cell. For negative pressure or induced air fabric filters, the bag leak detector must be installed downstream of the fabric filter. (63.1506(f)(1)(vii)) 10.14.1.8 Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors. (63.1506(f)(1)(viii)) 10.14.1.9 The baseline output must be established by adjusting the range and the averaging period of the device and establishing the alarm set points and the alarm delay time. (63.1506(t)(1)(ix)) 10.14.1.10 Following initial adjustment of the system, the owner or operator must not adjust the sensitivity or range, averaging period, alarm set points, or alarm delay time except as detailed in the OM&M plan. In no case may the Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 40 sensitivity be increased by more than 100 percent or decreased more than 50 percent over a -365=day--period--unless such adjustment follows a complete fabric filter inspection which demonstrates that the fabric filter is in good operating condition. (63.1506(f)(1)(x)) 10.15 Afterburner. These requirements apply to the owner or operator of an affected source using an afterburner to comply with the requirements of Subpart RRR. 10.15.1 The owner or operator must install, calibrate, maintain, and operate a device to continuously monitor and record the operating temperature of the afterburner consistent with the requirements for continuous monitoring systems in 40 CFR Part 63, Subpart A. (63.1510(g)(1)) 10.15.2 The temperature monitoring device must meet each of the performance and equipment specifications set forth in 63.1510(g)(2). 10.15.3 The owner or operator must conduct an inspection of each afterburner at least once a year and record the results. At a minimum, an inspection must include the items set forth in 63.1510(g)(3). 10.16 Fabric filter inlet temperature. These requirements apply to the owner or operator of a scrap dryer/delacquering kiln/decoating kiln or a group 1 furnace using a lime -injected fabric filter to comply with the requirements of this subpart. 10.16.1 The owner or operator must install, calibrate, maintain, and operate a device to continuously monitor and record the temperature of the fabric filter inlet gases consistent with the requirements for continuous monitoring systems in subpart A of this part. (63.1510(h)(1)) 10.16.2 The temperature monitoring device must meet each of these performance and equipment specifications: 10.16.2.1 The monitoring system must record the temperature in 15 -minute block averages and calculate and record the average temperature for each 3 -hour block period. (63.1510(h)(2)(i)) 10.16.2.2 The recorder response range must include zero and 1.5 times the average temperature established according to the requirements in § 63.1512(n). (63.1510(h)(2)(ii)) 10.16.2.3 The reference method must be a National Institute of Standards and Technology calibrated reference thermocouple -potentiometer system or alternate reference, subject to approval by the Administrator. (63.1510(h)(2)(iii)) 10.17 Lime injection. These requirements apply to the owner or operator of an affected source or emission unit using a lime -injected fabric filter to comply with the requirements of this subpart. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 41 10.17.1 The owner or operator of a continuous lime injection system must verify that lime is always free -flowing by inspecting each feed hopper or silo at least once each 8 -hour period and recording the results of each inspection. If lime is found not to be free - flowing during any of the 8 -hour periods, the owner or operator must increase the frequency of inspections to at least once every 4 -hour period for the next 3 days. The owner or operator may return to inspections at least once every 8 hour period if corrective action results in no further blockages of lime during the 3 -day period. (63.1506(i)(1)(i)) 10.17.2 The owner or operator of a continuous lime injection system must record the lime feeder setting once each day of operation. (63.1506(i)(2)) 10.17.3 An owner or operator who intermittently adds lime to a lime coated fabric filter must obtain approval from the permitting authority for a lime addition monitoring procedure. The permitting authority will not approve a monitoring procedure unless data and information are submitted establishing that the procedure is adequate to ensure that relevant emission standards will be met on a continuous basis. (63.1506(i)(3)) 10.18 Total reactive flux injection rate. These requirements apply to the owner or operator of a group 1 furnace (with or without add-on air pollution control devices) or in -line fluxer. The owner or operator must: 10.18.1 Install, calibrate, operate, and maintain a device to continuously measure and record the weight of gaseous or liquid reactive flux injected to each affected source or emission unit. (63.1510(j)(1)) 10.18.1.1 The monitoring system must record the weight for each 15 -minute block period, during which reactive fluxing occurs, over the same operating cycle or time period used in the performance test. (63.1510(j)(1)(i)) 10.18.1.2 The accuracy of the weight measurement device must be +1 percent of the weight of the reactive component of the flux being measured. The owner or operator may apply to the permitting authority for permission to use a weight measurement device of alternative accuracy in cases where the reactive flux flow rates are so low as to make the use of a weight measurement device of +1 percent impracticable. A device of alternative accuracy will not be approved unless the owner or operator provides assurance through data and information that the affected source will meet the relevant emission standards. (63.1510(j)(1)(ii)) 10.18.1.3 The owner or operator must verify the calibration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months. (63.1510(j)(1)(iii)) Operating Permit Number: 96OP WE 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 42 10.18.2 Calculate and record the gaseous or liquid reactive flux injection rate (kg/Mg or lb/ton) for each operating cycle or time period used in the performance test using the procedure in § 63.1512(o). (63.1510(j)(2)) 10.18.3 Record, for each 15 -minute block period during each operating cycle or time period used in the performance test during which reactive fluxing occurs, the time, weight, and type of flux for each addition of 10.18.3.1 Gaseous or liquid reactive flux other than chlorine; and 10.18.3.2 Solid reactive flux. (63.1510(j)(3)) 10.18.4 Calculate and record the total reactive flux injection rate for each operating cycle or time period used in the performance test using the procedure in § 63.1512(o). (63.1510(j)(4)) 10.18.5 The owner or operator of a group 1 furnace or in -line fluxer performing reactive fluxing may apply to the Administrator for approval of an alternative method for monitoring and recording the total reactive flux addition rate based on monitoring the weight or quantity of reactive flux per ton of feed/charge for each operating cycle or time period used in the performance test. An alternative monitoring method will not be approved unless the owner or operator provides assurance through data and information that the affected source will meet the relevant emission standards on a continuous basis. (63.1510(j)(5)) 10.19 Sidewell group I furnace with add-on air pollution control devices. These requirements apply to the owner or operator of a sidewell group 1 furnace using add-on air pollution control devices. The owner or operator must: 10.19.1 Record in an operating log for each charge of a sidewell furnace that the level of molten metal was above the top of the passage between the sidewell and hearth during reactive flux injection, unless the furnace hearth was also equipped with an add-on control device. (63.1510(n)(1)) 10.19.2 Submit a certification of compliance with the operational standards in 63.1506(m)(7) for each 6 -month reporting period. Each certification must contain the information in 63.1516(b)(2)(iii). (63.1510(n)(2)) 10.20 Site -specific requirements for secondary aluminum processing units. 10.20.1 The owner or operator of a secondary aluminum processing unit at a facility must include, within the OM&M plan prepared in accordance with 63.1510(b), the information set forth in 63.1510(s)(1). 10.20.2 The SAPU compliance procedures within the OM&M plan may not contain any of the provisions set forth in 63.1510(s)(2). Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 43 10.20.3 To revise the SAPU compliance provisions within the OM&M plan prior to the end of the permit term, the owner or operator must submit a request to the Division containing the information required by 63.1510(s)(1) and obtain approval of the Division prior to implementing any revisions. (63.1510(s)(3)) 10.21 Secondary aluminum processing unit compliance by individual emission unit demonstration. As an alternative to the procedure of 63.1510(t), an owner or operator may demonstrate, through performance tests, that each individual emission unit within the secondary aluminum production unit is in compliance with the applicable emission limits for the emission unit. (63.1510(u)) 10.22 Alternative monitoring method for lime addition. The owner or operator of a lime -coated fabric filter that employs intermittent or noncontinuous lime addition may apply to the Administrator for approval of an alternative method for monitoring the lime addition in accordance with the provisions of 63.1510(v). 10.23 Alternative monitoring methods. An owner or operator may submit an application to the Division for approval of alternative monitoring requirements to demonstrate compliance with emission standards of Subpart RRR, subject to the provisions of 63.1510(w). § 63.1511 Performance test/compliance demonstration general requirements. 10.24 Site -specific test plan. Prior to conducting a performance test required by Subpart RRR, the owner or operator must prepare and submit a site -specific test plan which satisfies all of the requirements, and must obtain approval of the plan pursuant to the procedures set forth in 63.7(c). (63.1511(a)) 10.25 Initial Performance test: Following approval of the site -specific test plan, the owner or operator must demonstrate initial compliance in accordance with the provisions in 63.1511(b). 10.26 Test methods. The owner or operator must use the methods set forth in 63.1511(c) to determine compliance with the applicable emission limits or standards. 10.27 Alternative methods. The owner or operator may use an alternative test method, subject to approval by the Division. (63.1511(d)) 10.28 Establishment of monitoring and operating parameter values. The owner or operator of new or existing affected sources and emission units must establish a minimum or maximum operating parameter value, or an operating parameter range for each parameter to be monitored as required by 63.1510 that ensures compliance with the applicable emission limit or standard, in accordance with 63.1511(g). § 63.1512 Performance test/compliance demonstration requirements and procedures. 10.29 Scrap dryer/delacquering kiln/decoating kiln. The owner or operator must conduct performance tests to measure emissions of D/F at the outlet of the control device as set forth in 63.1512(c). Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 44 10.30 Group 1 furnace with add-on air pollution control devices. The owner or operator must conduct performance tests to measure emissions-of-DIEat the -outlet -of the control device as set forth in 63.1512(d). 10.31 Feed/charge weight measurements. During emission test(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format, the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the affected source or emission unit for each of the three test rounds and calculate and record the total weight. An owner or operator that chooses to demonstrate compliance on the basis of the aluminum production weight must measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge weight. (63.1512(k)) 10.32 Afterburner. The owner or operator of an affected source using an afterburner must comply with the requirements of 63.1512(m). 10.33 Inlet gas temperature. The owner or operator of a scrap dyer/delacquering kiln/decorating kiln or a group I furnace using a lime -injected fabric filter must use the procedures in 63.1512(n) to establish an operating parameter value or range for the inlet gas temperature. 10.34 Flux injection rate. The owner or operator must use the procedures in 63.1512(o) to establish an operating parameter value or range of the total reactive chlorine flux injection rate. 10.35 Lime injection rate. The owner or operator of an affected source or emission unit using a lime - injected fabric filter system must use the procedures in 63.1512(p) during the D/F test to establish an operating parameter value for the feeder setting for each operating cycle of time period used in the performance test. 10.36 Bag leak detection system. The owner or operator of an affected source or emission unit using a bag leak detection system must submit the information described in §63.1515(b)(6) as part of the notification of compliance status report to document conformance with the specifications and requirements in §63.1510(O. (63.1512(q)) 10.37 Labeling. The owner or operator of each scrap dryer/delacquering kiln/decorating kiln, group 1 furnace, group 2 furnace and in -line fluxer must submit the information described in 63.1515(b)(3) as part of the notification of compliance status report to document conformance with the operational standard in 63.1506(b). (63.1512(r)) 10.38 Capture/collection system. The owner or operator of a new or existing affected source or emission unit with an add-on control device must submit the information described in 63.1515(b)(2) as part of the notification of compliance status report to document conformance with the operational standard in 63.1506(c). (63.1512(s)) § 63.1513 Equations for determining compliance. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 45 10.39 The owner or operator shall use the equations set forth in 63.1513 to determine compliance with emission limits. § 63.1515 Notifications. 10.40 Initial notifications. The owner or operator must submit initial notifications to the Division as described in 63.1515(a). 10.41 Notification of compliance status report. Each owner or operator of an existing affected source must submit a notification of compliance status report within 60 days after the compliance date specified in 63.1501 (Condition 10.1, above). The notification must be signed by the responsible official who must certify its accuracy. A complete notification of compliance status report must include the information specified in 63.1515(b). The report may be submitted as set forth in 63.1515(b). § 63.1516 Reports. 10.42 Startup, shutdown, and malfunction plan/reports. The owner or operator must develop a written plan as described in 63.6(e)(3) that contains specific procedures to be followed for operating and maintaining the source during periods of startup, shutdown, and malfunction, and a program for corrective action for malfunctioning process and air pollution control equipment used to comply with the standard. The owner or operator shall also keep records of each event as required by 63.10(b) and record and report if an action taken during startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in 63.6(e)(3). In addition to the information required in 63.6(e)(3), the plan must include the items set forth in 63.1516(a). (63.1516(a)) 10.43 Excess emissions/summary report. As required by 63.10(e)(3), the owner or operator must submit semiannual reports within 60 days after the end of each 6 -month period. Each report must contain the information specified in 63.10(c). When no deviations of parameters have occurred, the owner or operator must submit a report stating that no excess emissions occurred during the reporting period. (63.1516(b)) 10.43.1 A report must be submitted if any of the conditions listed in 63.1516(6)(1) occurs during a 6 -month reporting period. 10.43.2 Each report must include each of the certifications listed in 63.1516(b)(2), as applicable. 10.43.3 The owner or operator must submit the results of any performance test conducted during the reporting period, including one complete report documenting test methods and procedures, process operation, and monitoring parameter ranges or values for each test method used for a particular type of emission point tested. (63.1516(b)(3)) 10.44 Annual compliance certifications. For the purpose of annual certifications of compliance required by 40 CFR Part 70, the owner or operator must certify continuing compliance based Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 46 upon, but not limited to, the following conditions: (I) Any period of excess emissions, as defined in 63.1516(b)(3), that occurred during the year were reported as required by Subpart RRR; and (2) All monitoring, recordkeeping, and reporting requirements were met during the year. (63.1516(c)) § 63.1517 Records 10.45 As required by 63.10(b), the owner or operator shall maintain files of all information (including all reports and notifications) required by the general provisions (Subpart A) and Subpart RRR. (63.1517(a)) Records shall be maintained as set forth in 63.1517(a)(1) through (3). 10.46 In addition to the general records required by 63.10(b), the owner or operator of a new or existing affected source (including an emission unit in a secondary aluminum processing unit) must retain records of the information listed in 63.1517(b). § 63.1516 Applicability of General Provisions 10.47 The requirements of the general provisions in Subpart A of this part that are applicable to the owner or operator subject to the requirements of this subpart are shown in Appendix A of this subpart. The general provisions that apply to this source, include but are not limited to the following: 10.47.1 Prohibited activities in 63.4. 10.47.2 Operation and maintenance requirements in 63.6(e)(1). 10.47.3 Startup, shutdown and malfunction plan requirements in 63.6(e)(3). 10.47.4 Performance test requirements in 63.7. 10.47.5 Monitoring requirements in 63.8. 10.47.6 Notification requirements in 63.9. 10.47.7 Recordkeeping requirement sin 63.10. 11. Compliance Assurance Monitoring 11.1 The Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64, as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV, apply to S002 — Delacquering Kiln with respect to the facility wide HAP emission limitations identified in Condition 9 and S006 — Melt Area Baghouse with respect to the particulate matter and facility wide HAP limitations identified in Conditions 4.1 and 9 as follows: 11.1.1 The permittee shall follow the CAM Plan provided in Appendix H of this permit. Excursions, for purposes of reporting, are as follows: Operating Permit Number: 96OP WE 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 47 11.1.1.1 For S006 (Melt Area Baghouse) Any instance in which the bag leak detection system alarms. 11.1.1.2 For S006 (Melt Area Baghouse) Any day in which the bag leak deteciont system is not operational for any time during that day. 11.1.1.3 For S002 (Delaquering Kiln) and S006 (Melt Area Baghouse) Any day in which the recorded lime injection rate is not at the level set during the relevant performance test. 11.1.1.4 For S002 (Delaquering Kiln) and S006 (Melt Area Baghouse) Any day in the daily check reveals that lime is not free -flowing. 11.1.1.5 For S002 (Delaquering Kiln) and S006 (Melt Area Baghouse) Any day in which the daily check for free -flowing lime and lime injection rate is not conducted. Note that daily checks are not required on days when the delaquering kiln and/or melter sidewells are not in operation for any time during that day. Excursions of these limitations shall be reported as required by Section IV, Conditions 21 and 22.d of this permit. 11.1.2 Operation of Approved Monitoring 11.1.2.1 At all times, the owner or operator shall maintain the monitoring, including but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment (40 CFR Part 64 § 64.7(b), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.2.2 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 pollutant -specific 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 these CAM requirements, including data averages and calculations, or fulfilling a minimum data availability requirement, if 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 (40 CFR Part 64 § 64.7(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.2.3 Response to excursions or exceedances Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 48 a. Upon detecting an excursion or exceedance, the owner or operator shall --restor-e--operation—o£__the pollutant -specific emissions unit (including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). Such actions may include initial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system), or any necessary follow-up actions to return operation to within the indicator range, designated condition, or below the applicable emission limitation or standard, as applicable (40 CFR Part 64 § 64.7(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Determination of whether the owner of operator has used acceptable procedures in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance procedures and records, and inspection of the control device, associated capture system, and the process (40 CFR Part 64 § 64.7(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.2.4 After approval of the monitoring required under the CAM requirements, 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 Division and, if necessary submit a proposed modification for this 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 (40 CFR Part 64 § 64.7(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.3 Quality Improvement Plan (QIP) Requirements 11.1.3.1 Based on the results of a determination made under the provisions of Condition 11.1.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64 § 64.8(a), as adopted by Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 49 reference in Colorado Regulation No. 3, Part C, Section XIV). -14A.32— Theowneror operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64 § 64.8(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.3.3 The QIP initially shall include procedures for evaluating the control performance problems and, based on the results of the evaluation procedures, the owner or operator shall modify the plan to include procedures for conducting one or more of the following actions, as appropriate: a. Improved preventative maintenance practices (40 CFR Part 64 § 64.8(b)(2)(i), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. Process operation changes (40 CFR Part 64 § 64.8(b)(2)(ii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). c. Appropriate improvements to control methods (40 CFR Part 64 § 64.8(b)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). d. Other steps appropriate to correct control performance (40 CFR Part 64 § 64.8(b)(2)(iv), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 11.1.3.3.a through d above) (40 CFR Part 64 § 64.8(b)(2)(v), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.3.4 If a QIP is required, the owner or operator shall develop and implement a QIP as expeditiously as practicable and shall notify the Division if the period for completing the improvements contained in the QIP exceeds 180 days from the date on which the need to implement the QIP was determined (40 CFR Part 64 § 64.8(c), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 11.1.2.3.b, the Division or the U.S. EPA may require that an owner or operator make reasonable changes to the QIP if the QIP is found to have: a. Failed to address the cause of the control device performance problems (40 CFR Part 64 § 64.8(d)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit /4 96OPWE125 Golden Aluminum, Inc. Page 50 accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64 § 64.8(d)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.3.6 Implementation of a QIP shall not excuse the owner or operator of a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or local law, or any other applicable requirements under the federal clean air act (40 CFR Part 64 § 64.8(e), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 1.1.1 Reporting and Recordkeeping Requirements 11.1.3.7 In addition to the reporting requirements in Section IV, Conditions 21 and 22.d and the recordkeeping requirements in Section IV, Condition 22.a through c, the following apply: a. The owner or operator shall submit, if necessary, a description of the actions taken to implement a QIP during the reporting period as specified in Condition 11.1.3 of this permit. 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 (40 CFR Part 64 § 64.9(a)(2)(iii), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). b. The owner or operator shall maintain records of any written QIP required pursuant to Condition 11.1.3 and any activities undertaken to implement a QIP, and any supporting information required to be maintained under these CAM requirements (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions) (40 CFR Part 64 § 64.9(b)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). c. Instead of paper records, the owner or operator may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements (40 CFR Part 64 § 64.9(b)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.4 Savings Provisions 11.1.4.1 Nothing in these CAM requirements shall excuse the owner or operator of Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 51 a source from compliance with any existing emission limitation or standard, or any existing monitoring, testing, reporting or recordkeeping requirement that may apply under federal, state, or locaFEw, or any of er applicable requirements under the federal clean air act. These CAM requirements shall not be used to justify the approval of monitoring less stringent than the monitoring which is required under separate legal authority and are not intended to establish minimum requirements for the purposes of determining the monitoring to be imposed under separate authority under the federal clean air act, including monitoring in permits issued pursuant to title I of the federal clean air act. The purpose of the CAM requirements is to require, as part of the issuance of this Title V operating permit, improved or new monitoring at those emissions units where monitoring requirements do not exist or are inadequate to meet the requirements of CAM (40 CFR Part 64 § 64.10(a)(1), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.4.2 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to impose additional or more stringent monitoring, recordkeeping, testing or reporting requirements on any owner or operator of a source under any provision of the federal clean air act, including but not limited to sections 114(a)(1) and 504(b), or state law, as applicable (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). 11.1.4.3 Nothing in these CAM requirements shall restrict or abrogate the authority of the U.S. EPA or the Division to take any enforcement action under the federal clean air act for any violation of an applicable requirement or of any person to take action under section 304 of the federal clean air act (40 CFR Part 64 § 64.10(a)(2), as adopted by reference in Colorado Regulation No. 3, Part C, Section XIV). Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 52 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B and § 25-7-114.4(3)(a), C.R.S. 1. Specific Non -Applicable Requirements Based on the information available to the Division and supplied by the applicant, the following parameters and requirements have been specifically identified as non -applicable to the facility to which this permit has been issued. This shield does not protect the source from any violations that occurred prior to or at the time of permit issuance. In addition, this shield does not protect the source from any violations that occur as a result of any modification or reconstruction on which construction commenced prior to permit issuance. No requirements were specifically requested to be included in the permit shield for this facility. 2. General Conditions Compliance with this Operating Permit shall be deemed compliance with all applicable requirements specifically identified in the permit and other requirements specifically identified in the permit as not applicable to the source. This permit shield shall not alter or affect the following: 2.1 The provisions of §§ 25-7-112 and 25-7-113, C.R.S., or § 303 of the federal act, concerning enforcement in cases of emergency; 2.2 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; 2.3 The applicable requirements of the federal Acid Rain Program, consistent with § 408(a) of the federal act; 2.4 The ability of the Air Pollution Control Division to obtain information from a source pursuant to § 25-7-111(2)(I), C.R.S., or the ability of the Administrator to obtain information pursuant to § 114 of the federal act; 2.5 The ability of the Air Pollution Control Division to reopen the Operating Permit for cause pursuant to Regulation No. 3, Part C, § XIII. 2.6 Sources are not shielded from terms and conditions that become applicable to the source subsequent to permit issuance. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 53 3. Streamlined Conditions The following applicable requirements have been subsumed within this operating permit using the pertinent streamlining procedures approved by the U.S. EPA. For purposes of the permit shield, compliance with the listed permit conditions will also serve as a compliance demonstration for purposes of the associated subsumed requirements. Permit Condition Streamlined (Subsumed) Requirements Section I, Conditions 1.1.1, 2.1.1, 3.1.1 and 4.1.1 Regulation No. 6, Pan B, Section III..C.1 [particulate matter standard - E = 3.59(P)062, — State -only provision. Section I, Conditions 6.1.1 and 7.1.1 Regulation No. 6, Part B, Section III..C.2 [particulate matter standard - E = 17.31 Oaf 16] — State -only provision. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OP W E 125 Golden Aluminum, Inc. Page 54 SECTION IV - General Permit Conditions 7/21/09 version 1. Administrative Changes Regulation No. 3, 5 CCR 1001-5, Part A, § III. The permittee shall submit an application for an administrative permit amendment to the Division for those permit changes that are described in Regulation No. 3, Part A, § I.B.1. The permittee may immediately make the change upon submission of the application to the Division. 2. Certification Requirements Regulation No. 3, 5 CCR 1001-5, Part C, §§ III.B.9., V.C.16.a.&e. and V.C.17. a. Any application, report, document and compliance certification submitted to the Air Pollution Control Division pursuant to Regulation No. 3 or the Operating Permit shall contain a certification by a responsible official of the truth, accuracy and completeness of such form, report or certification stating that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. b. All compliance certifications for terms and conditions in the Operating Permit shall be submitted to the Air Pollution Control Division at least annually unless a more frequent period is specified in the applicable requirement or by the Division in the Operating Permit. c. Compliance certifications shall contain: (i) the identification of each permit term and condition that is the basis of the certification; (ii) the compliance status of the source; (iii) whether compliance was continuous or intermittent; (iv) the method(s) used for determining the compliance status of the source, currently and over the reporting period; and (v) such other facts as the Air Pollution Control Division may require to determine the compliance status of the source. d. All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. e. If the permittee is required to develop and register a risk management plan pursuant to § I I2(r) of the federal act, the permittee shall certify its compliance with that requirement; the Operating Permit shall not incorporate the contents of the risk management plan as a permit term or condition. 3. Common Provisions Common Provisions Regulation, 5 CCR 1001-2 §§ ILA., ILB., ILC., II,.E., II.F., 11.1, and II.J a. To Control Emissions Leaving Colorado When emissions generated from sources in Colorado cross the State boundary line, such emissions shall not cause the air quality standards of the receiving State to be exceeded, provided reciprocal action is taken by the receiving State. Operating Permit Number: 960P WE 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 55 b. Emission Monitoring Requirements The Division may require owners or operators of stationary air pollution sources to install, maintain, and use instrumentation to monitor and record emission data as a basis for periodic reports to the Division. c. Performance Testing The owner or operator of any air pollution source shall, upon request of the Division, conduct performance test(s) and furnish the Division a written report of the results of such test(s) in order to determine compliance with applicable emission control regulations. Performance test(s) shall be conducted and the data reduced in accordance with the applicable reference test methods unless the Division: (i) specifies or approves, in specific cases, the use of a test method with minor changes in methodology; (ii) approves the use of an equivalent method; (iii) approves the use of an alternative method the results of which the Division has determined to be adequate for indicating where a specific source is in compliance; or (iv) waives the requirement for performance test(s) because the owner or operator of a source has demonstrated by other means to the Division's satisfaction that the affected facility is in compliance with the standard. Nothing in this paragraph shall be construed to abrogate the Commission's or Division's authority to require testing under the Colorado Revised Statutes, Title 25, Article 7, and pursuant to regulations promulgated by the Commission. Compliance test(s) shall be conducted under such conditions as the Division shall specify to the plant operator based on representative performance of the affected facility. The owner or operator shall make available to the Division such records as may be necessary to determine the conditions of the performance test(s). Operations during period of startup, shutdown, and malfunction shall not constitute representative conditions of performance test(s) unless otherwise specified in the applicable standard. The owner or operator of an affected facility shall provide the Division thirty days prior notice of the performance test to afford the Division the opportunity to have an observer present. The Division may waive the thirty day notice requirement provided that arrangements satisfactory to the Division are made for earlier testing. The owner or operator of an affected facility shall provide, or cause to be provided, performance testing facilities as follows: (i) Sampling ports adequate for test methods applicable to such facility; (ii) Safe sampling platform(s); (iii) Safe access to sampling platform(s); and (iv) Utilities for sampling and testing equipment. Each performance test shall consist of at least three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in the applicable standard. For the purpose of determining compliance with an applicable standard, the arithmetic mean of results of at least three runs shall apply. In the event that a sample is accidentally lost or conditions occur in which one of the runs must be discontinued because of forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the owner or operator's control, compliance may, upon the Division's approval, be determined using the arithmetic mean of the results of the two other runs. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 56 Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. d. Affirmative Defense Provision for Excess Emissions during Malfunctions Note that until such time as the U.S. EPA approves this provision into the Colorado State Implementation Plan (SIP), it shall be enforceable only by the State. An affirmative defense to a claim of violation under these regulations is provided to owners and operators for civil penalty actions for excess emissions during periods of malfunction. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of evidence that: (i) The excess emissions were caused by a sudden, unavoidable breakdown of equipment, or a sudden, unavoidable failure of a process to operate in the normal or usual manner, beyond the reasonable control of the owner or operator; (ii) The excess emissions did not stem from any activity or event that could have reasonably been foreseen and avoided, or planned for, and could not have been avoided by better operation and maintenance practices; (iii) Repairs were made as expeditiously as possible when the applicable emission limitations were being exceeded; (iv) The amount and duration of the excess emissions (including any bypass) were minimized to the maximum extent practicable during periods of such emissions; (v) All reasonably possible steps were taken to minimize the impact ofthe excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; (viii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation, or maintenance; (ix) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This section is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement; and (x) During the period of excess emissions, there were no exceedances of the relevant ambient air quality standards established in the Commissions' Regulations that could be attributed to the emitting source. The owner or operator of the facility experiencing excess emissions during a malfunction shall notify the division verbally as soon as possible, but no later than noon of the Division's next working day, and shall submit written notification following the initial occurrence of the excess emissions by the end of the source's next reporting period. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to failures to meet federally promulgated performance standards or emission limits, including, but not limited to, new source performance standards and national emission standards for hazardous air pollutants. The affirmative defense provision does not apply to state implementation plan (sip) limits or permit limits that have been set taking into account potential emissions during malfunctions, including, but Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 57 not necessarily limited to, certain limits with 30 -day or longer averaging times, limits that indicate they apply during malfunctions, and limits that indicate they apply at all times or without exception. e. Circumvention Clause A person shall not build, erect, install, or use any article, machine, equipment, condition, or any contrivance, the use of which, without resulting in a reduction in the total release of air pollutants to the atmosphere, reduces or conceals an emission which would otherwise constitute a violation of this regulation. No person shall circumvent this regulation by using more openings than is considered normal practice by the industry or activity in question. f. Compliance Certifications g For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any standard in the Colorado State Implementation Plan, nothing in the Colorado State Implementation Plan shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. Evidence that has the effect of making any relevant standard or permit term more stringent shall not be credible for proving a violation of the standard or permit term. When compliance or non-compliance is demonstrated by a test or procedure provided by permit or other applicable requirement the owner or operator shall be presumed to be in compliance or non-compliance unless other relevant credible evidence overcomes that presumption. Affirmative Defense Provision for Excess Emissions During Startup and Shutdown An affirmative defense is provided to owners and operators for civil penalty actions for excess emissions during periods of startup and shutdown. To establish the affirmative defense and to be relieved of a civil penalty in any action to enforce an applicable requirement, the owner or operator of the facility must meet the notification requirements below in a timely manner and prove by a preponderance of the evidence that: (i) The periods of excess emissions that occurred during startup and shutdown were short and infrequent and could not have been prevented through careful planning and design; (ii) The excess emissions were not part of a recurring pattern indicative of inadequate design, operation or maintenance; (iii) If the excess emissions were caused by a bypass (an intentional diversion of control equipment), then the bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (iv) The frequency and duration of operation in startup and shutdown periods were minimized to the maximum extent practicable; (v) All possible steps were taken to minimize the impact of excess emissions on ambient air quality; (vi) All emissions monitoring systems were kept in operation (if at all possible); (vii) The owner or operator's actions during the period of excess emissions were documented by properly signed, contemporaneous operating logs or other relevant evidence; and, (viii) At all times, the facility was operated in a manner consistent with good practices for minimizing emissions. This subparagraph is intended solely to be a factor in determining whether an affirmative defense is available to an owner or operator, and shall not constitute an additional applicable requirement. The owner or operator of the facility experiencing excess emissions during startup and shutdown shall notify the Division verbally as soon as possible, but no later than two (2) hours after the start of the next working day, and shall Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 58 submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. The Affirmative Defense Provision contained in this section shall not be available to claims for injunctive relief. The Affirmative Defense Provision does not apply to State Implementation Plan provisions or other requirements that derive from new source performance standards or national emissions standards for hazardous air pollutants or any other federally enforceable performance standard or emission limit with an averaging time greater than twenty- four hours. In addition, an affirmative defense cannot be used by a single source or small group of sources where the excess emissions have the potential to cause an exceedance of the ambient air quality standards or Prevention of Significant Deterioration (PSD) increments. In making any determination whether a source established an affirmative defense, the Division shall consider the information within the notification required above and any other information the Division deems necessary, which may include, but is not limited to, physical inspection of the facility and review of documentation pertaining to the maintenance and operation of process and air pollution control equipment. 4. Compliance Requirements Regulation No. 3, 5 CCR 1001-5 Part C, && III.C.9., V.C.I 1. & 16.d., and S 25-7-122.1(2), C.R.S. a. The permittee must comply with all conditions of the Operating Permit. Any permit noncompliance relating to federally -enforceable terms or conditions constitutes a violation of the federal act, as well as the state act and Regulation No. 3. Any permit noncompliance relating to state -only terms or conditions constitutes a violation of the state act and Regulation No. 3, shall be enforceable pursuant to state law, and shall not be enforceable by citizens under § 304 of the federal act. Any such violation of the federal act, the state act or regulations implementing either statute is grounds for enforcement action, for permit termination, revocation and reissuance or modification or for denial of a permit renewal application. b. It shall not be a defense for a permittee in an enforcement action or a consideration in favor of a permittee in a permit termination, revocation or modification action or action denying a permit renewal application that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. c. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of any request by the permittee for a permit modification, revocation and reissuance, or termination, or any notification of planned changes or anticipated noncompliance does not stay any permit condition, except as provided in §§ X. and Xl. of Regulation No. 3, Part C. d. The permittee shall furnish to the Air Pollution Control Division, within a reasonable time as specified by the Division, any information that the Division 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 Division copies of records required to be kept by the permittee, including information claimed to be confidential. Any information subject to a claim of confidentiality shall be specifically identified and submitted separately from information not subject to the claim. e. Any schedule for compliance for applicable requirements with which the source is not in compliance at the time of permit issuance shall be supplemental, and shall not sanction noncompliance with, the applicable requirements on which it is based. f. For any compliance schedule for applicable requirements with which the source is not in compliance at the time of permit issuance, the pennittee shall submit, at least every 6 months unless a more frequent period is specified in the applicable requirement or by the Air Pollution Control Division, progress reports which contain the following: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 59 (i) dates for achieving the activities, milestones, or compliance required in the schedule for compliance, and dates when such activities, milestones, or compliance were achieved; and (ii) an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. The permittee shall not knowingly falsify, tamper with, or render inaccurate any monitoring device or method required to be maintained or followed under the terms and conditions of the Operating Permit. 5. Emergency Provisions Regulation No. 3, 5 CCR 1001-5, Part C, § VII. An emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed the technology -based emission limitation under the permit due to unavoidable increases in emissions attributable to the emergency. "Emergency" does not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. An emergency constitutes an affirmative defense to an enforcement action brought for noncompliance with a technology -based emission limitation if the permittee demonstrates, through properly signed, contemporaneous operating logs, or other relevant evidence that: a. an emergency occurred and that the permittee can identify the cause(s) of the emergency; b. the permitted facility was at the time being properly operated; c. during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and d. the permittee submitted oral notice of the emergency to the Air Pollution Control Division no later than noon of the next working day following the emergency, and followed by written notice within one month of the time when emissions limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This emergency provision is in addition to any emergency or malfunction provision contained in any applicable requirement. 6. Emission Controls for Asbestos Regulation No. 8, 5 CCR 1001-10, Part B The permittee shall not conduct any asbestos abatement activities except in accordance with the provisions of Regulation No. 8, Part B, "asbestos control." 7. Emissions Trading, Marketable Permits, Economic Incentives Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.13. No permit revision shall be required under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are specifically provided for in the permit. 8. Fee Payment C.R.S. §§ 25-7-114.1(6) and 25-7-114.7 a. The permittee shall pay an annual emissions fee in accordance with the provisions of C.R.S. § 25-7-114.7. A 1% per month late payment fee shall be assessed against any invoice amounts not paid in full on the 9I st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. Operating Permit Number: 96OPWEI25 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 60 b. The permittee shall pay a permit processing fee in accordance with the provisions of C.R.S. § 25-7-114.7. If the Division estimates that processing of the permit will take more than 30 hours, it will notify the permittee of its estimate of what the actual charges may be prior to commencing any work exceeding the 30 hour limit. c. The permittee shall pay an APEN fee in accordance withthe provisions of C.R.S. § 25-7-114.1(6) for each APEN or revised APEN filed. 9. Fugitive Particulate Emissions Regulation No. 1, 5 CCR 1001-3, § III.D.1. The permittee shall employ such control measures and operating procedures as are necessary to minimize fugitive particulate emissions into the atmosphere, in accordance with the provisions of Regulation No. 1, § HI.D.I. 10. Inspection and Entry Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.16.b. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Air Pollution Control Division, or any authorized representative, to perform the following: a. enter upon the permittee's premises where an Operating Permit source is located, or emissions -related activity is conducted, or where records must be kept under the terms of the permit; b. have access to, and copy, at reasonable times, any records that must be kept under the 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 Operating Permit; d. sample or monitor at reasonable times, for the purposes of assuring compliance with the Operating Permit or applicable requirements, any substances or parameters. I I. Minor Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, §§ X. & XI. The permittee shall submit an application for a minor permit modification before making the change requested in the application. The permit shield shall not extend to minor permit modifications. 12. New Source Review Regulation No. 3, 5 CCR 1001-5, Part B The permittee shall not commence construction or modification of a source required to be reviewed under the New Source Review provisions of Regulation No. 3, Part B, without first receiving a construction permit. 13. No Property Rights Conveyed Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.11.d. This permit does not convey any property rights of any sort, or any exclusive privilege. 14. Odor Regulation No. 2, 5 CCR 1001-4, Part A As a matter of state law only, the permittee shall comply with the provisions of Regulation No. 2 concerning odorous emissions. Operating Permit Number: 96OPWEl25 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit it 96OPWE125 Golden Aluminum, Inc. Page 61 15. Off -Permit Changes to the Source Regulation -No. 3, 5 CCR-1001-5- Part C—¢ XII.B. -- - - - The permittee shall record any off -permit change to the source that causes the emissions of a regulated pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from the change, including any other data necessary to show compliance with applicable ambient air quality standards. The permittee shall provide contemporaneous notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit . The permit shield shall not apply to any off -permit change. 16. Opacity Regulation No. 1, 5 CCR 1001-3, §§ I., II. The permittee shall comply with the opacity emissions limitation set forth in Regulation No. 1, §§ 17. Open Burning Regulation No. 9, 5 CCR 1001-11 The permittee shall obtain a permit from the Division for any regulated open burning activities in accordance with provisions of Regulation No. 9. 18. Ozone Depleting Compounds Regulation No. 15, 5 CCR 1001-17 The permittee shall comply with the provisions of Regulation No. 15 concerning emissions of ozone depleting compounds. Sections 1., ILC., IID., III. IV., and V. of Regulation No. 15 shall be enforced as a matter of state law only. 19. Permit Expiration and Renewal Regulation No. 3 5 CCR 1001-5, Part C, §§ III.B.6., IV.C., V.C.2. a. The permit term shall be five (5) years. The 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. b. Applications for renewal shall be submitted at least twelve months, but not more than 18 months, prior to the expiration of the Operating Permit. An application for permit renewal may address only those portions of the permit that require revision, supplementing, or deletion, incorporating the remaining permit terms by reference from the previous permit. A copy of any materials incorporated by reference must be included with the application. 20. Portable Sources Regulation No. 3, 5 CCR 1001-5, Part C, § II.D. Portable Source permittees shall notify the Air Pollution Control Division at least 10 days in advance of each change in location. 21. Prompt Deviation Reporting Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.7.b. The permittee shall promptly report any deviation from permit requirements, including those attributable to malfunction conditions as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" is defined as follows: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 960PWE125 Golden Aluminum, Inc. Page 62 a. Any definition of "prompt" or a specific timeframe for reporting deviations provided in an underlying applicable requirement as identified in this permit; or b. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations will be submitted based on the following schedule: (i) For emissions of a hazardous air pollutant or a toxic air pollutant (as identified in the applicable regulation) that continue for more than an hour in excess of permit requirements, the report shall be made within 24 hours of the occurrence; (ii) For emissions of any regulated air pollutant, excluding a hazardous air pollutant or a toxic air pollutant that continue for more than two hours in excess of permit requirements, the report shall be made within 48 hours; and (iii) For all other deviations from permit requirements, the report shall be submitted every six (6) months, except as othenvise specified by the Division in the permit in accordance with paragraph 22.d. below. c. If any of the conditions in paragraphs b.i or b.ii above are met, the source shall notify the Division by telephone (303-692-3155) or facsimile (303-782-0278) based on the timetables listed above. [Explanatory note: Notification by telephone or facsimile must speck that this notification is a deviation report for an Operating Permit.] A written notice, certified consistent with General Condition 2.a. above (Certification Requirements), shall be submitted within 10 working days of the occurrence. All deviations reported under this section shall also be identified in the 6 -month report required above. "Prompt reporting" does not constitute an exception to the requirements of "Emergency Provisions" for the purpose of avoiding enforcement actions. 22. Record Keeping and Reporting Requirements Regulation No. 3, 5 CCR 1001-5, Part A, 6 II.; Part C, 6§ V.C.6., V.C.7. a. Unless otherwise provided in the source specific conditions of this Operating Permit, the permittee shall maintain compliance monitoring records that include the following information: (i) date, place as defined in the Operating Permit, and time of sampling or measurements; (ii) date(s) on which analyses were performed; (iii) the company or entity that performed the analysis; (iv) the analytical techniques or methods used; (v) the results of such analysis; and (vi) the operating conditions at the time of sampling or measurement. b. 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, for this purpose, includes all calibration and maintenance records and all original strip -chart recordings for continuous monitoring instrumentation, and copies of all reports required by the Operating Permit. With prior approval of the Air Pollution Control Division, the permittee may maintain any of the above records in a computerized form. c. Permittees must retain records of all required monitoring data and support information for the most recent twelve (12) month period, as well as compliance certifications for the past five (5) years on -site at all times. A permittee shall make available for the Air Pollution Control Division's review all other records of required monitoring data and support information required to be retained by the permittee upon 48 hours advance notice by the Division. Operating Permit Number: 960PWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 63 d. The permittee shall submit to the Air Pollution Control Division all reports of any required monitoring at least every six (6) months, unless an applicable requirement, the compliance assurance monitoring rule, or the Division requires submission on a more frequent basis. All instances of deviations from any permit require ueub must K. clearly identified in such reports. e. The permittee shall file an Air Pollutant Emissions Notice ("APEN") prior to constructing, modifying, or altering any facility, process, activity which constitutes a stationary source from which air pollutants are or are to be emitted, unless such source is exempt from the APEN filing requirements of Regulation No. 3, Part A, § lID. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § Il.C.2., occurs; whenever there is a change in owner or operator of any facility, process, or activity; whenever new control equipment is installed; whenever a different type of control equipment replaces an existing type of control equipment; whenever a permit limitation must be modified; or before the APEN expires. An APEN is valid for a period of five years. The five-year period recommences when a revised APEN is received by the Air Pollution Control Division. Revised APENs shall be submitted no later than 30 days before the five-year term expires. Permittees submitting revised APENs to inform the Division of a change in actual emission rates must do so by April 30 of the following year. Where a permit revision is required, the revised APEN must be filed along with a request for permit revision. APENs for changes in control equipment must be submitted before the change occurs. Annual fees are based on the most recent APEN on file with the Division. 23. Reopenings for Cause Regulation No. 3, 5 CCR 1001-5, Part C, $ XIII. a. The Air Pollution Control Division shall reopen, revise, and reissue Operating Permits; permit reopenings and reissuance shall be processed using the procedures set forth in Regulation No. 3, Part C, § III., except that proceedings to reopen and reissue permits affect only those parts of the permit for which cause to reopen exists. b. The Division shall reopen a permit whenever additional applicable requirements become applicable to a major source with a remaining permit term of three or more years, unless the effective date of the requirements is later than the date on which the permit expires, or unless a general permit is obtained to address the new requirements; whenever additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program; whenever the Division determines the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of the permit; or whenever the Division determines that the permit must be revised or revoked to assure compliance with an applicable requirement. c. The Division shall provide 30 days' advance notice to the permittee of its intent to reopen the permit, except that a shorter notice may be provided in the case of an emergency. d. The permit shield shall extend to those parts of the permit that have been changed pursuant to the reopening and reissuance procedure. 24. Section 502(b)(10) Changes Regulation No. 3, 5 CCR 1001-5, Part C, § XII.A. The permittee shall provide a minimum 7 -day advance notification to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. The permittee shall attach a copy of each such notice given to its Operating Permit. 25. Severability Clause Regulation No. 3, 5 CCR 1001-5, Part C, § V.C.10. In the event of a challenge to any portion of the permit, all emissions limits, specific and general conditions, monitoring, record keeping and reporting requirements of the permit, except those being challenged, remain valid and enforceable. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 64 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, § II1.B.2. The permittee shall not make a significant modification required to be reviewed under Regulation No. 3, Part B ("Construction Permit" requirements) without first receiving a construction permit. The permittee shall submit a complete Operating Permit application or application for an Operating Permit revision for any new or modified source within twelve months of commencing operation, to the address listed in Item 1 in Appendix D of this permit. If the permittee chooses to use the "Combined Construction/Operating Permit" application procedures of Regulation No. 3, Part C, then the Operating Permit must be received prior to commencing construction of the new or modified source. 27. Special Provisions Concerning the Acid Rain Program Regulation No. 3, 5 CCR 1001-5, Part C, §§ V.C.1.b. & 8 a. Where an applicable requirement of the federal act is more stringent than an applicable requirement of regulations promulgated under Title IV of the federal act, 40 Code of Federal Regulations (CFR) Part 72, both provisions shall be incorporated into the permit and shall be federally enforceable. b. Emissions exceeding any allowances that the source lawfully holds under Title IV of the federal act or the regulations promulgated thereunder, 40 CFR Part 72, are expressly prohibited. 28. Transfer or Assignment of Ownership Regulation No. 3, 5 CCR 1001-5 Part C, § II.C. No transfer or assignment of ownership of the Operating Permit source will be effective unless the prospective owner or operator applies to the Air Pollution Control Division on Division -supplied Administrative Permit Amendment forms, for reissuance of the existing Operating Permit. No administrative permit shall be complete until a written agreement containing a specific date for transfer of permit, responsibility, coverage, and liability between the permittee and the prospective owner or operator has been submitted to the Division. 29. Volatile Organic Compounds Regulation No. 7, 5 CCR 1001-9, §§ III & V. a. For sources located in an ozone non -attainment area or the Denver Metro Attainment Maintenance Area, all storage tank gauging devices, anti -rotation devices, accesses, seals, hatches, roof drainage systems, support structures, and pressure relief valves shall be maintained and operated to prevent detectable vapor loss except when opened, actuated, or used for necessary and proper activities (e.g. maintenance). Such opening, actuation, or use shall be limited so as to minimize vapor loss. Detectable vapor loss shall be determined visually, by touch, by presence of odor, or using a portable hydrocarbon analyzer. When an analyzer is used, detectable vapor loss means a VOC concentration exceeding 10,000 ppm. Testing shall be conducted as in Regulation No. 7, Section VIII.C.3. Except when otherwise provided by Regulation No. 7, all volatile organic compounds, excluding petroleum liquids, transferred to any tank, container, or vehicle compartment with a capacity exceeding 212 liters (56 gallons), shall be transferred using submerged or bottom filling equipment. For top loading, the fill tube shall reach within six inches of the bottom of the tank compartment. For bottom -fill operations, the inlet shall be flush with the tank bottom. b. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. c. No owner or operator of a bulk gasoline terminal, bulk gasoline plant, or gasoline dispensing facility as defined in Colorado Regulation No. 7, Section VI, shall permit gasoline to be intentionally spilled, discarded in sewers, stored in open containers, or disposed of in any other manner that would result in evaporation. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 65 30. Wood Stoves and Wood burning Appliances Regulation No,-5-C-CICIOOt-6 - The permittee shall comply with the provisions of Regulation No. 4 concerning the advertisement, sale, installation, and use of wood stoves and wood burning appliances. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A - INSPECTION INFORMATION B - MONITORING AND PERMIT DEVIATION REPORT C - COMPLIANCE CERTIFICATION REPORT D - NOTIFICATION ADDRESSES E - PERMIT ACRONYMS F - PERMIT MODIFICATIONS G - FUEL ALLOCATION H - COMPLIANCE ASSURANCE MONITORING PLAN *DISCLAIMER: None of the information found in these Appendices shall be considered to be State or Federally enforceable, except as otherwise provided in this permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information Directions to Plant: The facility is located one half mile east of highway 85 on 14th street. Safety Equipment Required: Eye Protection, Safety Shoes, Hearing Protection, Gloves and Tap Coats (Tap Coats will be furnished by Golden Aluminum). Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on April 5, 1999 with the source's Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Tab wash line, wash and rinse tank, burners 1-5, tension level, paint storage room, stamco and braner slitter, roll shop, truck shop, Maintenance shop, electrical shop, block shop, emergency generator room, cooling tower, UCB storage building, chemical storage pad, pallet storage building, waste water pretreatment, air handling units, space heater exhaust, air intake stacks, water vent, cooling tower vent, steam vent washer, burner exhaust, rinse tank, steam vent rinse tank, steamvent, air vent restrooms, burner exhaust predryer, burner exhaust washer, coating room vent, annealing furnace exhaust, QA/QC lab vents, water exhaust out, ventilation fan radiant heater, west and east QA/QC lab, coating line satellite lab, melt house lab, coil coating material, lubricating material, coolants (cold and hot mill), future building expansion, (9) 150,000 btu space heaters, , sodium hydroxide totes, potassium hydroxide totes, phosphoric acid totes, sulfuric acid totes, chromium conversion coating totes, 55 gallon drums and totes, welding and soldering operations, striping the parking lot as needed, various labs and offices, furnace rebuilds, delaquering kiln rebuild, thermal oxidizer rebuilds, various lawn mowers and weed eaters, weeding activities, sweeping parking lot, landscaping and pest control activities, trash bins, thermite fires, baghouse fires, grass and weed fires, truck wash unit, (4) copying machines, PC printers, daily janitorial services, (8) 50 lb propane tanks, (2) 1,000 gallon diesel fuel tanks, (2) 12,000 gallon coolant tanks, hot mill Hoffman filter exhaust, (2) 1,078 and 4,800 gallon waste coolant tanks, (1) 297 gallon gasoline tank, (1) 2,674 gallon Morgoil tank, (2) 900K btu heating units, (3) 600K btu heating units, 14 forklifts, 3 frontloaders, emergency power generator, front office lighting. Operating Permit Number: 96OP W E 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 2 This Page Left Intentionally Blank Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Figure: 1 4) u m'Ij ^7 y ) y CI :) y ' ) C,'1 C) I I i I I I I I i I I i I I '--I' z� I I I I I i en I I I I I ea I I I I I d I 1 i k (— k 5 Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 1 APPENDIX B Reporting Requirements and Definitions - with codes ver 2/20/07 Please note that, pursuant to 113(c)(2) of the federal Clean Air Act, any person who knowingly: (A) makes any false material statement, representation, or certification in, or omits material information from, or knowingly alters, conceals, or fails to file or maintain any notice, application, record, report, plan, or other document required pursuant to the Act to be either filed or maintained (whether with respect to the requirements imposed by the Administrator or by a State); (B) fails to notify or report as required under the Act; or (C) falsifies, tampers with, renders inaccurate, or fails to install any monitoring device or method required to be maintained or followed under the Act shall, upon conviction, be punished by a fine pursuant to title 18 of the United States Code, or by imprisonment for not more than 2 years, or both. If a conviction of any person under this paragraph is for a violation committed after a first conviction of such person under this paragraph, the maximum punishment shall be doubled with respect to both the fine and imprisonment. The permittee must comply with all conditions of this operating permit. Any permit noncompliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. The Part 70 Operating Permit program requires three types of reports to be filed for all permits. All required reports must be certified by a responsible official. Report #1: Monitoring Deviation Report (due at least every six months) For purposes of this operating permit, the Division is requiring that the monitoring reports are due every six months unless otherwise noted in the permit. All instances of deviations from permit monitoring requirements must be clearly identified in such reports. For purposes of this operating permit, monitoring means any condition determined by observation, by data from any monitoring protocol, or by any other monitoring which is required by the permit as well as the recordkeeping associated with that monitoring. This would include, for example, fuel use or process rate monitoring, fuel analyses, and operational or control device parameter monitoring. Report #2: Permit Deviation Report (must be reported "promptly") In addition to the monitoring requirements set forth in the permits as discussed above, each and every requirement of the permit is subject to deviation reporting. The reports must address deviations from permit requirements, including those attributable to malfunctions as defined in this Appendix, the probable cause of Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 2 such deviations, and any corrective actions or preventive measures taken. All deviations from any term or condition of the permit arc required to be summarized or referenced in the annual compliance certification. For purposes of this operating permit, "malfunction" shall refer to both emergency conditions and malfunctions. Additional discussion on these conditions is provided later in this Appendix. For purposes of this operating permit, the Division is requiring that the permit deviation reports are due as set forth in General Condition 21. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. For example, quarterly Excess Emission Reports required by an NSPS or Regulation No. 1, Section IV. In addition to the monitoring deviations discussed above, included in the meaning of deviation for the purposes of this operating permit are any of the following: (1) A situation where emissions exceed an emission limitation or standard contained in the permit; (2) A situation where process or control device parameter values demonstrate that an emission limitation or standard contained in the permit has not been met; (3) A situation in which observations or data collected demonstrates noncompliance with an emission limitation or standard or any work practice or operating condition required by the permit; or, (4) A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only if the emission point is subject to CAM) For reporting purposes, the Division has combined the Monitoring Deviation Report with the Permit Deviation Report. All deviations shall be reported using the following codes: 1= Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: S = CAM: 9 = Other: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Report #3: Compliance Certification (annually, as defined in the permit) Submission of compliance certifications with terms and conditions in the permit, including emission limitations, standards, or work practices, is required not less than annually. Compliance Certifications are intended to state the compliance status of each requirement of the permit over the certification period. They must be based, at a minimum, on the testing and monitoring methods specified in the Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 3 permit that were conducted during the relevant time period. In addition, if the owner or operator knows of other material information (i.e. information beyond required monitoring that has been specifically assessed in relation to how the information potentially affects compliance status), that information must be identified and addressed in the compliance certification. The compliance certification must include the following: • The identification of each term or condition of the permit that is the basis of the certification; • Whether or not the method(s) used by the owner or operator for determining the compliance status with each permit term and condition during the certification period was the method(s) specified in the permit. Such methods and other means shall include, at a minimum, the methods and means required in the permit. If necessary, the owner or operator also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Federal Clean Air Act, which prohibits knowingly making a false certification or omitting material information; • The status of compliance with the terms and conditions of the permit, and whether compliance was continuous or intermittent. The certification shall identify each deviation and take it into account in the compliance certification. Note that not all deviations are considered violations.' • Such other facts as the Division may require, consistent with the applicable requirements to which the source is subject, to determine the compliance status of the source. The Certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. (only for emission points subject to CAM) Note the requirement that the certification shall identify each deviation and take it into account in the compliance certification. Previously submitted deviation reports, including the deviation report submitted at the time of the annual certification, may be referenced in the compliance certification. Startup, Shutdown, Malfunctions and Emergencies Understanding the application of Startup, Shutdown, Malfunctions and Emergency Provisions, is very important in both the deviation reports and the annual compliance certifications. Startup, Shutdown, and Malfunctions Please note that exceedances of some New Source Performance Standards (NSPS) and Maximum Achievable Control Technology (MACT) standards that occur during Startup, Shutdown or Malfunctions may not be considered to be non-compliance since emission limits or standards often do not apply unless specifically stated in the NSPS. Such exceedances must, however, be reported as excess emissions per the NSPS/MACT rules and would still be noted in the deviation report. In regard to compliance certifications, the permittee should be ' For example, given the various emissions limitations and monitoring requirements to which a source may be subject, a deviation from one requirement may not be a deviation under another requirement which recognizes an exception and/or special circumstances relating to that same event. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 4 confident of the information related to those deviations when making compliance determinations since they are subject to Division review. The concepts of Startup, Shutdown and Malfunctions also exist for Best Available Control Technology (BACT) sources, but are not applied in the same fashion as for NSPS and MACT sources. Emergency Provisions Under the Emergency provisions of Part 70 certain operational conditions may act as an affirmative defense against enforcement action if they are properly reported. DEFINITIONS Malfunction (NSPS) means any sudden, infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. Malfunction (SIP) means any sudden and unavoidable failure of air pollution control equipment or process equipment or unintended failure of a process to operate in a normal or usual manner. Failures that are primarily caused by poor maintenance, careless operation, or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions. Emergency means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology -based emission limitation under the permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventative maintenance, careless or improper operation, or operator error. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 5 Monitoring and Permit Deviation Report - Part I 1. Following is the required format for the Monitoring and Permit Deviation report to be submitted to the Division as set forth in General Condition 21. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. 2. Part II of this Appendix B shows the format and information the Division will require for describing periods of monitoring and permit deviations, or malfunction or emergency conditions as indicated in the Table below. One Part II Form must be completed for each Deviation. Previously submitted reports (e.g. EER's or malfunctions) may be referenced and the form need not be filled out in its entirety. FACILITY NAME: Golden Aluminum, Inc. OPERATING PERMIT NO: 96OPWE125 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) Operating Permit Unit ID Unit Description Deviations noted During Period?' Deviation Code2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO S001 Three Modified Miller Shedders and Fisher - Klosterman Cyclones XQ240, Design Rated at 3 TPH each, Baghouse Controlled. S002 Custom Apros Delaquering Kiln, 14 MMBtu Natural Gas Fired Burner, Design Rated at 10 TPH, SN: BIN22lControlled by a Thermal Oxidizer and baghouse. S003 Custom Melter # I Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. S004 Custom Melter # 2 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. S005 Gillespie/Powers Melter # 3 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH, SN: 0286. S006 Melt Area Baghouse for Sidewell Melting, Degassing and Filtration, Design Rated at 15 TPH. S008 Hot Mill, Design Rated at 13.5 TPII, Controlled with an Air Purifier Centrifugal Separator. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 6 Operating Permit Unit ID Unit Description Deviations noted During P€rio.d?' Deviation Code2 Malfunction/Emergency Condition Reported During Period? YES NO YES NO S009 Two Custom Secowarwick Annealing Furnaces, Two U -Tube 17.5 MMBtu Natural Gas Fired Burners, Design Rated at 78 TPH each. S010 Davy -McKee Cold Rolling Mill 2 -STD, Design Rated at 35 TPH, Controlled with a Air Purifier Centrifugal Separator. S011 Custom Hunter Coil Coating, 26.1 MMBtu Grace Tec Natural Gas Fired Burner, Controlled with an incinerator. General Conditions Insignificant Activities X shall be based on a reasonable inquiry using readily available information. 2Use the following 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8 = CAM: 9 = Other: entries as appropriate: When the requirement is an emission limit or standard When the requirement is a production/process limit When the requirement is monitoring When the requirement is testing When required maintenance is not performed When the requirement is recordkeeping When the requirement is reporting A situation in which an excursion or exceedance as defined in 40 CFR Part 64 (the Compliance Assurance Monitoring (CAM) Rule) has occurred. When the deviation is not covered by any of the above categories Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 7 Monitoring and Permit Deviation Report - Part II FACILITY NAME: Golden Aluminum, Inc. OPERATING PERMIT NO: 960P W E 125 REPORTING PERIOD: Is the deviation being claimed as an: Emergency Malfunction N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Malfunction Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Operating Permit Condition Number Citation Explanation of Period of Deviation Duration (start/stop date & time) Action Taken to Correct the Problem Measures Taken to Prevent a Reoccurrence of the Problem Dates of Malfunctions/Emergencies Reported (if applicable) Deviation Code Division Code QA: SEE EXAMPLE ON THE NEXT PAGE Operating Permit Number: 960PWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 8 EXAMPLE FACILITY NAME: Acme Corp. OPERATING PERMIT NO: 96OPZZXXX REPORTING PERIOD: 1/1/04 - 6/30/06 Is the deviation being claimed as an: Emergency Malfunction XX N/A (For NSPS/MACT) Did the deviation occur during: Startup Shutdown Normal Operation OPERATING PERMIT UNIT IDENTIFICATION: Asphalt Plant with a Scrubber for Particulate Control - Unit XXX Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Slurry Line Feed Plugged Duration START- 1730 4/10/06 END- 1800 4/10/06 Malfunction Action Taken to Correct the Problem Line Blown Out Measures Taken to Prevent Reoccurrence of the Problem Replaced Line Filter Dates of Malfunction/Emergencies Reported (if applicable) 5/30/06 to A. Einstein, APCD Deviation Code Division Code QA: Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Monitoring and Permit Deviation Report Appendix B Page 9 Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Golden Aluminum, Inc. FACILITY IDENTIFICATION NUMBER: 1230089 PERMIT NUMBER: 96OPWE125 REPORTING PERIOD: (see first page of the permit for specific reporting period and dates) All information for the Title V Semi -Annual Deviation Reports must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. STATEMENT OF COMPLETENESS I have reviewed the information being submitted in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this submittal are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in Sub -Section 18- 1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of Sub -Section 25-7 122.1, C.R.S. Printed or Typed Name Title Signature of Responsible Official Date Signed Note: Deviation reports shall be submitted to the Division at the address given in Appendix D of this permit. No copies need be sent to the U.S. EPA. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 1 APPENDIX C Required Format for Annual Compliance Certification Reports ver 2/20/07 Following is the format for the Compliance Certification report to be submitted to the Division and the U.S. EPA annually based on the effective date of the permit. The Table below must be completed for all equipment or processes for which specific Operating Permit terms exist. FACILITY NAME: Golden Aluminum, Inc. OPERATING PERMIT NO: 96OPWE125 REPORTING PERIOD: Facility Status During the entire reporting period, this source was in compliance with ALL terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference. The method(s) used to determine compliance is/are the method(s) specified in the Permit. _ With the possible exception of the deviations identified in the table below, this source was in compliance with all terms and conditions contained in the Permit, each term and condition of which is identified and included by this reference, during the entire reporting period. The method used to determine compliance for each term and condition is the method specified in the Permit, unless otherwise indicated and described in the deviation report(s). Note that not all deviations are considered violations. Operating Permit Unit ID Unit Description Deviations Reported ' Monitoring Method per Permit?2 Was Compliance Continuous or Intermittent?3 Previous Current YES NO Continuous Intermittent S001 Three Modified Miller Shedders and Fisher -Klosterman Cyclones XQ240, Design Rated at 3 TPH each, Baghouse Controlled. S002 Custom Apros Delaquering Kiln, 14 MMBtu Natural Gas Fired Burner, Design Rated at 10 TPH, SN: BIN221Controlled by a Thermal Oxidizer and baghouse. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 2 Operating Permit Unit ID Unit Description Deviations Reported I Monitoring Method per Permit? Was Compliance Continuous or Intermittent?3 Previous Current YES NO Continuous Intermittent S003 Custom Metter # I Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. S004 Custom Metter # 2 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH. S005 Gillespie/Powers Melter # 3 Pool, 32 MMBtu air/oxy/fuel Pyretron NF 2500 Burner (Natural Gas -Fired), Design Rated at 14.95 TPH, SN: 0286. S006 Melt Area Baghouse for Sidewell Melting, Degassing and Filtration, Design Rated at 15 TPH. S008 Hot Mill, Design Rated at 13.5 TPH, Controlled with an Air Purifier Centrifugal Separator. S009 Two Custom Secowarwick Annealing Furnaces, Two U -Tube 17.5 MMBtu Natural Gas Fired Burners, Design Rated at 78 TPH each. S010 Davy -McKee Cold Rolling Mill 2 - STD, Design Rated at 35 TPH, Controlled with a Air Purifier Centrifugal Separator. S011 Custom Hunter Coil Coating, 26.1 MMBtu Grace Tec Natural Gas Fired Burner, Controlled with an incinerator. General Conditions Insignificant Activities Operating Permit Number: 96OP WE 125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 3 I If deviations were noted in a previous deviation report , put an "X" under "previous". If deviations were noted in the current deviation report (i.e. for the last six months of the annual reporting period), put an "X" under "current". Mark both columns if both apply. 2 Note whether the method(s) used to determine the compliance status with each term and condition was the method(s) specified in the permit. If it was not, mark "no" and attach additional information/explanation. 3 Note whether the compliance status with of each term and condition provided was continuous or intermittent. "Intermittent Compliance" can mean either that noncompliance has occurred or that the owner or operator has data sufficient to certify compliance only on an intermittent basis. Certification of intermittent compliance therefore does not necessarily mean that any noncompliance has occurred. NOTE: The Periodic Monitoring requirements of the Operating Permit program rule are intended to provide assurance that even in the absence of a continuous system of monitoring the Title V source can demonstrate whether it has operated in continuous compliance for the duration of the reporting period. Therefore, if a source I) conducts all of the monitoring and recordkeeping required in its permit, even if such activities are done periodically and not continuously, and if 2) such monitoring and recordkeeping does not indicate non-compliance, and if 3) the Responsible Official is not aware of any credible evidence that indicates non-compliance, then the Responsible Official can certify that the emission point(s) in question were in continuous compliance during the applicable time period. Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix C Page 4 II. Status for Accidental Release Prevention Program: A. This facility is subject is not subject to the provisions of the Accidental Release Prevention Program (Section 112(r) of the Federal Clean Air Act) B. If subject: The facility requirements of section 112(r). is is not in compliance with all the 1. A Risk Management Plan will be has been submitted to the appropriate authority and/or the designated central location by the required date. III. Certification All information for the Annual Compliance Certification must be certified by a responsible official as defined in Colorado Regulation No. 3, Part A, Section I.B.38. This signed certification document must be packaged with the documents being submitted. I have reviewed this certification in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this certification are true, accurate and complete. Please note that the Colorado Statutes state that any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in this document is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Title Signature Date Signed NOTE: All compliance certifications shall be submitted to the Air Pollution Control Division and to the Environmental Protection Agency at the addresses listed in Appendix D of this Permit. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 1 APPENDIX D Notification Addresses 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B 1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Jim King 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-T U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Permit Modifications, Off Permit Changes: Office of Partnerships and Regulatory Assistance Air and Radiation Programs, 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 1 Listed Alphabetically: APPENDIX E Permit Acronyms AIRS - Aerometric Information Retrieval System AP -42 - EPA Document Compiling Air Pollutant Emission Factors APEN - Air Pollution Emission Notice (State of Colorado) APCD - Air Pollution Control Division (State of Colorado) ASTM - American Society for Testing and Materials BACT - Best Available Control Technology BTU - British Thermal Unit CAA - Clean Air Act (CAAA = Clean Air Act Amendments) CCR - Colorado Code of Regulations CEM - Continuous Emissions Monitor CF - Cubic Feet (SCF = Standard Cubic Feet) CFR - Code of Federal Regulations CO - Carbon Monoxide COM - Continuous Opacity Monitor CRS - Colorado Revised Statute D/F - Dioxin/Furan EF - Emission Factor EPA - Environmental Protection Agency FI - Fuel Input Rate in Lbs/mmBtu FR - Federal Register G - Grams Gal - Gallon GPM - Gallons per Minute HAPs - Hazardous Air Pollutants HC1 - Hydrogen Chloride HP - Horsepower HP -HR Horsepower Hour (G/HP-HR = Grams per Horsepower Hour) KG - Kilogram LAER Lowest Achievable Emission Rate LBS - Pounds M - Thousand Mg - Megagram µg microgram MM - Million MMscf - Million Standard Cubic Feet MMscfd - Million Standard Cubic Feet per Day N/A or NA - Not Applicable NOx - Nitrogen Oxides NESHAP - National Emission Standards for Hazardous Air Pollutants Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 2 NSPS - New Source Performance Standards OM�1M - Operating, Maintenance and Monitoring (Plan) P - Process Weight Rate in Tons/Hr PE - Particulate Emissions PM - Particulate Matter PM10 - Particulate Matter Under 10 Microns PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT - Reasonably Available Control Technology SAPU - Secondary Aluminum Processing Unit SCC - Source Classification Code SCF - Standard Cubic Feet SIC - Standard Industrial Classification SO2 - Sulfur Dioxide\ TEQ - Toxicity Equivalent THC - Total Hydrocarbon TPY - Tons Per Year TSP - Total Suspended Particulate VOC - Volatile Organic Compounds Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 1 APPENDIX F Permit Modifications DATE OF REVISION TYPE OF SECTION REVISION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Fuel Allocation Appendix G Page 1 APPENDIX G Fuel Allocation *The methods outlined will be used to calculate fuel use for Units S002, S009 and S011 A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design RatellHrs. of Operation) X [Facility Fuel Use for Month — Fuel Use for Units S003 + S004 + S0051 [Sum of Numerator for Each Piece of Equipment] Unit Number Fuel Design Rate S002 14.0 MMBtu/hr S009 17.5 MMBtu/hr SO II 26.1 MMBtu/hr *Allocated Fuel Use shall be determined within the first seven days of each month based on the monthly hours of operation for each listed piece of equipment from the previous month. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring APPENDIX H Appendix H Page 1 Compliance Assurance Monitoring Plan I. Background a. Emission Unit Description: S002 — Delacquering Kiln — The kiln burns the coating off of shredded aluminum scrap. A lime - injected baghouse controls HAP emissions. S006 — Hot Melt Area Baghouse — This baghouse controls PM. PM10, and HAP emissions from the sidewells from Melters #1, #2 and #3 and the degassing and filtration units. b. Applicable Regulations, Emission Limits, Monitoring Requirements Parameter Permit Condition Number Emission Limitations Monitoring Requirements PM (S006) 4.1.1 19.20 lbs/hour 11.90 tons/year bag leak detection system PM10 (S006) 4.1.1 11.90 tons/year bag leak detection system HAPs 9 8 tons/year any single HAP 30 tons/year combined HAPs Lime injection rate c. Control Technology S002 — Delacquering Kiln: Lime Injected Baghouse S006 -- Melt Area Baghouse (Sidewells of Melters #1, #2 and #3): Lime Injected Baghouse Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring II. Monitoring Approach Appendix H Page 2 Indicator (S006 Only) Indicator (Both S002 and S006) I. Indicator Bag Leak Detection System Lime Injection Rate Measurement Approach A Triboguard © particulate monitor continuously detects and measures releases of particulate matter in the discharge air system. Lime addition is regulated by a variable frequency drive to maintain constant lime feed into the exhaust stream for HCI control, Lime addition rate is set by a controller to correspond to the type of scrap being processed. Rate of feed is set by verifying lime flow to motor drive speed. On a daily basis, the permittee shall verify that lime is free -flowing daily and record the lime injection rate. II. Indicator Range An excursion is defined as any instance in which the bag leak detection system alarm sounds. An excursion is also defined as any day in which the bag leak detection system is not operational for any part of that day. In addition to the above, when an excursion occurs, personnel will investigate to determine why baghouse and/or bag leak detection system performance is compromised and make any necessary adjustments. The Work Order system log will be updated with repairs or adjustments made, the craftsman(s) involved, date and time. An excursion is defined as any day in which the recorded lime injection rate is not at the level set during the performance test. An excursion is also defined as any day on which the daily check reveals that lime is not free -flowing. An excursion is also defined as any day on which the daily checks have not been conducted. Daily checks are not required on days when the delaquering kiln and/or melter sidewells are not in operation for any time during that day. Excursions require the source to conduct corrective action, The Work Order system log will be updated with repairs or adjustments made, the craftsman(s) involved, date and time. II. Performance Criteria a. Data Representativeness The bag leak detection system indicates bag condition and estimates remaining bag life. The lime injection rates were determined during performance tests. b. QA/QC Practices and Criteria The bag leak detections systems shall meet the requirements in 40 CFR Part 63 Subpart RRR § 63.1510(O (Section II, Condition 10.14) Calibration and certification of the accuracy of each monitoring device shall occur at least once every six months, according to the manufacturer's instructions. Maintenance of the control device shall occur in accordance with the manufacturer's instructions and recommendations. c. Monitoring Frequency Continuously Daily checks are conducted to verify that the lime is free -flowing and to monitor and record the lime injection rate. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Assurance Monitoring Appendix H Page 3 III. Justification a. Background: This facility manufactures coiled aluminum sheet from aluminum scrap. Rational for Selection of Performance Indicators: The bag leak detection system was selected as an indicator of baghouse performance as the systems are a means to determine bag filter condition and remaining life. The lime injection rate was selected as an indicator since lime is injected in order to reduce HCl emissions, therefore, changes in the injection rate will directly affect the HO emission. The Secondary Aluminum Production MACT requires that delaquering kilns and group 1 furnaces controlled by lime -injected baghouses use bag leak detection devices and maintain the lime feeder setting at the same level established during the performance test. The CAM rule specifies that monitoring required for a MACT standard is presumptively acceptable monitoring, provided the monitoring is applicable to the performance of the control device (40 CFR Part 64 § 64.4(b)(4)). Since the MACT monitoring is for the same control device, the Division considers that the indicators are presumptively acceptable. While the MACT requires that other parameters be monitored (such as inlet baghouse temperature), the permittee is required to monitor these parameters under the MACT requirements and they have not been specifically identified as CAM requirements. b. Rational for Selection of Indicator Ranges: The indicator ranges that were selected (when the bag leak detection system alarms and maintain lime injection rate at the same level established during the performance test) are consistent with the MACT requirements. As indicated above, since MACT monitoring is considered presumptively acceptable, the Division considers that the indicator range is also presumptively acceptable. Operating Permit Number: 96OPWE125 125 First Issued: 11/1/99 Renewed: DRAFT \12/14/2009) Jackie Joyce - Re: 96WE125 renew2draft withchanges to JJ 2009.doc Page 1 From: Jackie Joyce To: Forchette, Don Date: 12/14/2009 11:13 AM Subject: Re: 96WE125 renew2draft withchanges to JJ 2009.doc Don, I've made the changes you requested. I should get this to our public comment coordinator this week. >>> "Forchette, Don" <DonForchette@GoldenAluminum.com> 12/10/2009 2:29 PM >>> Dear Jackie, Hope you are coping with this terrible cold snap. My inputs to the Permit draft (finally) are attached. They are few! Page 17 - In the equation the word "charged" to replace "processed". This change eliminates a possible confusion with the "processed" term as used in-house. APPENDIX A Page 1 - In the List of Insignificant Activities please replace "titanium conversion coating totes" with "chromium conversion coating totes" APPENDIX G Page 1 - In the equation statement: "fuel use for units 5003-5005" The dash to indicate "thru" may be confused with a minus sign. Better as "fuel use for units S003+5004+5005". That's all I have. I do see changes that will require up -grades in our documentation of "specifications shall be in a written format, and shall be made available to the Division upon request" (examples -1.1.3; 2.1.3). This won't be a problem. Once the final Permit is available we will train each department on its implementation. Thanks -Stay warm DAForchette I (12/12/2009) Jackie Joyce - 96WE125 renew2draft withchanges to JJ 2009.doc Page 1 From: To: Date: Subject: Attachments: "Forchette, Don" <DonForchette@GoldenAluminum.com> Jackie Joyce <jejoyce@cdphe.state.co.us> 12/10/2009 2:29 PM 96WE125 renew2draft withchanges to JJ 2009.doc 96WE125 renew2draft withchanges to JJ 2009.doc Dear Jackie, Hope you are coping with this terrible cold snap. My inputs to the Permit draft (finally) are attached. They are few! Page 17 - In the equation the word "charged" to replace "processed". This change eliminates a possible confusion with the "processed" term as used in-house. APPENDIX A Page 1 - In the List of Insignificant Activities please replace "titanium conversion coating totes" with "chromium conversion coating totes" APPENDIX G Page 1 - In the equation statement: "fuel use for units S003-8005" The dash to indicate "thru" may be confused with a minus sign. Better as "fuel use for units S003+S004+S005". That's all I have. I do see changes that will require up -grades in our documentation of "specifications shall be in a written format, and shall be made available to the Division upon request" (examples -1.1.3; 2.1.3). This won't be a problem. Once the final Permit is available we will train each department on its implementation. Thanks -Stay warm DAForchette Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 17 PE = 3.59 x (P)° 62 where: PE = particulate standard in lbs/hr P = process weight rate in tons/hr 4.1.2 Emissions of PM and PM1° from all melter sidwells combined shall not exceed the limitations stated above (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 91 WE864) as modified under the provisions of Section I, Condition 1.3). Monthly emissions from all three melter sidewlls together shall be calculated by the end of the subsequent month, using the emission factors in the above table (from 10/29/02 synthetic minor (HAP) permit application — factors based on calculation) in the following equation: Tons/mo = Quantity of shredded/scrap material charged (tons/mo) x EF (lbs/ton Al) 2000 lbs/ton Monthly emissions shall be used in a twelve month rolling total to monitor compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.1.3 Routine maintenance of the baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. Should visible emissions, other than steam, be observed, the source shall follow the steps in 4.1.3.1 and 4.1.3.2 and record in a log the opacity observations and any action taken as a result of the observations. The baghouse pressure drop shall be monitored and recorded daily. Should the daily recorded baghouse pressure drop be outside the manufacturer's recommendations, the source shall follow the steps in 4.1.3.1, 4.1.3.3, and 4.1.3.4, within one hour of the recorded pressure drop. 4.1.3.1 Verify that the process and control equipment are operating properly and perform any maintenance or adjustments needed to minimize visible emissions. 4.1.3.2 If, after maintenance and/or adjustments have been made, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Inspection Information Appendix A Page 1 APPENDIX A - Inspection Information Directions to-Plantr The facility is located one half mile east of highway 85 on 14`h street. Safety Equipment Required: Eye Protection, Safety Shoes, Hearing Protection, Gloves and Tap Coats (Tap Coats will be furnished by Golden Aluminum). Facility Plot Plan: Figure 1 (following page) shows the plot plan as submitted on April 5, 1999 with the source's Title V Operating Permit Application. List of Insignificant Activities: The following list of insignificant activities was provided by the source to assist in the understanding of the facility layout. Since there is no requirement to update such a list, activities may have changed since the last filing. Insignificant activities and/or sources of emissions as submitted in the application are as follows: Tab wash line, wash and rinse tank, burners 1-5, tension level, paint storage room, stamco and braner slitter, roll shop, truck shop, Maintenance shop, electrical shop, block shop, emergency generator room, cooling tower, UCB storage building, chemical storage pad, pallet storage building, waste water pretreatment, air handling units, space heater exhaust, air intake stacks, water vent, cooling tower vent, steam vent washer, burner exhaust, rinse tank, steam vent rinse tank, steamvent, air vent restrooms, burner exhaust predryer, burner exhaust washer, coating room vent, annealing furnace exhaust, QA/QC lab vents, water exhaust out, ventilation fan radiant heater, west and east QA/QC lab, coating line satellite lab, melt house lab, coil coating material, lubricating material, coolants (cold and hot mill), future building expansion, (9) 150,000 btu space heaters, , sodium hydroxide totes, potassium hydroxide totes, phosphoric acid totes, sulfuric acid totes, chromium conversion coating totes, 55 gallon drums and totes, welding and soldering operations, striping the parking lot as needed, various labs and offices, furnace rebuilds, delaquering kiln rebuild, thermal oxidizer rebuilds, various lawn mowers and weed eaters, weeding activities, sweeping parking lot, landscaping and pest control activities, trash bins, thermite tires, baghouse fires, grass and weed fires, truck wash unit, (4) copying machines, PC printers, daily janitorial services, (8) 50 lb propane tanks, (2) 1,000 gallon diesel fuel tanks, (2) 12,000 gallon coolant tanks, hot mill Hoffman filter exhaust, (2) 1,078 and 4,800 gallon waste coolant tanks, (1) 297 gallon gasoline tank, (1) 2,674 gallon Morgoil tank, (2) 900K btu heating units, (3) 600K btu heating units, 14 forklifts, 3 frontloaders, emergency power generator, front office lighting. Operating Permit Number: 96OP W E 125 First Issued: 11/1/99 Renewed: DRAFT ' Air Pollution Control Division Colorado Operating Permit Fuel Allocation Appendix G Page 1 APPENDIX G Fuel Allocation *The methods outlined will be used to calculate fuel use for Units S002, S009 and S011 A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design Ratel[Hrs. of Operation] X [Facility Fuel Use for Month — Fuel Use for Units S003+S004+S0051 [Sum of Numerator for Each Piece of Equipment] Unit Number Fuel Design Rate S002 14.0 MMBtu/hr S009 17.5 MMBtu/hr SOl l 26.1 MMBtu/hr *Allocated Fuel Use shall be determined within the first seven days of each month based on the monthly hours of operation for each listed piece of equipment from the previous month. Operating Permit Number: 96OPWE125 First Issued: 11/1/99 Renewed: DRAFT STATE OF COLORADO Bill Ritter, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us October 21, 2009 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 Mr. Don Forchette Environmental Engineer Golden Aluminum, Inc. 1405 East 14th Street Ft. Lupton, CO 80621 SUBJECT: Draft Renewal Operating Permit for Golden Aluminum Colorado Department of Public Health and Environment Dear Mr. Forchette: Enclosed please find a draft of the renewal operating permit for your facility as well as a copy of the technical review summary document. Please review and submit any comments you may have concerning the modified draft operating permit. Following our review of your comments, we will send the draft permit out for a 30 -day Public Comment period and then to EPA for their 45 -day review period. The regulations also require that the applicant receive written notice of their right to a formal hearing before the Colorado Air Quality Control Commission at the same time that the Public Comment packet goes out. You will receive a separate letter containing that information. This draft renewal permit contains the modifications that you requested in your renewal application received on July 1, 2009 and the minor modification applications submitted on April 1 and 6, 2009. The permit was also revised to be more consistent with recently issued permits, correct errors, omissions and discrepancies identified during inspections and/or review of the renewal application and incorporate EPA comments made on other operating permits for similar sources. The changes are summarized in the technical review document for the renewal permit. While you are reviewing this permit, please be aware of the following: 1. EPA promulgated National Emission Standards for Hazardous Air Pollutants for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources (40 CFR Part 63 Subpart HHHHHH) on January 9, 2008. Since your facility is not a major source of —--hazardous-air-pollutarrt-(HAP) emissions, -these-rules-potentially-apply--The-Division- — believes that any spray coating of motor vehicles and mobile equipment and spray application of coatings that contain target HAPS that may occur at this facility would meet the definition of facility maintenance and would therefore, not be subject to the requirements in 40 CFR Part 63 Subpart HHHHHH. However, we cannot determine whether any paint stripping activities at this facility would be subject to these Mr. Don Forchette, Golden Aluminum, Inc. October 21, 2009 Draft Renewal Operating Permit Page 2 requirements. Please indicate whether any paint stripping chemicals used at your facility include methlyene chloride. We would like you to review this permit and respond to the items identified above by November 25, 2009. Feel free to give me a call at (303) 692-3267 if you have any questions or concerns. Sincerely, Jacqueline Joyce, Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division Enclosures June 29, 2009 Ms. Jacqueline Joyce Colorado Dept. of Public Health and Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Co. 80246-15303 :Le C' (1 7///(i/ SUBJECT: Operating Permit Renewal for Golden Aluminum Inc : 96OPWE125 Dear Ms. Joyce: cy r,- , „ • -• Please find the companion document Form 2000-800 as a renewal of our existing Operating Permit, in fulfillment of Colorado Air Quality Control Commission Regulation No.3 Part C, Section 111.8.6 and Section V.C. Please note that no changes are being requested for the existing Operating Permit. We would like to point out a "units" clarification for 96OPWE125 Section 3 Part 8. 5011 -Coil Coating Line w/Thermal Oxidizer; the Parameter table; "Coating of Aluminum Sheet", Long Term Limitation the units should be 1,235,140.5 Ksqft/yr. as stated on our Coil Coating APEN. If further information, clarification or assistance is needed, please contacts us. Sincerely y j Mark Selepack Vice President of Operations Golden Aluminum Inc. 1405 East 14th St. Fort Lupton Colorado 80621 1405 East 14th Street, P.O. Box 207 • Fort Lupton, Colorado 80621 • (303) 659-9767 • Fax (303) 654-8360 Operating Permit Application TABULATION OF PERMIT APPLICATION FORMS Colorado Department of I Rallis 09-94 Air pollution Control Division Facility Name: GOLDEN ALUMINUM INC. I. ADMINISTRATION 96OPWE 125 Renewal FORM 2000-800 Facility Identification Code: CO 1230089 This application contains the following forms: Renewal of existing Operating Permit Fort 2000-100, Facility Identification Fmni 2000-101, Facility Plot Plan Forms 2000-102, -IO2A, and -10213, Source and Site Descriptions IL EMISSIONS SO(IRCE DESCRIPTION I ION Total Number of This Form lists application contains the following forms lone brat lilt each facility boiler, printing Renewal of existing Operating Permit Form 2000-200, Stack Identification 0 Form 2000-300, l3oiler or Furnace Operalion 0 Fong 2000-301, Storage Tanks 0 Form 2000-302, Internal Combustion Engine 0 Form 2000-303, Incineration 0 Polo,, 2000-304, Panting Operations 0 Form 2000-305, fainting and Coating Operations 0 Form 2000-306, Miscellaneous Processes 0 Form 2000-307, Glycol Dehydration Unit 0 III. AIR POLLUTION CONTROL SYSIT.M 96OPWE125 Renewal fatal Number of This Form This application contains the following forms: Renewal of existing Operating Permit Form 2000-400, Miscellaneous 0 Form 2000-401, Condensers 0 Form 2000-402, Adsorbcrs 0 Form 2000-403, Catalytic or Thermal Oxidation 0 Form 2000-404, Cyclones/Settling Chambers 0 Form 2000-405, Electrostatic Precipitates 0 Form 2000-406, Wet Collection Systems 0 Form 2000-407, I3aghouscs/Fabric Fillers 0 IV cOMPlIANCF 96OPWE125 Renewal -rota) Number DEMONS] RA I ION of 'ibis Form I his application contains the following forms lone for each foci lay boiler, printing operation. Renewal of existing Operating Permit Form 2000-500, Compliance Certificalion- Monitoring and 0 Rrporlloc Form 2000-501, Continuous Emission Monitoring 0 Form 2000-502, Periodic Emission Monitoring Using 0 Portable Monitors Finn 2000-503, Control System Parameters or Operation 0 Parameters of a Process Form 2000-504, Monitoring Maintenance Procedures 0 Form 2000-505, Stack Testing 0 Form 2000-506, Fuel Sampling and Analysis 0 Form 2000-507, Rccordkccping 0 Form 2000-508, Other Methods 0 V. EMISSION SUMMARY AND COMPLIANCE CERTIFICATION 960PWEl25 Renewal Total Number of This Form This application contains the following forms quantifying emissions, certifying compliance with applicable requirements. and developing a compliance plan Renewal of existing Operating Permit Form 2000-600, Emission Unit Hazardous Air Pollutants 0 Form 2000-601, Emission Unit Criteria Air Pollutants 0 Form 2000-602, Facility Iazardous Air Pollutants 0 Form 2000-603, Facility Criteria Air Pollutants 0 Form 2000-604, Applicable Requirements and Slaws of Emission Unit 0 Form 2000-605, Permit Shield Protection Identification 0 Form 2000-606, Emission Unit Compliance Plan - Commitments and Schedule 0 Form 2000-607, Plant -Wide Applicable Requirements 0 Form 2000-608, Plant -Wide Compliance Plan - Commitments and Schedule 0 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - FEDERAL/STATE CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS - FEDERAL/STATE CONDITIONS (check one box only) 7. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7 122.1, C.R.S. Printed or Typed Name Mark Selepack Title - V.P. of Operations Signature Date Signed - June 2911 2009 Operating Permit Application 800 CnloraiIn Department of I Iealllt Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS FORM 2000 - Facility Name: GOLDEN ALUMINUM INC. 09-94 Facility Identification Code: CO 1230089 VI. SIGNATURE OF RESPONSIBLE OFFICIAL - STATE ONLY CONDITIONS A. STATEMENT OF COMPLETENESS I have reviewed this application in its entirety and. based on information and belief formed alter reasonable inquiry, I certify that the statements and information contained in this application are true, accurate and complete. B. CERTIFICATION OF FACILITY COMPLIANCE STATUS FOR STATE -ONLY CONDITIONS (check one box only) X I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements. I certify that the facility described in this air pollution permit application is fully in compliance with all applicable requirements, except for the following emissions unit(s): (list all non -complying units) WARNING: Any person who knowingly, as defined in § 18-1-501(6), C.R.S., makes any false material statement, representation, or certification in, or omits material information from this application is guilty of a misdemeanor and may be punished in accordance with the provisions of § 25-7122.1, C.K.S. Printed or Typed Name Mark Selepack Title-V.P. of Operations Signature / / ,/ o C c Date Signed 6/29/2009 SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B 1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 STATE OF COLORADO Bill Hitler, Jr-, Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry Creek Dr. S. Denver, Colorado 80246-1530 Phone (303) 692-2000 TDD Line (303) 691-7700 Located in Glendale, Colorado http://www.cdphe.state.co.us April 10, 2009 Mr. Don Forchette Environmental Engineer Golden Aluminum, Inc. 1405 East 14`° Street Ft. Lupton, CO 80621 Laboratory Services Division 8100 Lowry Blvd. Denver, Colorado 80230-6928 (303) 692-3090 RE: Complete Application for Minor Modification to Operating Permit 96OPWE125 Dear Mr. Forchette: Colorado Department of Public Health and Environment The Division received your requests to modify the Operating Permit for your facility on April 1 and 6, 2009. The Division agrees that the requested modifications meet the requirements of a minor permit modification (Reg 3, Part C, Section X.A) and considers that your submittals comprise a complete application for a minor permit modification. The Division considers your application for a minor operating permit modification to be complete as of April 6, 2009. As specified in Colorado Regulation 3, Part C, Section X.1, "a source shall be allowed to make the changes proposed in its application for a minor permit modification immediately after it files such [complete] application," Note that if you choose to make the changes proposed in your minor permit application before the Division issues the revised permit that Colorado Regulation 3, Part C, Section X.I requires that: "...the source must comply with both the applicable requirements governing the change and the proposed permit terms and conditions. During this time the source does not need to comply with existing permit terms and conditions it seeks to modify, but if the source fails to comply with its proposed permit terms and conditions during this period, the existing permit terms and conditions it seeks to modify shall be fully enforceable by the Division." Typically, the next step for this permit modification is the EPA 45 -day review period. Although you submitted draft permit language, the Division is considering alternative language and we will most likely make revisions to this permit based on recent internal permit processing decisions and/or EPA comments on other Operating Permits. We believe that these changes meet the requirements for minor permit modifications (Reg 3, Part C, Section X.A). We will provide you with an opportunity to review the language we propose for your modification, as well as the additional changes that we make to your permit. You will receive a draft Operating Permit and technical review document for your review in the near future. Note that since your renewal application is due on July 1, 2009, the Division is considering incorporating this modification into your renewal permit. If you have any further questions please contact me at (303) 692-3267. Sincerely, Jacqueline Joyce Permit Engineer Operating Permit Unit Stationary Sources Program Air Pollution Control Division C\ 4. B9 Ca 0 INI On CI RE: X.D.3 Certification by a responsible official that the proposed modification meets the criteria for use of minor permit modification procedures and a request that such procedures be used. I have reviewed this application in its entirety and, based on information and belief formed after reasonable inquiry, I certify that the statements and information contained in this Minor Permit Modification Application are true, accurate and complete. Mark Selepack V.P. of Operations, Golden Aluminum Inc. Date March 25, 2009 1405 East 14th Street, P.O. Box 207 • Fort Lupton, Colorado 80621 • (303) 659-9767 • Fax (303) 654-8360 March 20, 2009 Colorado Department of Public Health and Environment Air Pollution Control Division Attn: Jackie Joyce Permit Engineer Operating Permit Section, Stationary Sources 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 RE: Minor Permit Modification; Operating Permit # 96OPWE125 Dear Ms. Joyce, (a ll o rIJ 111 99 4%a I'm writing the Colorado Department of Public Health and Environment (CDPHE) to request a minor permit modification for the above reference permit concerning melt house operations. This request is to expand the authorization for charging coated scrap to all three of our melter sidewells. The melt house is comprised of three melters; each a reverberatory furnace with an attached sidewell. All three sidewells are of the same design, with Melter S003 and S004 being identical; Melter S005 with the same lateral dimensions but slightly deeper. The current permit limits the charging of coated scrap to Melter sidewells S004 and S005. Golden Aluminum is submitting as a "Minor Permit Modification"(CDPHE Air Quality Control Commission Regulation #3, Part C, Section X) our proposed plans to configure the sidewell of S003 as MACT compliant and submit to performance testing within 90 days. Golden Aluminum would also request the operation flexibility of charging coated material simultaneously to our MACT compliant sidewells. Golden Aluminum is proposing to operate in a two melter simultaneous scheme. One of our three current melters will be off line at any point in time. This will provide for needed process economy and operational flexibility, but still comply with the Secondary Aluminum MACT requirements and Operating Permit Conditions 3.1 through 3.8. The Modification requires changes in the permit to broaden Condition 3.9 to allow all three Melter sidewells to process coated, lubed and painted scrap when online in the proposed two melter scheme. Our Coated Charged Designated Sidewell (CCDS) OM&M plan will be replaced by an OM&M plan that requires the tracking of total coated material charged facility wide to the performance test determined limit. A copy of the OM&M plan and the emissions capture design for Melters S003 and S005 sidewells are attached for your review. All three sidewells exhaust to S006 lime -injected baghouse which is the control. 1405 East 14th Street, P.O. Box 207 • Fort Lupton, Colorado 80621 • (303) 659-9767 • Fax (303) 654-8360 4 (� (C)P,�k.�\,1 n A 09 Vl 0 We are not proposing any changes in production or emissions limits, and because the siewe s are already vented to the previously tested S006 Melt Area Baghouse, there would be no change in our stack emissions. Golden Aluminum is seeking CDPHE approval for operating in a two simultaneous melter operation scheme. Golden Aluminum is also seeking to modify the existing hoods to take advantage of the baghouse capability gained with the two melter scheme, while still meeting ACGIH design criteria as stated in §63.1506,c,1. Emissions from all three sidewell enclosures will remain ducted to one common lime -injected baghouse, (Emission Point S006). This baghouse was the point source for a Dioxin/Furan successful compliance air test July11 & 12 2006 (APT Inc.). As the next step in pursuing this permit modification, we are at your disposal to meet with CDPHE air permitting staff to further discuss the proposed project and provide any additional details needed to help you render a decision. Please contact me at your earliest convenience if you have any questions or would like to schedule a meeting. Thank you for your prompt attention to this important matter. Don Forchette Environmental Engineer Golden Aluminum Inc. 1405 East 14th Street Fort Lupton, Co. 80621 303-654-8366 donforchette@goldenaluminum.com cc: Emilio Llamozas USEPA 999 18`h Street, Suite 300 8ENF-AT Denver, Co. 80202-2466 1405 East 14th Street, P.O. Box 207 • Fort Lupton, Colorado 80621 • (303) 659-9767 • Fax (303) 654-8360 Table I (a) APT Project NAL3115 Test Report — MACT Compliance (August 14, 2003) Nichols Aluminum — Fort Lupton, Colorado Melt Area Baghouse— Sidewell (S006/019/P006}, Emissions Testing Results, June 11 & 12, 2003 Date Start Time Stop Time Run #1 Run #2 Run #3 Average 06/11/2003 06/11/2003 06/1212003 09:15 13:19 11:22 12:15 16:19 14:22 Stack Parameters Slack Temp. ("F) Gas Flow (dscfm) Gas Flow (actin) OZ (%vd) CO2'(%vd) 1-12O (%vw) Isokinetic Ratio (%) 125 126 132 128 46,684 48,256 47,815 47,585 64,776 66,727 66,589 66,03 I 20.9 20.9 20.9 20.9 0.0 0 0 0.0 0.0 1.3 0 8 0.6 0.9 100 101 102 101 Production Data Charge — Aluminum Coated Scrap (total lb) Baghouse Inlet Temp. ('F) 27,455 38,585 41.010 35,683 153 156 159 156 Emissions Data PCOD/PCDF (gdton TEO) PCDD/PCDF (1lg1Mg TEO) 1.9E-06 1.2E-06 0.13 0.1)9 1.4E-06 1.5E-06 0.10 0,11 MA CT Standard 2.1E-04 15 Tablet Emissions Testing Results Summary, Melt Area Baghouse Golden Aluminum Melt Area Baghouse Golden, Colorado July 11th 8 12th, 2006 Method 23 : Determination of Polychlorinated Di henzo-p-dioxins and Polychlorinated Dibenzofurans from Stationary Sources Table I (b) Field Data dale stars time stop lime sample volume (In sampling duration (minutes) stack temp. (`F) Meter temp. ('F) barometric pressure (mbar) barometric pressure (" Hg) Slack pressure (" H2O) moisture (9) oxygen (%vd) carbon dioxide (%vd) orifice pressure delta H C1 -12O) average (delta P)" (" H2O)" meter box Y lector (unilless) delta (unilless) pilot tube constant (unilless) nozzle diameter (inches) slack diameter (inches) 'toxic Equivalents (qr TEO per ton) 2,3.7,8-C14-Dibenzoluran (DB225)'.- 2,3,7,8-O14-Dibenzo-p-dioxin 1,2;3,7,8-C15-Dibenzoluran 2;3.4,7,8-C15-Dibenzoluran IL 1.2.3.7,8-C15-Dibenzo-p-dioxin 1.2,3,4,7,8-C16-Dibonzoluran I .2,3.6,7.8-Cle-Dbenzoluran 2.3.4,6.7.8-CIO-Dihe nzoluran 1,2.3.7.8.9-016-Dibonzoturan 1.2,3,4,7,8-016-Dibenzo'p-dioxin 1,2,3,6,7,8-CIG-Dibenzo-p-dioxin 1,2,3.7,8,9-O6-Dibenzo-p-dioxin 1,2,3,4,6,7.8-017-Dibenzoluran r 1,2,3,4.7.8,9.O17-Dibenzoluran 1,2,3,4,6,7,5-C17-Dibenzo-p-dioxin 1 ,2.3.1,6.7.8,9-CI8-Dibenzelu ran 1,2,3,4.6.7.8,9-O8-dbenzo-p-dioxin/,4.. Total = 3.61 E-07 0.00E+00 0.00E, 00 1.63E-06 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.006 r 00 3.67E-08 0.00E+00 0.00E+00 0.00E+00 1.20E-08 2.04E-06 Run 41 Run N2 Run 43 7/11/2006 7/12/2006 7/12/2006 13:00 7:40 11:45 16:05 10:44 14:52 118.041 112.480 117.036 180 180 180 133 132 135 105 00 103 848 850 849 25.04 25.10 25.07 -8.8 -8.8 -8.8 23.5 39.7 26.1 20.9 20.9 20.9 0.0 0.0 0.0 0.9 0.9 0.9 1.273 1.285 1.280 1.004 1.004 1.004 I .58 1.58 1.58 0.84 0.84 0-84 0.160 0.160 0 150 49.25 49.25 49.25 2.13E-07 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E *00 0.00E+00 194E-08 232E-07 3.35E-07 3.14E-07 0.00E+00 0.00E+00 200E+00 0.006+00 0.00E+ 00 0 00E+00 0 00E+00 0.00E+00 0.00E+00 0.00E 00 0.00E+00 0.00E , 00 0.00E+00 0.00E+00 0.00E+00 2.06E-08 Average 116.152 180 133 06 849 25.07 -5.8 29.8 20.9 0.0 0.9 1.279 .004 1.50 084 160 49.3 296E-07 0.00E+00 0.00E+00 5.42E-07 0.00E+00 0.00E+00 0.00E+00 0.006+00 200E+00 0 00E+00 0.00E+00 0.006+00 1.22E-08 0.00E+00 0.00E.00 0.00E+00 1741--08 8.67E-07 Permit Limit _< 2.1E -L1 Table II CHANGES S005 MACE Regulated GROUP I FURNACE #3 MELTER SIDEWELL 15000 lbs/hr Aluminum Charge Rate All Scrap Allowed Dross cover salt flux OK Chlorine/Argon Gas Flux_OK Do Not Expose Arch While Chlorine Fluxing Ventilate To Melt Area Baghouse Must Be <15µg D/F TEQ Exhausted Per Ton of Aluminum S004 MACT Regulated GROUP I FURNACE #2 MELTER SIDEWELL 15000 lbs/hr Aluminum Charge Rate All Scrap Allowed Dross cover salt flux OK Chlorine/Argon Gas Flux_OK Do Not Expose Arch While Chlorine Fluxing Ventilate To Melt Area Doghouse Must Be <15µg D/F TEQ Exhausted Per Ton of Aluminum S003 MACT Regulated GROUP I FURNACE #1 MELTER SIDEWELL 15000 lbs/hr Aluminum Charge Rate All Scrap Allowed Dross cover salt flux OK Chlorine/Argon Gas Flux_ OK Do Not Expose Arch While Chlorine Fluxing Ventilate To Melt Area Doghouse Must Be <15µg D/F TEQ Exhausted Per Ion of Aluminum S006 MALT Regulated Melt Area Baghouse For Melter Sidewells March 20, 2009 Colorado Regulation 3 Part C X. Mine: Permit -Modification -Procedures for Golden A!'iminum Inc. X.A.1- None X.A.2- Monitoring, reporting and recordkeeping will remain as required by the Operating Permit 96OPWEI25.. All feed/charge weights and locations are recorded as required by the Operating Permit 96OPWE125. X.A.3- Our proposed modification does not change or alter the conditions of this section. X.A.4- Our proposed modification does not seek to establish or change a permit term or condition as stated in this section to include; X.A.4.a. Federally enforceable emissions cap. X.A.4.b. An alternative emissions limit. X.A.5. Our proposed modification is not a new source, nor has it been shut down or inactive for emission elimination reasons. It is not exempted from the definition of modification as stated in Part A. Section I.B.27. X.A.6.- Our proposed modification is considered a minor permit modification following conversation with our permit engineer. X.B.- No state approved incentives, approaches or implemented plans are used or applied for. X.C. State forms are unavailable. X.D.1- Our three sidewells: S003, S004, S005 are class I furnaces. The sidewells of S004 and S005 are MACT compliant; capable of receiving coated material as charge. The sidewell of S003 is currently only capable of receiving clean charge material with reactive flux. Modification Description Sidewell S003 will be modified to meet 40 CFR PART 63, SUBPART RRR pertaining to dioxin and furan emissions and associated operating, monitoring, reporting and recordkeeping requirements for affected sources listed in §16.1500 (c), located at a secondary aluminum facility that is an area source of HAPs. Emissions - Melt Area Baghouse S006 provides control for dioxin/furan emissions. Our three sidewells S003, S004, S005 are ducted to this control point source. S006 has successfully passed performance tests with S005 sidewell as the charge source in June 2003 and S004 sidewell as the charge source in July 2006. Within the 90 -day period allowed, Golden Aluminum will schedule testing in accordance with EPA Method 23 for dioxin furan with S003 as the charge source. With all three sidewells MACT compliant, Golden Aluminum Golden Aluminum Inc. Rev. 3-20-2009 requests the flexibility of charging coated material to sidewells simultaneously at the charge rate determined by the performance test. Operating Requirements §63.1506- The owner or operator must operate all new and existing affected sources and control equipment according to the requirements of §63.1506(a)(1). The operating, maintenance and monitoring plan (OM&M) will be broadened to incorporate S003 sidewell as a coated charge capable sidewell. Labeling- The existing labels will be changed to identify the MACT criteria and capabilities for all sidewells (see table II). Capture / Collection System -Emission capture/collection will be designed and installed for S003 sidewell to meet the engineering standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists in chapter 3 and 5 of "Industrial Ventilation: A Manual of Recommended Practice" §63.1506(c)(1). The vent captured emissions to a fabric filter §63.1506(c)(2) criteria is met by the existing ductwork and baghouse S006. The OM&M plan contains the proper instructions for system use. Emission capture/collection will be designed and installed for S004 sidewell to meet the engineering standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists in chapter 3 and 5 of "Industrial Ventilation: A Manual of Recommended Practice" §63.1506(c)(1). Feed / Charge Weight- The charge weight measurement procedure, as stated in the OM&M plan has been written to monitor —Total Coated Material Weight. Group 1 Furnace With Add —on Air Pollution Control Device -Edit of the existing language to allow for the use of S003, S004 and S005 as the MACT regulated sidewells. Corrective Action- Edit of the existing language by replacing CCDS with "melter sidewell". Monitoring Requirements §63.1510- The owner or operator of a new or existing affected source or emission unit must monitor all control equipment and processes according to the requirements in §63.1510(a). The OM&M plan will be edited to extend the MACT monitoring requirements to all melter sidewells. Labeling- Label monitoring (inspections) will remain unchanged. Capture and Collection System- Operation, maintenance and inspection records will remain in place. Language changes will be made to reflect the ability to charge coated material to any melter sidewell. Feed/Charge Weight- No changes to the existing calibration, operation and maintenance plan for the scale used for weight measurements of charge material. Feed/charge total weight must be recorded to the affected source or emission unit over the same operating cycle or time period used in the performance test as set forth Golden Aluminum Inc. Rev. 3-20-2009 in §63.1510(e). The feed charge is measured and recorded on an emission unit -by - emission unit basis. Sidewell Group 1 Furnace with Add --on Air Pollution Control Device- No change -in- __ the recording of each charge of a sidewell that the molten metal was above the top of the passage between the sidewell and the main hearth during reactive flux injection §63.1510(n)(1). X.D.3-Certification by a responsible official is enclosed. X.D.4- N/A X.D.5.a&b- Melt Area Baghouse S006 is the control point source for D/F for all melter sidewells. The performance test result data supplied; Tables I (a),(b), is representative of the performance expected for the proposed MACT configured S003. This data was originally submitted Aug.I3 2003 for S005 sidewell and Aug 23 2006 for S004 sidewell. At all tested rates, the D/F emissions were below 2.1 E-4 gr of D/F per ton charged as required in §63.1505(i)(3). X.D.5.c&d-Our facility operates in an area designated as non -attainment for ozone. Golden Aluminum Inc. Rev. 3-20-2009 START UP PROCEDURE MELTER SIDEWELL AND MELT AREA BAGHOUSE Melt Area Baghouse Start Up Start Melt Area Baghouse prior to charging scrap into sidewells. To Start: Start I.D. Fan, Amber light will stay lit. Depress "System On" button, Amber light will stay lit. Leave all other System controls in Automatic. IE: Screw Conveyors, Compartment Bag Cleaning, etc. Melter Sidewell Startup When main bath molten metal temperature is above 1300 °F and the molten metal level is above the archway, scrap charging to the attached sidewell may proceed. Metter Sidewell and Melt Area Baghouse ready to process aluminum scrap. SHUT DOWN PROCEDURE MELTER SIDEWELL AND MELT AREA BAGHOUSE Melter Sidewell Shutdown If the melter Main Hearth Burners are extinguished, then the melter and attached sidewell are shut down. Melt Area Baghouse Shutdown LEAVE MELT AREA BAGHOUSE SYSTEMS AND I.D. FAN ON IF SIDEWELL IS MELTING COATED SCRAP OR CHLORINE/ARGON FLUXING! If no Sidewell charging or fluxing occurs in any furnace, then the Melt Area Baghouse maybe shut down. I. Depress "System Off' pushbutton. Amber light should extinguish. 2. Depress "I.D. Fan Stop" pushbutton. Amber light should extinguish. 3/24/2009 MELT AREA BAGHQUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 1 of 6 Definitions of acronyms as used in this plan: CAAA = Clean Air Act Amendments CE = Control Equipment CFR = Code of Federal Regulations D/F= dioxin/Furan EPA=Environmental Protection Agency HAPs= Hazardous Air Pollutants PMS = Parameter Monitoring System CMMS = Computerized Maintenance Management System EU = Emission Unit (defined by MACT as a group 1 furnace or an in -line fluxer; all others are affected sources) OM&M = Operation, Maintenance, & Monitoring P.M. = Preventative Maintenance SECAL MACT = SECondary ALuminum Maximum Achievable Control Technology Floating Interval = an approximate period of time where the end point is variable; the subsequent approximate period of time begins anew at the end point of the previous time period TBD = To Be Determined (due to the early development of this OM&M Plan, items in this category are those which need to be purchased, or information is still being gathered, or will be completed in con- junction with compliance testing, etc.) Preface: Lime used to reduce the emission of HCL gases is not subject to MACT regulation, since this facility is an AREA source of HAPs. The use and monitoring of lime is subject to requirements of Title V Operating permit and is not referenced in any OM&M SSM documents. General Procedures: Only one item, the Melt Area Baghouse is needed to prevent excess emissions of D/F from the production of aluminum through the sidewells. Defining the pollution control equipment as the affected sources in this OM&M plan is consistent with the terms outlined in the Preambles of the SECAL MACT standard and Section 112 of the CAAA, and in guidance from the EPA Wcbsites. This facility is committed to making timely corrective actions in times of excursion, where the indicators are out of range. Corrective actions may involve an investigation as to the reason, evaluation of the situation, and an appropriate chronological range of actions to remedy the situation. Baghouse bag leak detector system alarms, baghouse inlet temperature system alarms are considered by the facility as excursions. An excursion does not necessarily indicate a violation of an applicable requirement. If an excursion occurs, one of three levels of action will be taken: (Level I) the control equipment causing the excursion shall be repaired in an expeditious manner, or if that cannot be accomplished in a reasonable period of time, (Level 2) the process generating the emissions shall be changed to minimize excess emissions of hazardous air pollutants, or if that cannot be accomplished in a reasonable period of time, (Level 3) commencement of a total orderly shutdown of all production processes that could cause excess hazardous air pollutant emissions. A timely or expeditious manner is the time necessary to determine the MELT AREA BAGHOUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 2 of 6 cause of the excursion and to correct it in a reasonable period of time. A reasonable period of time is eight hours plus the period of time required to change or shut down the process without jeopardizing employee safety or damaging the process or control equipment. Emission during a period of startup, shutdown, or cleaning of control equipment is not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions. Run-time conditions will be monitored by the PMS. Monitoring is not required during periods of time greater than one day when the source does not operate. PMS detected excursions or malfunctions, including the date, time, and duration, will be recorded as outlined in the SSM Plan. Excess emissions will be reported as required by 40 CFR 63.1516(b) of the SECAL MACT standard. OM&M Plan Specifics: Note: The layout convention below follows the OM&M outline sequence listed in 40 CFR 63.1510(b) (1) The following process and control device parameters are monitored to determine compliance with the applicable emission limits for the Melt Area Baghouse unit S006: (a) Baghouse leak detector alarm system — automated system to assure that the baghouse bags are in good working condition. (b) Baghouse inlet temperature alarm system — automated system to assure that the baghouse inlet temperature is within allowable parameter range. (c) Feed/charge weight of all material — Total weight The operating levels or ranges for the above parameters are established as follows: (a) Baghouse leak detector system -- TBD (50% +100% of sensitivity established) (b) Baghouse inlet temperature — 155°F plus 10 °F (c) Total feed/charge weight of all material— 15 000 lbs. per hour Note: Values will be revised to reflect actual parameters established during performance test. (2) The monitoring schedule for each affected source (process or control device) and emission unit is as follows: (a) Baghouse leak detector system —Automated system data logging and alarming, check daily. (b) Baghouse inlet temperature - Automated system data logging and alarming, records 15 minute block averages and average temperature for each 3 -hour block period, check daily. (c)Total feed/charge weight of all material — Charge weight recorded by operators each charge cycle. MELT AREA BAGHOUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 3 of 6 (3) Procedures for the proper operation and maintenance of each process unit and add-on control device used to meet the emission limits are as follows: (a) Baghouse system — The Baghouse control device must be operational in order to process any aluminum scrap to the MELTER SIDEWELL or chlorine/argon fluxing. This is currently achieved through alarm annunciators from the control system of the Baghouse. Charging of coated scrap is prohibited unless the Baghouse system is functional. (b) Total feed/charge weight of all material — The weight of all coated aluminum processed will be recorded each shift on the daily production log. Note: The proper operation and maintenance of various monitoring devices that are attached to the baghouse are incorporated in item (4) below. (4) Procedures for the proper operation and maintenance of monitoring devices or systems used to determine compliance, including: Calibration and Certification of accuracy of each monitoring device according to the manufacturer's instructions or at least once every 6 months; and Quality Control of continuous emissions monitoring systems per subpart A general requirements are as follows, are as follows: General Operation, Maintenance, and Quality Control of Parameter Monitoring Systems: (i) This facility will endeavor to maintain and operate each PMS in a manner consistent with good air pollution practices. (ii) Every attempt will be made to repair PMS detected malfunctions as outlined in the SSM (Startup, Shutdown, and Malfunction) Plan, and reported in the semiannual startup, shutdown, and malfunction report required by the SECAL MACT standard. Any actions not consistent with the SSM Plan will be recorded and reported in the semiannual excess emissions/summary report as required by the SECAL MACT standard (records kept by the Engineering Secretary). (a) Baghouse leak detector system — The Bag Leak Detector System will be calibrated, operated, and maintained in accordance procedures outlined in Triboguard II Instruction manual, document number TA -7502, chapter 5, section 1.3 in conjunction with the its Preventative Maintenance Guide Forms (annually). The Bag Leak Detector System Preventative Maintenance (P.M.) is conducted at floating intervals of monthly and yearly. The Preventative Maintenance Guide Forms have been compiled using the appropriate manufacturer's specifications. Because bag leak detectors have not been previously required or necessary, the company has no experience with them. Since the manufacturer's specifications are subject to change, the agency will allow the company, without notification to the permitting authority, to adapt quality control improvements and upgrades to its computerized forms during the term of this permit.The guide forms are generated by the PM system (Preventative Maintenance System) and the completed work orders are recorded into and kept on file within this system accessible from the Maintenance Planning Department office. Because the SECAL MACT standard requires an annual compliance certification at the end of each year that must be kept for 5 years, these maintenance records must be kept for a total of five years. (NOTE: -50% +100% of sensitivity establishedd, also be sure to include some latitude for adjusting range, averaging period, alarm set points, alarm delay times, etc in this addendum) MELT AREA BAGHOUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 4 of 6 (b) Baghouse inlet temperature — The Baghouse Inlet Temperature System will be calibrated, operated, and maintained in accordance with its Preventative Maintenance Guide Forms (semi- annually). The Baghouse Inlet Temperature System Preventative Maintenance (P.M.) is conducted at floating intervals of monthly and yearly. The Preventative Maintenance Guide Forms have been compiled using the appropriate manufacturer's specifications. Because baghouse inlet temperature systems of this type have not been previously required or necessary, the company has little experience with them. Since the manufacturer's specifications are subject to change, the agency will allow the company, without notification to the permitting authority, to adapt quality control improvements and upgrades to its computerized fors during the term of this permit. The guide forms are generated by the PM system (Preventative Maintenance System) and the completed work orders are recorded into and kept on file within this system accessible from the Maintenance Planning Department office. Because the SECAL MACT standard requires an annual compliance certification at the end of each year that must be kept for 5 years, these maintenance records must be kept for a total of five years. (c) Total feed/charge weight of all material — The MELTER SIDEWELL Fccd/Chargc Wcight system will be calibrated, operated, and maintained in accordance with its Preventative Maintenance Guide Forms (quarterly). The MELTER SIDEWELL Feed/Charge Weight system Preventative Maintenance (P.M.) is conducted at floating intervals of monthly and yearly. The Preventative Maintenance Guide Forms have been compiled using the appropriate manufacturers specifications. Since the manufacturers' specifications are subject to change, the agency will allow the company, without notification to the permitting authority, to adapt quality control improvements and upgrades to its computerized forms during the term of this permit. The guide forms are generated by the PM system (Preventative Maintenance System) and the completed work orders are recorded into and kept on file within this system accessible from the Maintenance Planning Department office. Because the SECAL MACT standard requires an annual compliance certification at the end of each year that must be kept for 5 years, these maintenance records must be kept for a total of six years. MELT AREA BAGHOUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 5 of 6 (5) Procedures for monitorin&process and control device parameters [including annual inspection of Hot Gas Generator, if applicable, and procedure used to determine charge (or throughput) weight if a measurement device is not used] are as follows: (a) Control device parameter monitoring is done by automation. Should the monitoring system detect a malfunction, it automatically sends an alarm signal to plant operations personnel who will respond and initiate corrective action as outlined in this SSM Plan. (b) Additionally, preventative maintenance procedures are performed that monitor control device parameters as outlined and incorporated in item (4) above. (6) Corrective actions to be taken when process or operating parameters or add-on control device parameters deviate from the specified limit or range, including: (A) Alarm Level Actions (1) Level One —Any alarms displayed on current Melt Area Baghouse control panel. Response — Investigate the source of the General Alarm and acknowledge the alarm if necessary have maintenance make repairs. Emissions are not affected. Log persistent alarms so permanent corrective action can be taken. (2) Level Two — Quit Charging Sidewells Response — Investigate the source of the Genera] Alarm and acknowledge the alarm if necessary, have maintenance make repairs. These include but are not limited to: Baghouse Leak Detector, Baghouse Inlet Temperature established by upcoming performance testing. Log all Level 2 alarms in Startup -Shutdown -Malfunction Log. Charging may resume after appropriate corrective actions have been taken, up to and including continued operations if the alarmed Unit (One or Two) of the baghouse have been isolated.. (3) Level Three — Quit Charging Sidewells Response - Investigate the source of the Baghouse Alarm and acknowledge the alarm if necessary, have maintenance make repairs. These include but are not limited to: loss of baghouse I.D. fan, or a baghouse fire. Log all level three alarms in Startup -Shutdown - Malfunction Log. Charging may resume after appropriate corrective actions have been taken. (B) Procedures to determine and record the cause of the deviation or excursion (C) The time the deviation or excursion began and ended (D) Procedures for recording the corrective action taken (E)The corrective action initiation and completion times/dates (a) When a monitored parameter malfunction alarm occurs, Operations Personnel will, as soon as practicable, initiate corrective action. Note that SECAL MACT requires initiation of corrective action within one hour of the alarm. MELT AREA BAGHOUSE OM&M PLAN Operation, Maintenance, & Monitoring Plan Secondary Aluminum MACT Standard Page 6 of 6 (b) Operations Personnel will then perform appropriate diagnostic and troubleshooting functions on the equipment to determine the cause of the malfunction, and the proper corrective action will be taken as outlined in the EU SSM Plan. (c) All monitored parameter malfunctions will be detailed and recorded (records kept by the Maintenance Planning Scheduler) on the "Startup -Shutdown -Malfunction Log", including: (i) The date of the malfunction. (ii) The time of the alarm. (iii) The time that corrective action was initiated. (iv) Cause of the malfunction. (v) Corrective action taken, including steps to minimize excess stack emissions if necessary. (vi) Date and time that the corrective action was completed. (vii) Total duration, in minutes or hours, of the malfunction. (7) (8) Maintenance Schedule for each process and control device consistent with manufacturer's instructions and recommendations (a) Baghouse leak detector alarm system — See 4(a) above. (b) Baghouse inlet temperature alarm system — See 4(b) above. (c) Total feed weight of all material — See 4(c) above. Documentation of work practices and pollution prevention measures used to achieve compliance for group I furnaces without an add-on pollution control device (a) Not Applicable — Each sidewell is a group 1 furnace with add-on pollution control devices, and chlorine/argon fluxing occurs only if the arch is not visible. The compliance procedures within this OM&M plan do not contain the inclusion of any periods of startup, shutdown, or malfunction in emission calculations To revise the EU compliance provisions within this OM&M plan prior to the end of the permit term, the owner or operator will submit a request to the applicable permitting authority containing the information required and obtain approval of the applicable permitting authority prior to implementing any revisions. Melt Area Baghouse SSM Plan Startup, Shutdown, Malfunction Plan Secondary Aluminum MACT Standard General: • Only one item, the Melt Area Baghouse is needed to prevent excess emissions of dioxin/furan (D/F) from the production of aluminum melted in MELTER SIDEWELL. The Melt Area Baghouse and the work practices of the MELTER SIDEWELL are maintained according to the OM&M (Operation, Maintenance, & Monitoring) Plan for the process of melting in the MELTER SIDEWELL. Defining the pollution control equipment as the source in this SSM plan is consistent with the terms outlined in the Preambles of the SECAL MACT (Secondary Aluminum Maximum Achievable Control Technology) standard and Section 112 of the CAAA (Clean Air Act Amendments), and in guidance from the EPA (Environmental Protection Agency) Websites. Normal Baghouse Operation — Parameters Monitored: • The Bag Leak Detector System is monitored and automatically alarmed should a broken bag be detected. This helps assure that the baghouse is preventing excess D/F stack emissions. • The Baghouse Inlet Temperature is monitored and automatically alarmed should the temperature deviate from the standard specification. This helps assure that the baghouse is preventing excess D/F stack emissions. Unless the above measurements are within normal operating ranges the MELTER SIDEWELL will not be charged with coated scrap metal. Procedures for Operating and Maintaining the Source during Normal Startup: • The control equipment for the MELTER SIDE WELL will be started before any production takes place that causes excess D/F emissions. See attached "Start Up Procedure MELTER SIDEWELL and MELT AREA BAGHOUSE" document. • Operations Personnel will assure that none of the monitored parameter alarms are present before starting up any production that causes excess D/F emissions. This is additionally accomplished through automatic annunciation from controls to alert operations that charging of coated scrap is prohibited until the monitored parameter alarms are within their set points. • All control equipment startups, normal or otherwise, including the date, time, and duration, will be recorded on the "Startup -Shutdown -Malfunction Log". Procedures for Operating and Maintaining the Source during Normal Shutdown: • Operations will not charge MELTER SIDEWELL immediately before or after the control equipment is shut down. Sec attached "Start Up Procedure MELTER S1DEWELL and MELT AREA BAGHOUSE" document. Golden Aluminum Inc. Rev. 3-20-2009 Melt Area Baghouse SSM Plan Startup, Shutdown, Malfunction Plan Secondary Aluminum MACT Standard • All control equipment shutdowns, normal or otherwise, including the date, time, and duration, will be recorded on the "Startup -Shutdown -Malfunction Log" Malfunctions: • The following malfunction events are covered in this plan: • Component failures of parameter monitoring systems that cause a PMS alarm . • Catastrophic events (fire, lightening, weather, and other acts of God). • Loss of utilities (power, gas, water, etc. as applicable). • Sudden & unavoidable equipment failure (broken fan shaft, numerous simultaneous bag breaks, etc.). • Other malfunctions (Animal/human/alien trespass, riot, war, other explainable/unexplainable events). Any excess D/F emission caused by a listed malfunction will result in one or more monitored parameter malfunction annunciated alarms. Follow the procedures and corrective action program outlined below. Procedures for Operating and Maintaining the Source during Malfunctions: • All monitored parameter malfunctions will be corrected as soon as practicable after their occurrence in order to minimize excess D/F stack emissions. Note that SECAL MACT requires initiation of corrective action within one hour of the alarm. • Depending on the severity of the malfunction, the actions taken may involve, after diagnosing and troubleshooting, a chronological range of activities from: • First Level response - merely repairing the malfunction in a timely manner, or if that cannot be accomplished after a reasonable amount of time, to ty • Second Level response - changing the production process to minimize excess D/F stack emissions, or if that cannot be accomplished in a reasonable amount of time, to • Third Level response - a total orderly shutdown of all production processes that cause excess D/F stack emissions. • All monitored parameter malfunctions, including the date, time, and duration, will be detailed and recorded on the "Startup -Shutdown -Malfunction Log". Corrective Action Program for Malfunctioning Equipment: • When a malfunction occurs, Operations Personnel will, as soon as practicable, initiate corrective action. Note that SECAL MACT requires initiation of corrective action within one hour of the alarm. Golden Aluminum Inc. Rev. 3-20-2009 Melt Area Baghouse SSM Plan Startup, Shutdown, Malfunction Plan Secondary Aluminum MACT Standard • Operations and or Maintenance Personnel will then perform appropriate diagnostic and troubleshooting_functions_ on the equipment to determine the cause of the malfunction. • Operations and or Maintenance Personnel will then repair the malfunction in a timely manner, or if that cannot be accomplished after a reasonable amount of time, they will • Change the production process to minimize excess D/F stack emissions, or if that cannot be accomplished in a reasonable amount of time, • Begin a total orderly shutdown of all production processes that cause excess D/F stack emissions. Identification of all routine or otherwise predictable PMS (Parameter Monitoring System) malfunctions: • Per 40 CFR 63.1510(f)(1)(ii) of the SECAL MACT, each Triboelectric Bag Leak Detection system will be installed, operated, calibrated, and maintained in a manner consistent with the appropriate manufacturers written specifications and recommendations. • Because the manufacturers specifications are subject to change and because bag leak detectors have not been previously required or necessary, the company has no experience with them and thus no knowledge of what constitutes routine and otherwise predictable PMS malfunctions. • To satisfy the 40 CFR 63.1516(a) and subsequent 40 CFR 63.8(c)(1)(i) and 40 CFR 63.6(e)(3)(i) requirements, the company will endeavor to repair all PMS malfunctions in a timely manner, track these malfunctions during the term of this permit, then develop the "routine or otherwise predictable PMS malfunction" list, including the required spare parts inventory and list, for inclusion during the next term issuance of this permit. Procedure to determine and record the cause of the malfunction, the corrective actions taken, and the time the malfunction began and ended lin accordance with 40 CFR 63.1516(a)(1)&(2)1: • The monitored parameter automatic alarms will alert Operations Personnel of a malfunction. Note that SECAL MACT requires initiation of corrective action within one hour of the alarm. • Operations Personnel will, as soon as practical, record the type of malfunction and the time of the malfunction on the "Startup -Shutdown -Malfunction Log". • Operations Personnel and or Maintenance will then perform appropriate diagnostic and troubleshooting functions on the equipment to determine the cause of the malfunction. Golden Aluminum Inc. Rev. 3-20-2009 Melt Area Baghouse SSM Plan Startup, Shutdown, Malfunction Plan Secondary Aluminum MACT Standard • If repairs can be made in a timely manner, Operations and or Maintenance Personnel will Complete same and then record the ending time of the malfunction and both the cause of the malfunction and the action taken to correct the malfunction on the "Startup -Shutdown - Malfunction Log". • If repairs cannot be made in a timely manner, Operations Personnel will record both the cause of the malfunction and the corrective action to be taken on the "Startup -Shutdown - Malfunction Log" and at the same time, will, if necessary, • Go to second level response or beyond, as outlined in the "Procedures for Operating and Maintaining the Source during Malfunctions" section of this plan, and • Record actions taken for minimizing emissions as well as the final ending time of the malfunction on the "Startup -Shutdown -Malfunction Log". Golden Aluminum Inc. Rev. 3-20-2009 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 9 No. 1, Section II.A.4) In the absence of credible evidence to the contrary, compliance with this opacity limit shall be assumed when the provisions of Condition 2.1.1 are met. 2.6 The delacquering kiln is subject to 40 CFR Part 63, Subpart RRR as set forth in Condition 12 of this permit. 2.7 This source is subject to the CAM requirements set forth in Condition 13 of this permit. 3. S003 and S004 and S005 - Melter #1 and #2 and #3 Main Hearths Parameter Permit Condition Number Limitations(As group) Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 3.1 42.46 lb/hr 34.11 tons/yr 0.53 lbs/ton Al Recordkeeping and Calculation Monthly PM10 NA 34.11 tons/yr 0.53 lbs/ton Al NOx NA 70.6 tons/yr 400 lb/MMscf CO NA 23.85 tons/yr 84 lb/MMscf VOC NA 8.05 tons/yr 0.131 lbs/ton Al Aluminum Consumption 3.2 NA 123,078 tons/yr NA Recurdkeeping Monthly Fuel Use 3.3 NA 568 MMscf/yr NA Fuel Allocation (See Appendix G) Monthly Opacity 3.4 Except as provided in Condition 3.5, below, not to exceed NA Visual Observations Weekly 3.5 During certain operating conditions, not to exceed 30% S003.S004& S005 —Coated Material Charge 3.7 See Condition 3.7 3.1 Emissions of air pollutants for grouped main hearths shall not exceed the limitations stated above (Construction Permit 82WE250-3 as modified under the provisions of Section I, Condition 1.3). Particulate Matter emissions shall not exceed the short term limitation stated above as calculated from the equation PE = 3.59(P)062 = lbs/hr, where P = Process Weight Rate in tons per hour (Regulation No. 1, Section III.C.1. Compliance with the hourly limit will be assumed by calculation. Emissions shall be calculated by the end of the subsequent month using the listed compliance emission factors (EF) in the following equations: For PM, PM10 and VOC Tons/month = Throughput (tons Al/month) x EF (lbs/ton Al) / 2000 For NOx and CO Jperating Permit Number: 96OPWE125 First Issued: 11/1/99 Proposed Renewal Permit Renewed: 7/1/05 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 10 Tons/month = Throughput (MMscf/month) x EF (Ib/MMscf) / 2000 A twelve-month rolling total for the grouped main hearths shall be maintained for demonstration of compliance with annual limitations. Each month, a new twelve month total shall be calculated using the previous twelve months data. Records of the calculations shall be maintained for Division inspection upon request. 3.2 The consumption of aluminum for the grouped hearths shall not exceed the limitation above (Construction Permit 82WE250-3 as modified under the provisions of Section I, Condition 1.3). Consumption rates shall be measured and recorded each month. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of actual consumption shall be maintained for Division inspection upon request. 3.3 The consumption of natural gas for the grouped main hearths shall not exceed the limitation above (Construction Permit 82WE250-3 as modified under the provisions of Section I, Condition 1.3). Consumption rates shall be calculated by allocation and recorded each month. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. Records of actual consumption shall he maintained for Division inspection upon request. 3.4 For the grouped main hearths: Except as provided in Condition 3.5, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section ILA of Regulation No. 1. (Construction Permit 82WE250-3, and Colorado Regulation No. 1, Section II.A.1). Compliance with the opacity requirements shall be monitored by conducting visual observation of emissions weekly, during normal operation. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 3.5 For the grouped main hearths: No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of fire boxes, soot blowing, start-up, any process modification, or adjustment or occasional cleaning of control equipment, which )perating Permit Number: 96OPWE125 First Issued: 11/1/99 Proposed Renewal Permit Renewed: 7/1/05 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 11 is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) If any of theses operating conditions persists for one hour or more, a visual observation of emissions shall be performed. If any visible emissions are observed, the source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been performed, visible emissions persist for longer than one hour, an EPA Reference Method 9 opacity observation shall be performed to determine compliance with the opacity standard. Subject to the provisions of C.R.S. 25- 7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. All observations shall be recorded and kept on site to be made available to the Division upon request. 3.6 These sources are subject to 40 CFR Part 63, Subpart RRR as set forth in Condition 12 of this permit. 3.7 The permittee may charge coated material to S003, S004 & S005 according to the following conditions. 3.7.1 The limits set forth in Section II, Conditions 3.1 through 3.6 are met. 3.7.2 Records of the following information shall be maintained and made available to the Division for inspection upon request: amount of coated material charged. 3.7.3 When coated material is charged, all sidewells are subject to 40 CFR Part 63, Subpart RRR as set forth in Condition 12 of this permit. (Note: Emissions at the Melt Area Baghouse are subject to the MACT provisions only when Metter #1,#2 and #3 sidewells are in use). 3.7.4 The permittee shall record the weight of total coated feed charge (all sidewells) to the affected source emission unit (S006) over the same operational cycle or time period used in the performance test. §63.1510(e) )perating Permit Number: 96OPWE125 First Issued: 11/1/99 Proposed Renewal Permit Renewed: 7/1/05 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 12 4. S006 - Melt Area Baghouse Parameter Pennit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 4.1 19.24 lb/hr 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) Recordkeeping, Calculation and Baghousc Maintenance Annually, Daily PM �� NA 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) Shredded and Plant Scrap Consumption 4.2 NA 68,166 tons/yr NA Recordkeeping Monthly Opacity 4.3 Except as provided in Condition 5.4, below, not to exceed 20% NA Compliance with Condition 5.1 At All Times 4.4 During certain operating conditions, not to exceed 30% CAM 4.5 See Condition 13 and Appendix H 4.1 Emissions of PM and PM10 shall not exceed the limitations stated above (Construction Permit 91WE864 as modified under the provisions of Section I, Condition 1.3). Particulate Matter emissions shall not exceed the short term limitation stated above as calculated from the equation PE = 3.59(P)°'62 = lbs/hr, where P = Process Weight Rate in tons per hour (Regulation No. 1, Section III.C.1.a). In the absence of credible evidence to the contrary, compliance with the hourly limit will be assumed if Conditions 4.1.1 and 4.1.2 below are met. Compliance with the annual emission limitations shall be assumed if the following conditions are met and the processing rates do not exceed the listed limitations (Condition 4.2). 4.1.1 Routine maintenance of the baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. These specifications shall be in written format, and shall be made available to the Division upon request. A visual observation of each stack shall be conducted daily to document any fluctuations in performance and for prioritization of preventive maintenance activities. Should visible emissions, other than steam, be observed, the source shall follow the steps in 4.1.1.1. through 4.1.1.3. and record in a log the opacity observations and any action taken as a result of the observations. Should the baghouse pressure drop be observed outside the manufacturer=s recommendations, the source shall follow the steps in 4.1.1.1, 4.1.1.4., and 4.1.1.5., within one hour of the pressure drop observation. 4.1.1.1 properly. Verify that the process and control equipment are operating /perating Permit Number: 96OPWE125 First Issued: 11/1/99 Proposed Renewal Permit Renewed: 7/1/05 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 13 4.1.1.2 Perform any maintenance or adjustments needed to minimize visible emissions and ensure that the process and control equipment are operating properly. 4.1.1.3 If visible emissions continue to occur, EPA Reference Method 9 observations shall be conducted to demonstrate compliance with the twenty percent (20%) opacity standard. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, exceedance of the limit shall be considered to exist from the time a Method 9 reading is taken that shows an exceedance of the opacity limit until a Method 9 reading is taken that shows the opacity is less than the opacity limit. 4.1.1.4 Perform any maintenance or adjustments needed on the baghouse. 4.1.1.5 If the baghouse pressure drop remains outside of manufacturer's specifications, the baghouse shall be inspected for bag integrity and overall mechanical efficiency. Necessary repairs shall be made prior to bringing the equipment back on line. Any action taken as a result of baghouse pressure drop shall be recorded in a daily log, for Division inspection upon request. 4.1.2 The haghouses shall be inspected for bag integrity and overall mechanical efficiency annually. Powdered dye tests shall be performed as necessary to identify faulty bags. Necessary repairs shall be made prior to bringing the equipment back on line. An adequate inventory of replacement bags and parts shall be maintained on site. 4.1.3 The emission factors listed shall be used to calculate emissions annually. 4.2 The consumption of shredded and plant scrap shall not exceed the limitation above (Construction Permit 91WE864 as modified under the provisions of Section I, Condition 1.3). Consumption rates shall be measured and recorded each month, and maintained for Division inspection upon request. A twelve month rolling total shall be maintained for demonstration of compliance with the annual limitations. Each month a new twelve month total shall be calculated using the previous twelve months data. 4.3 Except as provided in Condition 4.4, below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement on which these standard are based is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Regulation No. 1. (Construction Permit 91WE864, and Colorado Regulation No. 1, Section II.A.1). In the absence of credible evidence to the contrary, compliance with this opacity limit shall be assumed when the provisions of Condition 4.1.1 are met. 4.4 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any air pollutant resulting from the building of a new fire, cleaning of lire boxes, soot blowing, start-up, any process iperating Permit Number: 96OPWE 125 First Issued: 11/1/99 Proposed Renewal Permit Renewed: 7/1/05 Air Pollution Control Division Colorado Operating Permit Permit ti 96OPWE125 Golden Aluminum, Inc. Page 14 modification, or adjustment or occasional cleaning of control equipment, which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Colorado Regulation No. 1, Section II.A.4) In the absence of credible evidence to the contrary, compliance with this opacity limit shall be assumed when the provisions of Condition 4.1.1 are met. 4.5 This source is subject to the CAM requirements set forth in Condition 11. Note: See Condition 3.7 regarding MACT provisions. 5. S008 - Hot Mill w/ Air Purifier Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 5.1 18.03 lb/hr 3.9 tons/yr 0.0929 lb/ton Al pressed Recordkeeping, Calculation and Purifier Maintenance Annually, Daily PM10 NA 3.9 tons/yr 0.0929 lb/ton Al pressed Aluminum Pressed 5.2 NA 84,722 tons/yr NA Recordkeeping Monthly Opacity 5.3 Except as provided in Condition 7.4, below, not to exceed 20% NA Compliance with Condition 5.1 At All Times 5.4 During certain operating conditions, not to exceed 30% 5.1 Emissions of air pollutants shall not exceed the limitations stated above (Construction Permit 82WE250- 6 as modified under the provisions of Section I, Condition 1.3). Particulate Matter emissions shall not exceed the short term limitation stated above as calculated from the equation PE = 3.59(P)°62 = lbs/hr, where P = Process Weight Rate in tons per hour (Regulation No. 1, Section ITI.C.I.a). Compliance with the hourly limit 1perating Permit Number: 96OPWE125 Proposed Renewal Permit First Issued: 11/1/99 Renewed: 7/1/05 Air Pollution Control Division Construction Permit Application PLEASE READ INSTRUCTIONS ON REVERSE SIDE. 1. Permit to be issued to: Golden Aluminum Inc. 2. Mailing Address: 1405 East I4`° Street Fort Lupton Colorado 80621 3. General Nature of Business: Aluminum sheet manufacturing SIC code (if known) 3353 4. Air Pollution Source Description: 96OPWE125 (List permit numbers if existing source, attach additional pages if needed) Is this a Portable Unit? No 5. Source Location Address (Include Location Map) If portable, include the initial location and home base location Latitude 40 deg, 05min., 45 sec.; Longitude 104 deg, 48 min., 09 sec. 6. Reason for Application: (Check all that apply) ❑ New or Previously Unreported Source Administrative Permit Amendments 1 Modification of Existing Source ❑ Transfer of Ownership (Complete Section 9 & 10 below) ❑ Request for Synthetic Minor Permit ❑ Company Name Change (Complete Section 9 below) ❑ Other: N/A ❑ Other: N/A 7. Projected Startup Date: 4/8/2009 %„,„.•---C_-- 3/a 3-1O7 Signature of Legally Authorized Person of Company listed in Section 1 Date Signed Mark Selepack V.P. of Operations Phone: 303-654-8384 Type or Print Name and Official Title of Person Signing Above Fax: 303-654-8360 8. Check appropriate box if you want: ❑ Copy of preliminary analysis conducted by Division ❑ To review a draft of the permit prior to issuance These sections are to be completed only if a company name change or transfer of ownership has occurred. 9. Permit previously issued to: N/A 10. Transfer of Ownership Information Effective Date of Permit Transfer: N/A As responsible party for the emission source(s) listed above, I certify that the business associated with this source has been sold, and agree to transfer the permit to said party. N/A N/A Signature of Legally Authorized Person of Company listed in Section 9 Date Signed N/A Phone: N/A Type or Print Name and Official Title of Person Signing Above Fax: N/A Mail completed application, APENs, and filing fee to: Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-BI Denver, Colorado 80246-1 53 0 http://www.cdphe.state.co.us/ap/stationary.asp Phone: (303) 692-3150 Revised August 2004 INSTRUCTIONS FOR THE COMPLETION OF THE APPLICATION FOR CONSTRUCTION PERMIT OR PERMIT MODIFICATION FORM The following instructions for the completion of this form are titled, lettered, and numbered the same as the applicable sections of the form on the other side. ,ction does not apply, write "N/A": DO NOT LEAVE BLANK. NOTE: All information submitted as part of this permit application and all data generated by the Division as part of processing this permit will be considered open to the public unless confidential treatment is requested in writing. All such materials MUST be (1) clearly marked "CONFIDENTIAL" and (2) enclosed in a separate sealed envelope marked "CONFIDENTIAI. INFORMATION" to ensure against accidental release. Confidentiality is granted only if the release of such information would result in economic disadvantage to the applicant. If confidentiality is requested, the Division will notify you of its decision and, if denied, allow time for you to present additional evidence justifying the need for confidentiality. In general, confidentiality requests will increase permit processing time. Under no circumstances can emissions data be held confidentia 1. PERMIT ISSUED TO: List the name of the company (e.g., corporation, partnership, association, individual owner, or governmental agency) to whom the permit is to be issued and who will therefore be responsible for the operation of the source. This company name will be listed on the permit. 2. MAILING ADDRESS: This is the address for all correspondence relating to this permit. 3. GENERAL NATURE OF BUSINESS: List the business activity (dry cleaner, saw mill, furniture manufacturer, commercial printing, etc.). Also, list the Standard Industrial Classification (S.I.C.) for this type of business activity, if known. 4. AIR POLLUTION SOURCE DESCRIPTION: Provide a brief description of the equipment being permitted and the associated emission controls (e.g., concrete batch plant with baghouses, paint booth with particulate filters). If this source has an existing APCD permit(s), please list all applicable permit numbers. 5. SOURCE ADDRESS: Do not give a P.O. Box. This is for the physical location of the source. Please include a map that indicates the exact location and shows major topographic features. If the source is portable, include the home base and initial location. 6. REASON FOR APPLICATION: Modification of Permitted Source — A permit modification may be required for changes in emissions, throughput, equipment, etc. Request for Synthetic Minor —A source that is voluntarily applying for a permit to create federally enforceable permit conditions to limit the potential to emit criteria or hazardous air pollutants in order to avoid other requirements. Public comment must be conducted prior to the issuance of any synthetic minor emission permit. Administrative Permit Amendments Transfer of Ownership — A transfer of ownership is required if equipment previously permitted by another company has been purchased. A merger is considered to be a transfer ofownership. Complete sections 9 & 10 of this form. Name Change — A name change is appropriate if only the name on the permit is to be changed, and there is no transfer of ownership. Complete section 9 of thi: form. Other— Any other administrative change as defined in Regulation No. 3, Part A, Section LB.I. 7. PROJECTED START-UP DATE: Construction, operation, or modifications prior to receipt of a permit is prohibited by Colorado Statute. S. DRAFT REVIEW REQUEST: Review requests will usually add to both processing costs and processing time. Any additional time and charges incurred by the Division in providing a draft and correspondence with the applicant will be billed to the applicant. The Division will consider the request an official extension of the processing deadlines specified by the Act. The extension will consist of the number of days elapsed between Division mailing of the draft permit to the applicant an receipt of the applicant's comments by the Division, not to exceed 15 days. However, the Division is not bound to consider any comments received after the 15 day time period lapses, unless both the Division and the applicant agree to a further extension of the processing deadlines. 9. PERMIT PREVIOUSLY ISSUED TO: list the name of the company on the most recently issued permit. This section should be completed only if a company name change or transfer of ownership has occurred. 10. TRANSFER OF OWN ERSHP: This section should be completed by the former owner of the permit. Transfer of the permit(s) conveys to the new owner all responsibility, coverage and liability associated with the permit(s). Submission of a transfer of ownership application without a request for permit modification implies that no change is contemplated which would constitute a new or modified air pollution source. A written agreement containing a specific date for transfer a ownership permit will be accepted in lieu of completion of this section of this form. Submit completed application, APENs, and filing fee to the address below: APENS: More than one Air Pollutant Emission Notice (APEN) may be needed with this application. Only one application form needs to be completed. Multiple sources - An APEN is required for each source unless they may be grouped as specified in Regulation No. 3, Part A, Section 11.11.4. 'transfer of Ownership - An APEN must be submitted for each individual emission source to be transferred. Name Change - If a company is changing its name only, and all other procedures and information as stated in the last submitted ADEN remains unchanged, then on. one APEN for each facility is required. (—Filing Fee: Permittee must submit 5119.96 per APEN with the application.) Permit Processing Fee: Pemtittee will be invoiced a $59:9$ per hour based on the amount of time spent reviewing the application and issuing the permit Invoices for APEN fees and permit processing fees must be paid before permit will be issued. Once an application is received, all processing time will be charged regardless of whether a permit is issued or not. If a project is cancelled, the division should be notified in writing immediately. Annual Fees: Annual fees will be billed for each source requiring an APEN to cover the costs of periodic inspections and administration- Annual fees are based on the quantity and type of pollutants emitted. For specific information related to fees see Regulation No. 3, Part A, Section VI. Mail completed application, APENs, and filing fee to: Colorado Department of Public Health and Environment Air Pollution Control Division 4300 Cherry Creek Drive South, APCD-SS-I31 Denver, Colorado 80246-1530 http://www.edphe.slate.co.us/ap/stationaryasp Phone: (303) 692-3150 Revised August 2004 Hello