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Home My WebLink About20171379.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 May 9, 2017 Dear Sir or Madam: RECEIVED MAY 1 2 2017 WELD COUNTY COMMISSIONERS On May 11, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for Golden Aluminum, Inc. - Golden Aluminum, Inc.. 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 beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickentooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Offir Pu1O1;c, R,i wi c5/17/1 -, ec= PL Cmm/TP)HLCFel, PLO CERtCH f crc I Jm) 5115/17 2017-1379 Air Pollution Control Division Notice Of A Proposed Renewal Title V Operating Permit Warranting Public Comment Website Title: Golden Aluminum, Inc. - Golden Aluminum, Inc. - Weld County Notice Period Begins: May 11, 2017 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 East 14th Street Fort Lupton, CO 80621 Facility: Golden Aluminum, Inc. 1405 East 14th Street Fort Lupton, CO 80621 Golden Aluminum, Inc. has applied to renew the Operating Permit for the Golden Aluminum, Inc. in Weld County, CO. The facility performs secondary aluminum processing, turning scrap aluminum into aluminum coils. There were no modifications made to the facility during this issuance of the permit; relevant State and Federal requirements were updated, as appropriate. There was some restructuring of emissions during this issuance; the Source took reductions to a couple of processes to limit the VOC and NOx emissions. Additionally, the Source is now required to track insignificant activity emissions. A copy of the application, including supplemental information, the Division's analysis, and a draft of the Renewal Operating Permit 96OPWE125 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air- permit-public-notices. The Division has made a preliminary determination of approval of the application. Based on the information submitted by the applicant, the Division has prepared the draft renewal operating permit for approval. Any interested person may contact Nicholas Dummer of the Division at 303-692-3125 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) to receive comments regarding the concerns listed above as welt as the sufficiency of the preliminary analysis and whether the Division should approve or deny the permit application. If requested, the hearing will be held before the Commission 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. Ay,r'�., C O L a AD 1 Ji33�, 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: 123-0089 RENEWED: DRAFT EXPIRATION DATE: DRAFT 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: PLANT SITE LOCATION: Golden Aluminum, Inc. 1405 East 14th Street 1405 East 14th Street Fort Lupton, CO 80621 Fort Lupton, CO 80621 INFORMATION RELIED UPON Operating Permit Renewal Application Received: And Additional Information Received: April 29, 2014 March 30, 2016, August 15, 2016 Nature of Business: Aluminum Sheet Manufacturing Primary SIC: 3353 RESPONSIBLE OFFICIAL Name: Chris Moellers Title: Chief Technical Officer FACILITY CONTACT PERSON Name: Don Forchette Title: Environmental Engineer Phone: (303) 654-8373 Phone: (303) 654-8366 SUBMITTAL DEADLINES — Semi -Annual Monitoring Periods: May 1 - October 31, November 1 - April 30 Semi -Annual Monitoring Report: Due on December 1, 2010 & June 1 2011 and subsequent years First Annual Compliance Period: May — October 31 Subsequent Annual Compliance Periods: November 1 to October 31 Annual Compliance Certification: Due on December 1, 2010 and subsequent years Note that the Semi -Annual Monitoring Reports and Annual Compliance report 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 1 1. Permitted Activities 1 2. Alternative Operating Scenarios 2 3. Nonattainment Area New Source Review (NANSR) and Prevention of Significant Deterioration (PSD) 2 4. Accidental Release Prevention Program (112(r)) 3 5. Compliance Assurance Monitoring (CAM) 3 6. Summary of Emission Units 4 SECTION II - Specific Permit Terms 5 1. S001 - Prebreakers, Shredders, and Particle Separator Drop Out Box with Baghouse 5 2. S002 - Delacquering Kiln with 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 (Sidewells on Melters S003, S004, & S005, and Degassing Units (also known as in -line fluxers / demagging units)) 17 5. S008 - Hot Mill with Air Purifier 21 6. S009 - Two Annealing Furnaces 24 7. S010 - Cold Mill w/ Air Purifier 28 8. 5011 - Coil Coating Line with Thermal Oxidizer 31 9. S012 — Compression Ignition Emergency Engine — Make: Detroit Diesel; Model: 16V -179T; Serial: 16E4255; 1310 horsepower, turbocharged 41 10. Facility Wide HAP Emission Limits 50 11. 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production 51 12. Gasoline Tank: 297 Gallons 71 13. Insignificant Activity Tracking 73 14. Compliance Assurance Monitoring 74 SECTION III - Permit Shield 79 1. Specific Non -Applicable Requirements 79 2. General Conditions 79 3. Stream -lined Conditions 79 SECTION IV - General Permit Conditions (ver 5/22/2012) 81 1. Administrative Changes 81 2. Certification Requirements 81 3. Common Provisions 81 4. Compliance Requirements 85 5. Emergency Provisions 86 6. Emission Controls for Asbestos 86 7. Emissions Trading, Marketable Permits, Economic Incentives 86 8. Fee Payment 86 9. Fugitive Particulate Emissions 87 10. Inspection and Entry 87 11. Minor Permit Modifications 87 12. New Source Review 87 13. No Property Rights Conveyed 87 14. Odor 87 TABLE OF CONTENTS: 15. Off -Permit Changes to the Source 88 16. Opacity 88 17. Open Burning 88 18. Ozone Depleting Compounds 88 19. Permit Expiration and Renewal 88 20. Portable Sources 88 21. Prompt Deviation Reporting 88 22. Record Keeping and Reporting Requirements 89 23. Reopenings for Cause 90 24. Section 502(b)(10) Changes 90 25. Severability Clause 91 26. Significant Permit Modifications 91 27. Special Provisions Concerning the Acid Rain Program 91 28. Transfer or Assignment of Ownership 91 29. Volatile Organic Compounds 91 30. Wood Stoves and Wood burning Appliances 92 APPENDIX A - Inspection Information 94 1. Directions to Plant: 94 2. Safety Equipment Required: 94 3. Facility Plot Plan: 94 4. List of Insignificant Activities. 94 APPENDIX B — Reporting Requirements and Definitions 97 APPENDIX C — Required Format for Annual Compliance Certification Reports 106 APPENDIX D — Notification Addresses 110 APPENDIX E — Permit Acronyms 111 APPENDIX F — Permit Modifications 113 APPENDIX G — Fuel Allocation 114 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 Golden Aluminum, Inc. (the Source) is an aluminum sheet manufacturing plant: Standard Industrial Classification 3353. The Source manufactures coiled aluminum sheet by recycling rigid can stock (RCS) using prime aluminum and other alloying materials. The process flow follows: The RCS is shredded to expose the coating; the shredders have a baghouse for particulate matter (PM) emission control. The shredded aluminum is sent to a delacquering kiln to remove coating; emissions from the kiln are controlled with a thermal oxidizer and a lime -injected baghouse to remove PM, volatile organic compounds (VOC), and hazardous air pollutants (HAP) — a HAP of specific concern is hydrochloric acid (HCl). The shreds are melted in two of three furnaces with prime aluminum and alloying elements; plant scrap is melted in any of the three furnaces, and coated charge may be melted in the furnace sidewells with some limitations. Dross is removed from the furnaces and pressed into crucibles for cooling prior to shipment to another facility for processing. The molten aluminum goes through a series of three degassing boxes where they are agitated with rotors and bubbled with argon and chlorine gas to remove impurities. The gaseous emissions from the melting furnaces and the degassing boxes are vented through a lime -injected baghouse for PM and HAP emission control. The aluminum is solidified at a proprietary caster and milled in a hot mill where it is pressed into a long, continuous sheet and then coiled; PM from the hot mill is controlled with a centrifugal separator. The coils are loaded onto large carts and put into an annealing furnace which changes the molecular structure and tensile strength to specifications. The coils are removed from the annealing furnace and decoiled and milled to thickness specifications in a cold mill; the aluminum is sprayed with an atomized, mineral oil coolant in the mill, and the overspray is vented to a purifier for VOC emissions control. The aluminum sheet is pulled through a tension leveler which removes imperfections caused by the milling process. It is then washed with potassium hydroxide (KOH) and/or sodium hydroxide (NaOH) (wastewater from the process is treated on site to permitted levels before drainage to a municipal treatment facility or shipping of hazardous materials as required) and re -coiled, packaged, and shipped. Coils from the tension leveler may also be sent to the coating line to be washed and to add a coat to customer specifications; VOC emissions from the coating line are controlled with a thermal oxidizer. The coated aluminum is cured in a multiple -oven process. After the wash line the aluminum is lubricated (if applicable), re -coiled, packaged and shipped. Per customer specifications, the aluminum may be cut into thinner strips prior to packaging and shipping. The facility has an emergency generator for lighting and air compressors. 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 the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1.There are no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 2 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 The 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 Colorado 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 Colorado Regulation No. 3, Part C shall become new applicable requirements for purposes of this Operating Permit and shall survive reissuance. This permit incorporates the applicable requirements (except as noted in Section II) from the following construction permits: 03WE0032 (facility wide permit issued March 21, 2003 incorporating the provisions of 82WE250-2, 3, 4, 6 thru 8, & 12, 84WE342, 90WE247, and 91WE864). 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.g (last paragraph), 14 & 18 (as noted). 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. Either electronic or hard copy records are acceptable. 2. Alternative 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 for both NANSR and PSD as of the issuance date of this permit. 3.1.1 [NANSR] Any future modification at this facility which is major by itself (i.e. a potential to emit of>100 tons per year (TPY) of either VOC or oxides of nitrogen (NOx)) may result in the application of the NANSR review requirements. 3.1.2 [PSD] Any future modification at this facility for which is major by itself (potential to emit of >250 TPY) for any pollutant listed in Colorado Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 3 3.2 There are no other Operating Permits associated with this facility for purposes of determining applicability of PSD/NANSR 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 (CAA)). 5. Compliance Assurance Monitoring (CAM) 5.1 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 in 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 14 for specific CAM requirements. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 4 6. Summary of Emission Units 6.1 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 Particle Separator Drop Box, Design Rated at 3 TPH each, Baghouse Controlled. 1990 Day Co., IG013831 Baghouse S002 002 P002 Custom Apros delacquering 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 Melter # 3 Pool, 32 IVIMBtu 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 S010 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 S012 021 N/A Emergency Engine, Make: Detroit Diesel, Model: 16V -149T, SN: 16E4255, Horsepower: 1310 1983 Uncontrolled N/A N/A N/A Gasoline Tank: 297 Gallons 1983 N/A *Note: Emissions from the melter sidewells are vented to the melt Area Baghouse (S006) Table 1 - Golden Aluminum Emission Units Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 5 SECTION II - Specific Permit Terms 1. S001 - Prebreakers, Shredders, and Particle Separator Drop Out Box with Baghouse Parameter Permit Condition Number Limitations (for all three together) Short Term Long Term Compliance Emission Factor Monitoring Method Interval Total Suspended Particulate (TSP or PM) 1.1 For each shredder: 7.09 lbs/hr 9.80 tons/yr 0.5221b/ton Al Processed Recordkeeping -and Calculation - Baghouse Maintenance Monthly - See Conditions 1.1.3 and 1.1.4 NA 9.80 tons/yr 0.5221b/ton Al Processed PMto Production Rate 1.2 NA 37,500 tons/yr NA Recordkeeping Monthly Opacity 1.3 Not to exceed 20% except as provided for in Condition 1.4 NA Visible Emission Observations Daily 1.4 During certain operating conditions, not to exceed 30% HAP 1.5 NA Facility wide: 8 tons/yr (individual) 20 tons/yr (total) 0.0014 lb HAP metals/ton See Condition 10 Table 2 - S001 Summary Table 1.1 Total suspended particulate matter (TSP or PM) and particulate matter less than 10 microns in diameter (PM1() emissions are subject to the following limitations: PM from each shredder shall not exceed the short term (lbs/hr) limits in Table 2 (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 Conditions 1.1.3 and 1.1.4 are met. Note that the short-term TSP standard was determined using the design rate for the shredders (3 tons/hour per shredder) using the following equation: PE=3.59*P0.62 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] 1.1.2 PM and PM10 emissions from all three shedders together shall not exceed the annual limitations in Table 2 (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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 6 factors in Table 2 (emission factors obtained from 10/29/02 synthetic minor (HAP) permit application — factors based on calculation) using the following equation: Tons of pollutant ton Al f lb * 1 ton = Al processed[month] * Emission factor month f Lton Al]J 2000 lb 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 baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the baghouse and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request. A visual emission observation of each stack shall be conducted daily. If visible emissions other than steam are observed, the Source shall follow the steps in Conditions 1.1.3.1 and 1.1.3.2 and record 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 Conditions 1.1.3.1 and 1.1.3.3 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 as described in Condition 1.3. 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 observer certifications and observations shall be recorded and kept on site to be made available to the Division upon request for review. 1.1.3.3 If the baghouse pressure drop remains outside of manufacturer's Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 7 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. 1.1.4 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. 1.2 The processing of recycled aluminum shall not exceed the limitation in Table 2 (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 be made available to the Division upon request for review. 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, 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 as is required by EPA Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Colorado Regulation No. 1, Section II.A. (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. 1.5 The emissions units in Condition 1 are subject to the facility -wide hazardous air pollutant (HAP) limits in Table 2. Condition 10 outlines the recordkeeping requirements associated with these limitations. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 8 2. S002 - Delacquering Kiln with Multicyclone, Thermal Oxidizer, and Lime Injected Baghouse Parameter Permit Condition Limitations Compliance Monitoring Number Short Term Long Term Emission Factor Method Interval PM PM10 NOx 2.1 CO VOC Lead 14.97 lbs/hr 1.54 tons/yr Operating: 0.08 lb/ton Al Idle: 7.6 lb/MMscf NA 1.54 tons/yr Operating: 0.08 lb/ton Al Idle: 7.6 lb/MMscf NA 4.97 tons/yr Operating: 0.24 lb/ton Al Idle: 100 lb/MMscf NA 3.33 tons/yr Operating: 0.157 lb/ton Al Idle: 84 lb/MMscf NA 2.28 tons/yr Operating: 0.12 lb/ton Al Idle: 5.5 lb/MMscf NA 0.32 tons/yr Operating: 0.0167 lb/ton Al Idle: Neg. Recordkeeping and Calculation and Control Equipment Maintenance Monthly See Conditions 2.1.3 through 2.1.5 Aluminum Throughput 2.2 NA 37,500 tons/yr NA Recordkeeping Monthly Fuel Use 2.3 NA 60.0 MMscf/yr NA Fuel meter Monthly Opacity 2.4 Not to exceed 20% except as provided for in Condition 2.5 2.5 During certain operating conditions, not to exceed 30% NA Visible Emission Observations Daily MACT RRR Requirements 2.6 5.0 µg of D/F TEQ per Mg of feed/charge See Conditions 2.6 and 11 CAM 2.7 See Conditions 2.7, 14 and Appendix H HAP 2.8 NA Facility wide: 8 tons/yr (individual) 20 tons/yr (total) 0.002 lb HAP metals/ton 0.02 lb HC1/ton See Condition 10 Table 3 - S002 Summary Table 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 in Table 3 (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 2.1.4 are met. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 9 Note that the short-term TSP standard was determined using the design rate for the delacquering kiln (10 tons Al/hr) in the following equation: PE=3.59*P0.62 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] 2.1.2 Emissions of air pollutants shall not exceed the annual limitations in Table 3 (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 emission factors in Table 3 (Operating factors: NOx, CO, VOC and Pb from 4/5/1999 revised Title V application (calculated), TSP and PMio from 10/31/03 Title V renewal application (based on stack test), idle factors from AP -42, Section 1.4 (7/1998), Tables 1.4-1 and 1.4-2) in the following equations: While kiln is delacquering: tons [tons All lb l 1 ton month — Throughput month J * Emission Factor [tons Al] * 2000 lb While kiln is idle (just burning natural gas): tons MMsc f l lb l 1 ton month Throughput (idle time only) [month] * Emission Factor [MMscf) * 2000 lb 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 and made available to the Division upon request for review. 2.1.3 Routine maintenance of the thermal oxidizer shall be conducted in accordance with manufacturer's specifications and good engineering practices. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the thermal oxidizer and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 10 2.1.4 Routine maintenance of the baghouse shall be conducted in accordance with manufacturer's specifications and good engineering practices. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the baghouse and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request for review. 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 source shall follow the steps in 2.1.4.1 and 2.1.4.3 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 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. 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 11 2.2 The throughput of aluminum shall not exceed the limitation in Table 3 (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-2), as modified under the provisions of Section I, Condition 1.3). Throughput rates shall be measured and recorded each month. 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. Records of actual throughput shall be maintained for Division inspection upon request for review. 2.3 The consumption of natural gas shall not exceed the limitation in Table 3 (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 monitored using a fuel meter and recorded each month. Monthly fuel 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. Fuel meter records shall be maintained for Division inspection upon request for review. 2.4 Except as provided for in Condition 2.5, 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 Colorado Regulation No. 1. (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 — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production as described in Condition 11. 2.7 The delacquering kiln baghouse is subject to the CAM requirements with respect to the facility wide HAP limits (Condition 10) as set forth in Condition 14 of this permit. 2.8 The emissions units in Condition 2 are subject to the facility -wide hazardous air pollutant (HAP) limits in Table 3. Condition 10 outlines the recordkeeping requirements associated with these limitations. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 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 Compliance Emission Factor Monitoring Method Interval Short Term Long Term 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 28.4 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 Melter 3.6 Not to exceed 20% except as provided for in Condition 3.7 NA Visible Emission Observations Weekly 3.7 During certain operating conditions, not to exceed 30% MACT RRR Requirements 3.8 From Sidew ells, When Proces sing Coate d Charg e: 15 µg D/F TEQ per Mg of feed/c harge See Conditions 3.8 and 11 Table 4 - S003, S004, S005 Summary Table 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 (lbs/hr) limitations in Table 4 (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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 13 each melter precludes noncompliance. A copy of the calculation shall be made available to the Division upon request for review. 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 * P0.62 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] 3.1.2 PM and PMI° emissions from all melters (main hearths) together shall not exceed the annual limitations in Table 4 (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 (main hearths) together shall be calculated by the end of the subsequent month, using emission factors in Table 4 (based on performance test data) in the following equation: tons tons Al lb l 1 ton _ month Throughput [month] * Emission Factor [tons All * 2000 lb 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 in Table 4 (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 September 9, 2016). Monthly emissions from all melters together shall be calculated by the end of the subsequent month, using the appropriate emission factor from Table 5 below in the following equation: tons MMscf lb 1 ton month Natural Gas Consumption [month] * Emission Factor [MMscf] * 2000 lb 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 for review. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 14 Oxygen Participation Level (%) NOx Emission Factor (lbs/MMscf) Emission Factor Source 0 100 AP -42, Section 1.4 (dated 7/1998), Table 1.4-1 5 to 15 230 16 to 25 250 Manufacturer 26 to 50 350 51 to 95 400 100 50 Table 5 - S003, S004, and S005 Melter NOx Emission Factors 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 in Table 4 (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 emissions factors in Table 4 (VOC emission factor based on performance test data, CO emission factor from AP -42, Section 1.4 (dated 7/1998), Table 1.4-1) in the following equation: 3.3.1 VOC emissions shall be calculated using the equation in Condition 3.3.2. 3.3.2 CO emissions shall be calculated using the following equation: tons MMscf l lb l 1 ton = month Natural Gas Consumption [month) * Emission Factor [MMscf) * 2000 lb 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 in Table 4 (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 in Table 4 (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permits 82WE250-3, 82WE250-4 and 84WE342), as modified under the provisions of Section I, Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 15 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 Colorado 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). 3.6.1 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 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. 3.6.2 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. 3.6.3 The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. 3.6.4 All observations shall be recorded and kept on site to be made available to the Division upon request for review. 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). 3.7.1 Compliance with the opacity requirements shall be monitored by conducting visual observation of emissions if any of these operating conditions persists for one hour or more. If any visible emissions are observed, the Source shall investigate equipment performance and make any adjustments necessary. If, after maintenance has been Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 16 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. 3.7.2 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. 3.7.3 The EPA Reference Method 9 opacity observations shall be performed by an observer with current and valid Method 9 certification. 3.7.4 All observations shall be recorded and kept on site to be made available to the Division upon request for review. 3.8 The furnaces in Condition 3 are subject to the requirements in 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production as described in Condition 11. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 17 4. S006 - Melt Area Baghouse (Sidewells on Melters S003, S004, & S005, and Degassing Units (also known as in -line fluxers / demagging units)) Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM 4.1 For each Melter: 19.20 lb/hr 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) Recordkeeping and Calculation Monthly See PMio NA 11.90 tons/yr 0.348 lbs/ton Al (shred and plant scrap only) and Baghouse Maintenance Conditions 4.1.3 and 4.1.4 Shredded and Plant Scrap Consumption 4.2 NA 68,166 tons/yr NA Recordkeeping Monthly Opacity 4.3 Not to exceed provided for in 20% except as Condition 4.4 NA Visible Emission Observations Daily 4.4 During certain operating not to exceed conditions, 30% CAM 4.5 See Conditions 4.5, 14 and Appendix H MACT Requirements 4 6 From Sidewells, Coated 15 µg D/F TEQ feed/charge When Processing Charge: per Mg of See Conditions 4.6 and 11 HAP 4 7 0.0009 lb HAP metals/ton 0.0865 lb HC1/ton 0.0083 lb HF/ton Facility wide: 8 tons/yr (individual) 20 tons/yr (total) See Condition 10 Table 6 - S006 Summary Table 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 in Table 6 (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: PE=3.59*P0.62 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 18 4.1.2 Emissions of PM and PM10 from all melter sidewells combined shall not exceed the limitations in Table 6 (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 [tons Al lb l 1 ton _ month Throughput month] * Emission Factor [tons Al] * 2000 lb 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. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the baghouse and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request for review. 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 and 4.1.3.3 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 19 All observations shall be recorded and kept on site to be made available to the Division upon request for review. 4.1.3.3 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 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. 4.2 The consumption of shredded and plant scrap in all three melter sidewells combined shall not exceed the limitation in Table 6 (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 for review. 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 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 Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Colorado 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 with respect to the particulate matter limits (Condition 4.1) and the facility wide HAP limits as set forth in Condition 10. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 20 4.6 The requirements in 40 CFR Part 63, Subpart RRR as set forth in Condition 11 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 11.27 through 11.31 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. 4.7 The emissions units in Condition 4 are subject to the facility -wide hazardous air pollutant (HAP) limits in Table 6. Condition 10 outlines the recordkeeping requirements associated with these limitations. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 21 5. S008 - Hot Mill with 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 PM,o 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 Not to exceed 20% except as provided for in Condition 5.4 NA Visible Emission Observations Daily 5.4 During certain operating conditions, not to exceed 30% Table 7 - S008 Summary Table 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 in Table 7 (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 * P0.62 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] 5.1.2 PM emissions shall not exceed the annual limitations in Table 7 (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 tons All lb l ton month Throughput pressed [month J * Emission Factor [tons Al*I * 2000 lb 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 22 5.1.3 Routine maintenance of the air purifier shall be conducted in accordance with manufacturer's specifications and good engineering practices. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the air purifier and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request for review. 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 for review. 5.2 The amount of aluminum pressed shall not exceed the limitation in Table 7 (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 for review. 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, 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 Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Colorado 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. monitored by conducting daily visible emission observations in accordance with the requirements in Condition 5.1.3. Page 23 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 24 6. S009 - Two Annealing Furnaces Parameter Permit Condition Number Limitations (for both Short Term together) Long Term Compliance Emission Factor (lb/ton Al) Limitations Short Term Long Term PM For each Furnace: 34.5 lbs/hr 1.38 tons/yr HM: 0.0455 Inter: 0.0205 Stab: 0.0224 PM10 NA 1.38 tons/yr HM: 0.0455 Inter: 0.0205 Stab: 0.0224 NO„ 6.1 NA 4.22 tons/yr HM: 0.0978 Inter: 0.0976 Stab: 0.0986 Recordkeeping and Calculation Monthly . 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 Not to exceed provided for 20% except as in Condition 6.5 NA Visual Observations Weekly 6.5 During certain conditions, not operating to exceed 30% Table 8 - S009 Summary Table 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 in Table 8 (Colorado Regulation No. 1, Section III.C.1.b). In the absence of credible evidence to the contrary, compliance with the PM standard for each annealing furnace 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 furnace precludes noncompliance. A copy of the calculation shall be made available to the Division upon request for review. 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*p0.16 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 25 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [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: Hot Mill Annealing tons tons Al HM lb l 1 ton month Throughput [ month ] * Emission Factor [tons Al] * 2000 lb Intermediate Annealing tons tons Al Inter lb 1 ton = Throughput f * Emission Factor month L month tons Ali*2000 lb Stabilize Annealing tons [tons Al Stab lb l 1 ton month Throughput month ] * Emission Factor [tons Ali * 2000 lb Fuel Use tons MMscf] lb l 1 ton month Natural Gas Consumption [ month J * Emission Factor [MMscf J * 2000 lb 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 for review. 6.2 The throughput of aluminum coil for both annealing furnaces together shall not exceed the limitation in Table 8 (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250-8), as modified under the provisions of Section I, Condition 1.3). Emission rates for each annealing process (hot mill, intermediate and stabilize) shall be measured and recorded each month and maintained for the Division upon request for review. Emission 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 26 limitations. Each month a new twelve-month total shall be calculated using the previous twelve- months' data. 6.3 The consumption of natural gas from both annealing furnaces together shall not exceed the limitation in Table 8 (facility wide Colorado Construction Permit 03WE0032 (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 inspection by the Division upon request for review. 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 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 Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Colorado Regulation No. 1. (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250- 8), 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 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 for review. 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 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 necessary adjustments or maintenance. 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 27 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 for review (Colorado Regulation No. 1, Section II.A.4). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 28 7. S010 - 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 Monthly See Condition 7.1.3 PM10 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 Not to exceed 20% except as provided for in Condition 7.4 NA Visible Emission Observations Daily 7.4 During certain operating conditions, not to exceed 30% Table 9 - SO10 Summary Table 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 in Table 9 (Colorado Regulation No. 1, Section III.C.1.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*P0.16 where: PE = particulate matter emission standard [lbs/hr] P = process weight rate [tons/hr] 7.1.2 Emissions of air pollutants shall not exceed the annual limitations in Table 9 (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 Table 9 (per 4/5/99 revised Title V permit application - from stack tests) in the following equations: Breakdown Milling Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. tons tons Al Brkdown Throughput [ ] _ * Emission Factor month month Intermediate Milling Page 29 lb 1 1 ton [tons Ali * 2000 lb tons [tons Al Inter lb 1 ton = Throughput * Emission Factor l month month [tons All 2000 lb Finish Milling tons tons Al Finish lb 1 ton = Throughput l * Emission Factor month month J [tons Al]Ali 2000 lb 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 and made available to the Division upon request for review. 7.1.3 Routine maintenance of the air purifier shall be conducted in accordance with manufacturer's specifications and good engineering practices. A copy of the operating and maintenance procedures, schedules for maintenance and/or inspection activities, and records related to the operation and maintenance of the air purifier and good engineering practices, such as records of routine maintenance and/or inspections shall be maintained and made available to the Division upon request for review. 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 30 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 for review. 7.2 The amount of aluminum sheet processed shall not exceed the limitation in Table 9 (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 be made available to the Division upon request for review. Monthly material production 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. 7.3 Except as provided for in Condition 7.4 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 Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Colorado 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 31 8. soil - Coil Coating Line with Thermal Oxidizer Parameter Permit Condition Number Limitations Short Term Long Term Compliance Emission Factor Monitoring Method Interval PM NA 0.86 tons/yr 7.6 lb/MMscf PM10 NA 0.86 tons/yr 7.6 lb/MMscf NO„ NA 11.28 tons/yr 100 lb/MIVIscf CO 8.1 NA 9.47 tons/yr 84 lb/MMscf Recordkeeping and Monthly VOC NA 11.00 tons/yr Fuel Burning: 5.5 lb/MMscf Coatings/Solvents: Mass Balance Calculations Coating of Aluminum Sheet 8 2 NA 1,235 2140.5 Mft2/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/1 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, 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 HAP 8.10 Calculated as for VOC emissions in Condition 8.1 Facility wide: 8 tons/yr (individual) 20 tons/yr (total) See Condition 10 Colorado Regulation No. 7 8.11 Coatings must contain less than 0.31 kg/liter of coating (2.6 lb/gallon) NA Recordkeeping and Calculations Daily Table 10 - S011 Summary Table Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 32 8.1 Emissions of air pollutants shall not exceed the limitations in Table 10 (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 7/1998), Tables 1.4-1 and 1.4-2 ) in the following equations: TSP, PM10, NOx ,CO and VOC emissions from natural gas consumption tons MMscf lb l 1 ton month Natural Gas Consumption [month] * Emission Factor [MMscf) * 2000 lb VOC emissions from coating/solvents used in the coating line (controlled by thermal oxidizer) tons _ En 1(ViDiWi) month lb * (1 — Eff) 2000 [ton] 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/ibs coating), use 1.0 for solvents Eff = Reduction efficiency of control device VOC emissions from solvents used for clean-up (not controlled by thermal oxidizer: tons 1(ViDi) month lb 2000 rton- Total VOC Emissions = Natural Gas 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 in Table 10 (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 inspection by the Division upon request for review. 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 33 8.3 The consumption of natural gas shall not exceed the limitation in Table 10 (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 and be made available to the Division upon request for review. 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 in Table 10 (facility wide Colorado Construction Permit 03WE0032 (previously individual construction permit 82WE250- 12)). Consumption rates shall be measured and recorded each month and maintained for inspection by the Division upon request for review. Monthly consumption 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. 8.5 The coil coating line (S011) 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: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 60, Subpart TT published in the Federal Register on October 17, 2000. However, if revisions to the Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised versions of 40 CFR Part 60, Subpart TT.] §60.462 Standards for Volatile Organic Compounds 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 per liter (kg VOC/l) 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 (40 CFR Part 60, §60.462(a)(2)); or 8.5.1.2 10 percent of the VOC 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 (40 CFR Part 60, §60.462(a)(2)). §60.463 Performance Test and Compliance Provisions 8.5.2 Section §60.8(d) and (f) do not apply to the performance test (40 CFR Part 60, §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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 34 for each affected facility according to the procedures in this Subpart TT (40 CFR Part 60, §60.463(b)). 8.5.4 An owner or operator shall use the procedures in 40 CFR Part 60, §60.463(c)(2) (Condition 8.5.4) for each affected facility, as defined in Subpart TT, that continuously uses a capture system and a control device that destroys VOC (e.g., incinerator) to comply with the emission limits specified under 40 CFR Part 60, §60.462(a)(2) or (3) (Condition 8.5.1) (40 CFR Part 60, § 60.463(c)(2)). For the initial performance test, the overall reduction efficiency (R) shall be determined as prescribed in 40 CFR Part 60, §60.463(c)(2)(i)(A), (B), and (C). 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 40 CFR Part 60, §60.463(c)(2)(i)(A), (B), and (C), 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 (40 CFR Part 60, §60.463(c)(2)(i)). If the overall reduction efficiency (R) is equal to or greater than 0.90 (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 atmosphere per unit volume of coating solids applied (N) shall be computed as specified in 40 CFR Part 60, §60.463(c)(2)(ii)) (40 CFR Part 60, §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 greater than 99.9%. §60.464 Monitoring of Emissions and Operations 8.5.5 If thermal incineration is used, each owner or operator subject to the provisions of Subpart TT shall install, calibrate, operate, and maintain a device that continuously records the combustion temperature of any effluent gases incinerated to achieve compliance with 40 CFR Part 60, §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 (note that the measurement may be performed in degrees Fahrenheit and converted to Celsius). 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 40 CFR Part 60, §60.462(a)(2), (3), or (4) was demonstrated during the most recent measurement of incinerator efficiency required by 40 CFR Part 60, §60.8. The records required by §60.7 shall identify each such occurrence and its duration (40 CFR Part 60, §60.464(c)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 35 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 40 CFR Part 60, §60.465, with the exception that retention of the records specified in 40 CFR Part 60, §60.465(e) shall be retained for the time period specified in Section IV, Condition 22.b and c of this permit. 8.5.7 The permittee is subject to the Test Method and Procedures requirements found in 40 CFR Part 60, §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 40 CFR Part 60, §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 (40 CFR Part 60, §60.11(d)). 8.6.3 No article, machine, equipment or process shall be used to conceal 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 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 (40 CFR Part 60, §60.12). 8.7 Except as provided for in Condition 8.8, 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 Reference Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II.A of Colorado 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 36 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 10 of this permit, provided that the thermal oxidizer is operated and maintained in accordance with the requirements in Condition 8.5. 8.10 The emissions units in Condition 8 are subject to the facility -wide hazardous air pollutant (HAP) limits in Table 10. Condition 10 outlines the recordkeeping requirements associated with these limitations. 8.11 As described in Section I, Condition 1.1, this facility is located in the 8 -Hour Ozone Control Area and is subject to the requirements of Colorado Regulation No. 7. The coil coating line (S011) is subject to the following requirements in Section IX for Surface Coating Operations. Note that there are other requirements associated with Colorado Regulation No. 7 described in Section IV, Condition 29. Section IX.D Coil Coating Operations 8.11.1 Coating applicators, ovens, and quench areas of coil coating operations involved in primer, intermediate, top -coat or single -coat operations shall not exceed the following limitation (Colorado Regulation No. 7, Section IX.D.2.): 8.11.1.1 Any coat (primer, intermediate coat, topcoat, single coat): 0.31 Kg VOC/liter of coating (2.6 lb VOC/gallon of coating) (Colorado Regulation No. 7, Section IX.D.3.). Section IX.A.3. Test Methods and Procedures 8.11.2 The owner or operator of any VOC source required to comply with Colorado Regulation No. 7, Section IX shall, at their own expense, demonstrate compliance using EPA Reference Method 24 of 40 CFR Part 60 for surface coatings, and Reference Method 25 and Reference Methods 1 through 4 for add-on controls (Colorado Regulation No. 7, Section IX.A.3.a.). 8.11.3 The test protocol should be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual and shall be submitted to the Division for review and approval at least thirty (30) days prior to testing. No test shall be conducted without prior approval from the Division (Colorado Regulation No. 7, Section IX.A.3.b.). 8.11.4 The Division may use independent tests to verify test data submitted by the Source operator or owner. The test methods shall be those listed in Colorado Regulation No. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 37 7, Section IX.A.3.a. (Condition 8.11.2) and the Division test results shall take precedence (Colorado Regulation No. 7, Section IX.A.3.c.). 8.11.5 The Division may accept, instead of the testing required in Colorado Regulation No. 7, Section IX.A.3., a certification by the manufacturer of the composition of the coatings if supported by actual batch formulation records. The owner or operator of the VOC source required to comply with these requirements shall obtain certification from the coating manufacturer(s) that the test method(s) used for determination of VOC content meet the requirements specified in Colorado Regulation No. 7, Section IX.A.3.a. (Condition 8.11.2). The owner or operator shall have this certification readily available to Division personnel, in order to allow the results to be used in the daily compliance calculations specified in Colorado Regulation No. 7, Section IX.A.10. (Condition 8.11.15) (Colorado Regulation No. 7, Section IX.A.3.d.). 8.11.6 The performance of add-on control device equipment shall be established with the required test methods of Colorado Regulation No. 7, Section IX.A.3.a. (Condition 8.11.2) at equipment startup, and after major modification to the control equipment. Baseline operating parameters shall be established during the satisfactory (i.e. in- compliance) operation of the control equipment, including operation during all anticipated ranges of process throughput. During subsequent process operation, the owner or operator shall maintain the operating conditions of the add-on controls as close to these baseline conditions as possible. If serious operational problems with an add-on control system are evidenced from the daily monitoring required by Colorado Regulation No. 7, Section IX.A.8.b. (Condition 8.11.12) (such problems may be indicated by changes from baseline conditions), repeat performance tests may be required by the Division, as necessary (Colorado Regulation No. 7, Section IX.A.3.e.). Note that a performance test of the thermal oxidizer control device was performed in July, 1996 at an average temperature of 1317°F with an average destruction efficiency of greater than 99.9%. Section IX.A.4. Sampling 8.11.7 To determine compliance with applicable surface coating standards, samples shall be taken from the coating as freshly delivered to the reservoir of the coating applicator (Colorado Regulation No. 7, Section IX.A.4.). Section IX.A.5. Alternative Compliance Methods for Processes and Operations 8.11.8 For the coil coating process specified in Colorado Regulation No. 7, Section IX.D (Condition 8.11.1), the emission limit designated shall be achieved by (Colorado Regulation No. 7, Section IX.A.5.): 8.11.8.1 Use of coatings with proportions of VOC less than or equal to the Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 38 maximums specified by Colorado Regulation No. 7, Section IX.D (Condition 8.11.1) (Colorado Regulation No. 7, Section IX.A.5.a.); or 8.11.8.2 Use of the specified equipment and procedures prescribed by Colorado Regulation No. 7, Section IX.D (Condition 8.11.1) (Colorado Regulation No. 7, Section IX.A.5.b.); or 8.11.8.3 Use of an alternative means of control which satisfies the requirements of Colorado Regulation No. 7, Section IX.A.5.e. and f. (Condition 8.11.8.4) and Colorado Regulation No. 7, Section II.D (Condition 8.11.17) (Colorado Regulation No. 7, Section IX.A.5.c.). 8.11.8.4 The Source uses an add-on control to meet the applicable emission limit and shall meet the equivalent VOC emission limit, on the basis of solids applied (4.0 lb VOC/ gallon solids applied). Appendix F in Colorado Regulation No. 7 sets for the procedure for converting emission limits and lists equivalent limits for various coating operations (Colorado Regulation No. 7, Section IX.A.5.f.). Section IX.A.7. Fugitive Emission Control 8.11.9 Control techniques and work practices shall be implemented at all times to reduce VOC emissions from fugitive sources. Control techniques and work practices include, but are not limited to (Colorado Regulation No. 7, Section IX.A.7.a.): 8.11.9.1 Tight -fitting covers for open tanks (Colorado Regulation No. 7, Section IX.A.7.a.(i)); 8.11.9.2 Covered containers for solvent wiping cloths (Colorado Regulation No. 7, Section IX.A.7.a.(ii)); 8.11.9.3 Proper disposal of dirty cleanup solvent (Colorado Regulation No. 7, Section IX.A.7.a.(iii)). 8.11.10 Emissions of organic material released during clean-up operations, disposal, and other fugitive emissions shall be included when determining total emissions, unless the source owner or operator documents that the VOCs are collected and disposed of in a manner that prevent evaporation to the atmosphere (Colorado Regulation No. 7, Section IX.A.7.b.). Section IX.A.8. Recordkeeping, Reporting, and Monitoring 8.11.11 Continuous monitoring of the exhaust gas temperature of the thermal oxidizer shall be installed, calibrated, and operated at all times that the control equipment is operating (Colorado Regulation No. 7, Section IX.A.8.a.(i)). The Division may require any other monitoring and/or recording device, maintenance and/or control -media -replacement schedule(s) on a case -by -case basis (Colorado Regulation No. 7, Section IX.A.8.a.(iv)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 39 8.11.12 If add-on control equipment is used, in addition to the requirements of Colorado Regulation No. 7, Section IX.A.8.a. (Condition 8.11.11), the following information and any other necessary information, as determined applicable for each source by the Division, shall be monitored and recorded daily to assure continuous compliance. The substitution of continuous recordings for daily recording may be allowed by the Division (Colorado Regulation No. 7, Section IX.A.8.b.). 8.11.12.1 For the capture system: fan power use, duct flow, duct pressure (Colorado Regulation No. 7, Section IX.A.8.b.(i)). 8.11.12.2 For incinerator systems (e.g. thermal oxidizer): exhaust gas temperature, flame temperature (i.e. combustion chamber temperature), accumulated time of incinerator (Colorado Regulation No. 7, Section IX.A.8.b.(iv)). 8.11.13 Recordkeeping procedures shall follow the guidance in "Recordkeeping Guidance Document for Surface Coating Operations and the Graphic Arts Industry," July 1989, EPA 340/1-88-003 (Colorado Regulation No. 7, Section IX.A.8.c.). These recordkeeping requirements include, but are not limited to: 8.11.13.1 Coating formulation and analytical data. 8.11.13.2 Coating consumption data. 8.11.13.3 Capture and control equipment performance data. 8.11.13.4 Spray applicator transfer efficiency data. 8.11.13.5 Process information. Further discussion of these requirements and example forms may be found in Chapter 3 of the EPA document: EPA 340/1-88-003. Section IX.A.9. Required and Prohibited Acts 8.11.14 No owner or operator of a source of VOCs subject to Colorado Regulation No. 7, Section IX shall operate, cause, allow or permit the operation of the source, unless (Colorado Regulation No. 7, Section IX.A.9.a.): 8.11.14.1 For coil coating operations as described in Colorado Regulation No. 7, Section IX.D (Condition 8.11.1), the owner or operator shall not cause, allow or permit the discharge into the atmosphere of any VOCs in excess of the specified emission limit, calculated as delivered to the coating applicator or as applied to the substrate, whichever is greater (Colorado Regulation No. 7, Section IX.A.9.a.(1)). Section IX.A.10 Compliance Calculation Procedures 8.11.15 Compliance with Colorado Regulation No. 7, Section IX shall be monitored on a daily basis. Sources may request a revision to the State Implementation Plan for Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 40 longer times for compliance determination (Colorado Regulation No. 7, Section IX.A.10.a.). Note that calculations for the sake of determining compliance do not need to be performed on a daily basis; calculations may be performed at the end of the month. 8.11.16 Compliance calculation procedures shall follow the guidance in "Procedure for Certifying Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings," EPA -450/3-84/019. In addition, for add-on controls or other compliance alternatives, calculation procedures shall follow the guidance of Colorado Regulation No. 7, Section IX.A.5.f. (Condition 8.11.8.4) (Colorado Regulation No. 7, Section IX.A.10.b.). An example calculation follows; for more complicated situations including water content calculations and transfer efficiency, refer to the EPA document in this Condition: Mass of VOC emitted per volume of solids: lb lb VOC gal coating _ lb VOC Density of Coating * VOC Content of Coatin f l * Solids Ratio f l gal Coating lb coating) L gal solids] gal solids Section IX.II.D Alternative Control Plans and Test Methods 8.11.17 Should the Source elect to use an alternative emission control plan, compliance method, test method or procedure other than those described in Condition 8.11, they shall be subject to the requirements in Colorado Regulation No. 7, Section II.D for Alternative Control Plans and Test Methods. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 41 9. S012 — Compression Ignition Emergency Engine — Make: Detroit Diesel; Model: 16V -179T; Serial: 16E4255; 1310 horsepower, turbocharged Parameter Permit Condition Number Limitations Monitoring Method Interval NO„ 3.9 tpy Emission Factor: 3.2 lb/MMBtu heat input Recordkeeping and CO 9.1 1.0 tpy Emission Factor: 0.85 lb/MIviBtu heat input Calculation Monthly SO2 9.2 <1.5 lb SO2/MMBtu heat input Recordkeeping Ongoing Hours of Operation 9.3 249 Hours per year Recordkeeping Monthly Opacity 9.4 Except as provided for in Condition 9.5, not to exceed 20% EPA Method 9 Annually & As Required 9.5 During certain operating conditions, not to exceed 30% MACT ZZZZ 9.6 See Condition 9.6 Recordkeeping Monthly Table 11 - S012 Emission Summary 9.1 The engine shall not exceed the NOX and CO emissions limitations in Table 11. These limits shall be based on a rolling 12 -month interval. Each month the monthly emissions shall be added to the previous 11 months' emissions and a new 12 -month rolling total shall be calculated. The following equation shall be used to calculate the monthly emissions. gal l MMBtu f lb ll 1 ton Monthly emissions = Fuel Input [month) * Fuel Heat Content [ gal ] * Emission Factor MMMBtu] * 2000 lb Note that the standard fuel heat content for diesel fuel of 0.1387 MMBtu/gal was used to calculate the emission factors and shall be used to determine compliance with the limit unless other data are available concerning the fuel heat content. 9.2 Sulfur dioxide shall not be emitted at a greater rate than the limitation in Table 11 (Colorado Regulation No. 1, Section VI.A.3.b.). Compliance with this requirement shall be assumed provided the Source only combusts ultra -low sulfur diesel as defined by the EPA (less than 15 ppm). Records shall be maintained by the Source which demonstrate the sulfur content of the fuel and shall be provided to the Division upon request. In the event that the fuel is not certified as ultra -low sulfur diesel, the Source shall be required to demonstrate compliance using the Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 42 sulfur content of the fuel as determined by supplier records or laboratory testing and calculating the emissions in the units of the standard (lb SO2/MMBtu heat input). 9.3 The engine shall not be operated for more than 249 hours per rolling 12 -month interval. The hours of operation shall be monitored using a non-resettable hour meter. Each month the hours of operation shall be added to the previous 11 months' hours and a new 12 -month rolling total shall be calculated. Note that this engine does not require an APEN until it has exceeded 63 hours per rolling -12 month total. 9.4 Except as provided in Condition 9.5, 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 (Colorado Regulation No. 1, II.A.1.). 9.4.1 An EPA Reference Method 9 opacity observation shall be performed on this engine at least once per calendar year of operation when the engine is operating during conditions suitable for properly performing a valid Method 9 observation. If an engine has not been operated or if a valid Method 9 observation could not be performed when the engine did operate during the calendar year, the Source is not required to operate the engine for the sole purpose of obtaining an annual opacity observation. If any of the Method 9 opacity observations exceed the applicable standard, additional observations must be performed. Consecutive observations shall be performed until two (2) consecutive observations are in compliance with the standard. The first additional observation and each successive observation shall be performed no later than sixty (60) minutes after the completion of the previous observation. 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 opacity 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. All Method 9 observations shall be performed by a certified observer. A clear, readable copy of the opacity observer's certification shall be kept with the records of the Method 9 observation. These records and the copy of the certification shall be made available to the Division for review upon request. 9.5 No owner or operator of a source shall allow or cause to be emitted into the atmosphere any pollutant resulting from start-up, which is in excess of 30% opacity for a period or period aggregated more than six (6) minutes in any sixty (60) consecutive minutes (Colorado Regulation No. 1, II.A.4.). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 43 9.5.1 A record shall be kept of the type, date, and time of the commencement and completion of each and every condition subject to Regulation No. 1, II.A.4. that results in an opacity exceedance. The records shall be made available to the Division upon request for review. A Method 9 observation shall be performed any time an engine start-up requires longer than ten (10) consecutive minutes. If any of the Method 9 opacity observations exceed the applicable standard, additional observations must be performed. Consecutive observations shall be performed until two (2) consecutive observations are in compliance with the standard. The first additional observation and each successive observation shall be performed no later than sixty (60) minutes after the completion of the previous observation. 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. All Method 9 observations shall be performed by a certified observer. A clear, readable copy of the opacity observer's certification shall be kept with the records of the Method 9 observations. The records and the copy of the certification shall be made available for to the Division upon request for review. 9.6 This engine is subject to 40 CFR Part 63, Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engine. The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63, Subpart ZZZZ published in the Federal Register on 2/27/2014. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart ZZZZ. The D.C. Circuit Court issued a mandate on May 4, 2016 for vacatur for certain requirements of allowing emergency engines to operate for limited hours for demand response. Upon issuance of the mandate, §63.6640(f)(2)(ii)-(iii) have no legal effect, as such they have been omitted from this permit. See EPA memorandum "Guidance on Vacatur of RICE NESHAP and NSPS Provisions for Emergency Engines" published on April 15, 2016 for more information. It should be noted that additional revisions to the requirements of 40 CFR Part 63, Subpart ZZZZ are expected to be made in response to issues related to legal action associated with the allowable hours of operation provisions for emergency engines regarding engines used for demand response. The Source shall be subject to such revisions to the Subpart at the time of publication, as appropriate. These requirements have not been adopted into Colorado Regulation no. 8, Part E as of May 8, 2017, and are therefore not state -enforceable. In the event that these requirements are adopted into Colorado Regulations, they will become state -enforceable. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 44 9.6.1 Under Subpart ZZZZ, the engine is classified as: 9.6.1.1 Stationary reciprocating internal combustion engine (RICE) (40 CFR Part 63, §63.6585(a)); and 9.6.1.2 Located at an area source of HAP emissions (40 CFR Part 63, §63.6585(c)); and 9.6.1.3 Existing engine, since it was constructed or reconstructed prior to June 12, 2006 (40 CFR Part 63, §63.6590(a)(1)(iii)); and 9.6.1.4 Emergency stationary RICE (40 CFR Part 63, §63.6675). §63.6595 — When do I have to comply with this Subpart? 9.6.2 The Source owns and operates an existing, stationary, compression ignition (CI) RICE located at an area source of HAP emissions and shall comply with the applicable emission limitations, operating limitations, and other requirements no later than May 3, 2013 (40 CFR Part 63, §63.6595(a)). §63.6603 — What emission limitations, operating limitations, and other requirements must I meet if I own or operate and existing stationary RICE located at an area source of HAP emissions? Compliance with the numerical emission limitations established in this Subpart is based on the results of testing the average of three 1 -hour runs using the testing requirements and procedures in §63.6620 and Table 4 of Subpart ZZZZ. 9.6.3 Existing stationary RICE located at an area source of HAP emissions are subject to the following requirements and operating limitations for emergency, stationary, CI RICE (40 CFR Part 63, §63.6603(a)): 9.6.3.1 Change oil and filter every 500 hours of operation or annually, whichever comes first (40 CFR Part 63, Table 2d). a. The Source may utilize an oil analysis program as described in §63.6625(i) (Condition 9.6.3.1.b) to extend the specified oil change requirement in Table 2d (Condition 9.6.3.1) b. [Oil analysis program] The oil analysis must be performed at the same frequency specified for changing the oil in Table 2d of Subpart ZZZZ (Condition 9.6.3.1.a). The analysis program must at a minimum analyze the following three parameters: total base number, viscosity, and the percent (%) water content. The condemning limits for these parameters are as follows: total base number is less than 30 percent of the total base number of the oil when new; viscosity of the oil has changed by more than 20 percent from the viscosity of the oil when new; or percent water content (by volume) is greater than 0.5. If all Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 45 these condemning limits are exceeded, the engine owner or operator must change the oil within 2 business days of receiving the results of the analysis; if the engine is not in operation when the results of the analyses are received, the engine owner or operator must change the oil within 2 business days or before commencing operation, whichever is later. The owner or operator must keep records of the parameters that are analyzed as part of the program, the results of the analysis, and the oil changes for the engine. The analysis program must be part of the maintenance plan for the engine (40 CFR Part 63, §63.6625(i)). 9.6.3.2 Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, and replace as necessary (40 CFR Part 63, Table 2d). 9.6.3.3 Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary (40 CFR Part 63, Table 2d). 9.6.3.4 If an emergency engine is operating during an emergency and it is not possible to shut down the engine to perform the management practice requirements on the schedule required in Table 2d of Subpart ZZZZ, or if performing the management practice on the required schedule would otherwise pose an unacceptable risk under federal, state, or local law, the management practice can be delayed until the emergency is over or the unacceptable risk under federal, state, or local law has abated. The management practice should be performed as soon as practicable after the emergency has ended or the unacceptable risk under federal, state, or local law has abated. Sources must report any failure to perform the management practice on the schedule required and the federal, state, or local law under which the risk was deemed unacceptable (40 CFR Part 63, Table 2d, footnote 2). §63.6605 — What are my general requirements for complying with this Subpart? 9.6.4 The Source shall be in compliance with the emission limitations, operating limitations, and other requirements in Subpart ZZZZ that apply at all times (40 CFR Part 63, §63.6605(a)). 9.6.5 At all times the Source shall operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require the Source to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspections of the Source (40 CFR Part 63, §63.6605 (b)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 46 §63.6625 — What are my monitoring, installation, collection, operation, and maintenance requirements? 9.6.6 The Source shall operate and maintain the engine in Condition 0 and after -treatment control devices (if any) according to the manufacturer's emission -related written instructions. Alternatively the Source shall develop a separate maintenance plan which must provide to the extent practicable for the maintenance and operation of the engine in a manner consistent with good air pollution control practice for minimizing emissions (40 CFR Part 63, §63.6625(e)(3)). 9.6.7 The Source shall install a non-resettable hour meter on each engine in Condition 0 if not already installed (40 CFR Part 63, §63.6625(f)). 9.6.8 The Source shall minimize the engine's time spent at idle during startup and minimize the engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the emission standards applicable to all times other than startup in Tables la, 2a, 2c, and 2d of Subpart ZZZZ apply (40 CFR Part 63, §63.6625(h)). 9.6.9 The Source may perform an oil analysis program as described in Condition 9.6.3.I.b to extend the specified oil change requirement as described in Table 2d (40 CFR Part 63, §63.6625(i)). §63.6640 — How do I demonstrate continuous compliance with the emission limitations, operating limitations, and other requirements? 9.6.10 The Source shall demonstrate continuous compliance with each emission limitation, operating limitation, and other requirements in Tables la, lb, 2a, 2b, 2c, and 2d of Subpart ZZZZ, as applicable (Condition 9.6.3), according to methods specified in Table 6 of Subpart ZZZZ, which are described as follows (40 CFR Part 63, §63.6640(a)): 9.6.10.1 For demonstrating compliance with work or management practices (40 CFR Part 63, Table 6, (9)(a)): a. Operating and maintaining the stationary RICE according to the manufacturer's emission -related operation and maintenance instructions (40 CFR Part 63, Table 6, (9)(a)(i)); or b. Develop and follow an alternative maintenance plan which must provide to the extent practicable for the maintenance and operation to the engine in a manner consistent with good air pollution control practice for minimizing emissions (40 CFR Part 63, Table 6, (9)(a)(ii)). 9.6.11 The Source shall operate the engine in Condition 9 according to the requirements in §63.6640(f)(1) through (4) (Conditions 9.6.11.1 through 9.6.11.3) for the engine to be Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 47 considered emergency engine under Subpart ZZZZ. Any operation other than emergency operation, maintenance and testing, emergency demand response, and operation in non -emergency situations for 50 hours per year, as described in §63.6640(f)(1) through (4), is prohibited. If the Source does not operate the engine according to the requirements in §63.6640(f)(1) through (4), the engine will not be considered an emergency engine under Subpart ZZZZ and must meet all requirements for non -emergency engines (40 CFR Part 63, §63.6640(f)). 9.6.11.1 There is no time limit on the use of emergency stationary RICE in emergency situations (40 CFR Part 63, §63.6640(f)(1)). 9.6.11.2 The Source may operate the engine in Condition 9 for the purposes specified in §63.6640(f)(2)(i) (Condition 9.6.11.2.a) for a maximum of 100 hours per calendar year. Any operation for non -emergency situations as allowed by §63.6640(f)(3) and (4) (Condition 9.6.11.3) counts as part of the 100 hours per calendar year allowed by §63.6640(f)(2) (40 CFR Part 63, §63.6640(f)(2)). a. Emergency stationary RICE may be operated for maintenance checks and readiness testing, provided that the tests are recommendedby federal, state or local government, the manufacturer, the vendor, the regional transmission organization or equivalent balancing authority and transmission operator, or the insurance company associated with the engine. The owner or operator may petition the Administrator for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that federal, state, or local standards require maintenance and testing of emergency RICE beyond 100 hours per calendar year (40 CFR Part 63, §63.6640(f)(2)(i)). 9.6.11.3 The engine in Condition 9 may be operated for up to 50 hours per calendar year in non -emergency situations. The 50 hours of operation in non - emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in §63.6640(f)(2) (Condition 9.6.11.2). Except as provided in §63.6640(f)(4)(i) and (ii), the 50 hours per year for non -emergency situations cannot be used for 9.6.11.2 peak shaving or non -emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity (40 CFR Part 63, §63.6640(f)(4)). a. The 50 hours per year for non -emergency situations can be used to supply power as part of a financial arrangement with another entity if all the following conditions are met (40 CFR Part 63, §63.6640(f)(4)(ii): Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 48 (i) The engine is dispatched by the local balancing authority or local transmission and distribution system operator (40 CFR Part 63, §63.6640(f)(4)(ii)(A)). (ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert potential voltage collapse or line overloads that could lead to the interruption of power supply in a local area or region (40 CFR Part 63, §63.6640(f)(4)(ii)(B)). (iii)The dispatch follow reliability, emergency operation or similar protocols that follow specific NERC, regional, state, public utility commission or local standards or guidelines (40 CFR Part 63, §63.6640(f)(4)(ii)(C)). (iv)The power is provided only to the facility itself or to support the local transmission and distribution system (40 CFR Part 63, §63.6640(f)(4)(ii)(D)). (v) The owner or operator identified and records the entity that dispatches the engine and the specific NERC, regional, state, public utility commission or local standards or guidelines that are being followed for dispatching the engine. The local balancing authority or local transmission and distribution system operator may keep these records on behalf of the engine owner or operator (40 CFR Part 63, §63.6640(f)(4)(ii)(E)). §63.6650 — What reports must I submit and when? 9.6.12 Engines that operate or are contractually obligated to be available for more than 15 hours per year for the purposes specified in §63.6640(f)(4)(ii) (Condition 9.6.11.3.a) shall submit a report containing the information in §63.6650(h)(1) annually according to the requirements in §63.6650(h)(2) and (3) (40 CFR Part 63, Table 7, (4)). §63.6655 — What records must I keep? 9.6.13 The Source shall keep records of the maintenance conducted on the engine to demonstrate that it was operated and maintained according to the maintenance plan (40 CFR Part 63, §63.6655(e)). 9.6.14 The Source shall keep records of the hours of operation of the engine as recorded on the non-resettable hour meter. The owner or operator shall document how many hours are spent for emergency operation, including what classified the operation as emergency and how many hours are spent for non -emergency operation. If the engine is used for the purposes specified in §63.6640(f)(4)(ii) (Condition 9.6.11.3.a), the owner or operator must keep records of the notification of the emergency situation, and the date, start time, and end time of the engine operation for these purposes (40 CFR Part 63, §63.6655(f)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 49 §63.6660 — In what form and how long must I keep my records? 9.6.15 The records shall be in a form suitable and readily available for expeditious review according to §63.10(b)(1) (40 CFR Part 63, §63.6660(a)). 9.6.16 As specified in §63.10(b)(1), the Source shall keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record (40 CFR Part 63, §63.6660(b)). 9.6.17 The Source shall keep each record readily accessible in hard copy or electronic form for at least 5 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §63.10(b)(1) (40 CFR Part 63, §63.6660(c)). §63.6665 — What parts of the General Provisions apply to me? 9.6.18 The engine is subject to the General Provisions of 40 CFR Part 63, Subpart A as are outlined in Table 8 of Subpart ZZZZ. These requirements include but are not limited to (40 CFR Part 63, §63.6665): 9.6.18.1 9.6.18.2 Prohibited activities and circumvention (§63.4); and Recordkeeping and reporting requirements (§63.10). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 50 10. Facility Wide HAP Emission Limits Permit Limitations Compliance Monitoring Parameter Condition Number Short Term Long Term Emission Factor Method Interval Each Individual HAP 10.1 NA 8 tons/year See Condition 10.1 Recordkeeping and Calculation Monthly Total Facility Wide HAP NA 20 tons/year See Condition 10.1 Table 12 - Facility HAP Limits Summary 10.1 Emissions of HAPs shall not exceed the limitations in Table 12 (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 HAP). HAP emissions shall be calculated by the end of the subsequent month using actual throughputs and the compliance emission factors in Table 13. Emission Source Emission Factors Source of Emission Factor S001 (Condition 1) 0.0014 lb HAP metals/ton production From 10/29/02 synthetic minor (HAP) permit application. S002 (Condition 2) 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 (Condition 0) 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 (Condition 8) 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 7/1998), Table 1.4-3 Table 13 - HAP Compliance Emission Factors for Relevant Units and Processes 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 51 11. 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production This facility is subject to 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production. The requirements of this Subpart pertain to dioxin and furan (D/F) emissions and associated operating, monitoring, reporting and recordkeeping at a secondary aluminum facility that is an area source of HAPs (40 CFR Part 63, §63.1500(c)). Note that the Source is subject to only D/F requirements of this Subpart. Specifically, the facility is subject to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart RRR published in the Federal Register on September 18, 2015. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart RRR.] §63.1505 Emission standards for affected sources and emission units Scrap dryer/delacquering kiln/decoating kiln. 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) (Condition 11.1.1) 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 760°C (1400°F) at all times (40 CFR Part 63, §63.1505(e)). On and after the compliance date established in §63.1501, 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: 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 (40 CFR Part 63, §63.1505(e)(1)(iii)). 11.2 Group 1 furnace. The owner or operator of a group 1 furnace must use the limits in §63.1505(i)(3) and (6) (Conditions 11.2.1 and 11.2.2) to determine the emission standards for a secondary aluminum processing unit (SAPU). 11.2.1 15 µg D/F TEQ per Mg (2.1 x 10-4 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 (40 CFR Part 63, §63.1505(i)(3)). 11.2.2 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 (40 CFR Part 63, §63.1505(i)(6)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 52 11.3 Secondary aluminum processing unit. On and after the compliance date established in §63.1501, the owner or operator must comply with the emission limit calculated using the following equation for D/F for each secondary aluminum processing unit at a secondary aluminum production facility that is a major or area source (40 CFR Part 63, §63.1505(k)): L CD/F n = (� (LtiD/F * Tti))/ Tti i=1 1=1 Where: LtiD/F = The D/F emission limit for individual emission unit `i' in Condition 11.2.1 (40 CFR Part 63, §63.1505(i)(3)) for a group 1 furnace; and LCD/F = The daily D/F emission limit for the secondary aluminum processing unit which is used to calculate the 3 -day, 24 -hour D/F emission limit applicable to the SAPU; and Tti = The mass of the feed/charge for 24 hours for individual emission unit `i' (40 CFR Part 63, §63.1505(k)(3)). 11.4 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) (Condition 11.3) by demonstrating that each emission unit within the SAPU is in compliance with the emission limit of §63.1505(i)(3) (Condition 11.2.1) (40 CFR Part 63, §63.1505(k)(5)). 11.5 With the prior approval of the Division, the owner or operator may redesignate any existing group 1 furnace or in -line fluxer at a secondary aluminum production facility as a new emission unit. Any emission unit so redesignated may thereafter be included in a new SAPU at that facility. Any such redesignation will be solely for the purpose of this NESHAP and will be irreversible (40 CFR Part 63, §63.1505(k)(6)). §63.1506 Operating Requirements Summary. On and after the compliance date established in §63.1501, the owner or operator must operate all new and existing affected sources and control equipment according to the requirements of §63.1506 (40 CFR Part 63, §63.1506(a)(1)). 11.6 At all times, the owner or operator must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (40 CFR Part 63, §63.1506(a)(5)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 53 11.7 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 identifiesthe applicable emission limits and means of compliance, including (40 CFR Part 63, §63.1506(b)): 11.7.1 The type of affected source of emission unit (40 CFR Part 63, §63.1506(b)(1)). 11.7.2 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 (40 CFR Part 63, §63.1506(b)(2)). 11.7.3 The afterburner operating temperature and design residence time for a scrap dryer/delacquering kiln/decoating kiln (40 CFR Part 63, §63.1506(b)(3)). 11.8 Capture/collection systems. For each affected source or emission unit equipped with an add-on air pollution control device, the owner or operator must (40 CFR Part 63, §63.1506(c)): 11.8.1 Design and install a system for the capture and collection of emissions to meet the engineering standards for minimum exhaust rates or facial inlet velocities as contained in the ACGIH Guidelines (incorporated by reference, see §63.14) (40 CFR Part 63, §63.1506(c)(1)); 11.8.2 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 (40 CFR Part 63, §63.1506(c)(2)); and 11.8.3 Operate each capture/collection system according to the procedures and requirements in the OM&M plan (40 CFR Part 63, §63.1506(c)(3)). 11.9 Feed/charge weight. The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or µg/Mg (gr/ton) of feed charge must (40 CFR Part 63, §63.1506(d)): 11.9.1 Except as provided in §63.1506(d)(3) (Condition 11.9.3) 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 (40 CFR Part 63, §63.1506(d)(1)); and 11.9.2 Operate each weight measurement system or other weight determination procedure in accordance with the OM&M plan (40 CFR Part 63, §63.1506(d)(2)). 11.9.3 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 affected source or emission unit provided that (40 CFR Part 63, §63.1506(d)(3)): Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 54 11.9.3.1 The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission units within a SAPU (40 CFR Part 63, §63.1506(d)(3)(i)); and 11.9.3.2 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)(ii)). 11.10 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 (40 CFR Part 63, §63.1506(g)): 11.10.1 For each afterburner (also known as thermal oxidizer) (40 CFR Part 63, §63.1506(g)(1)), 11.10.1.1 Maintain the 3 -hour block average operating temperature of each afterburner at or above the average temperature established during the performance test (40 CFR Part 63, §63.1506(g)(1)(i)). 11.10.1.2 Operate each afterburner in accordance with the OM&M plan (40 CFR Part 63, §63.1506(g)(1)(ii)). Note: The delacquering kiln (S002) is equipped with an afterburner (thermal oxidizer) having a design residence time of 1 second and the afterburner is operated at a temperature of at least 1400°F. The performance test of this kiln (S002) complied with the D/F limit as described in Condition 11.1.1 and so the 3 -hour block average operating temperature shall be at or above 1400°F. 11.10.2 If a bag leak detection system is used to meet the fabric filter monitoring requirements in §63.1510 (Conditions 11.13 through 11.26) (40 CFR Part 63, §63.1506(g)(2)), 11.10.2.1 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 (40 CFR Part 63, §63.1506(g)(2)(i)). 11.10.2.2 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 (40 CFR Part 63, §63.1506(g)(2)(ii)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 55 11.10.3 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 (25°F) (40 CFR Part 63, §63.1506(g)(4)). 11.10.4 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 or above the level established during the performance test (40 CFR Part 63, §63.1506(g)(5)). 11.11 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 (40 CFR Part 63, §63.1506(m)): 11.11.1 If a bag leak detection system is used to meet the monitoring requirements in §63.1510 (Conditions 11.13 through 11.26), the owner or operator must (40 CFR Part 63, §63.1506(m)(1)): 11.11.1.1 Initiate corrective action within 1 hour of a bag leak detection system alarm (40 CFR Part 63, §63.1506(m)(1)(i)). 11.11.1.2 Complete the corrective action procedures in accordance with the OM&M plan (40 CFR Part 63, §63.1506(m)(1)(ii)). 11.11.1.3 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 (40 CFR Part 63, §63.1506(m)(1)(iii)). 11.11.2 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 (25°F) (40 CFR Part 63, §63.1506(m)(3)). 11.11.3 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 or above the level established during the performance test (40 CFR Part 63, §63.1506(m)(4)). 11.11.4 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 (40 CFR Part 63, §63.1506(m)(5)). 11.11.5 Operate each sidewell furnace such that (40 CFR Part 63, §63.1506(m)(6)): 11.11.5.1 The level of molten metal remains above the top of the passage between Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 56 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 (40 CFR Part 63, §63.1506(m)(6)(i)). 11.11.5.2 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 (40 CFR Part 63, §63.1506(m)(6)(ii)). 11.11.6 The operation of capture/collection systems and control devices associated with natural gas -fired, propane -fired or electrically heated group 1 furnaces that will be idles for at least 24 hours after the furnace cycle has been completed may be temporarily stopped. Operation of these capture/collection systems and control devices must be restarted before feed/charge, flux or alloying materials are added to the furnace (40 CFR Part 63, §63.1506(m)(7)). 11.12 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. 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 (40 CFR Part 63, §63.1506(p)). §63.1510 Monitoring Requirements Summary. On and after the compliance date as established in §63.1501, 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 (40 CFR Part 63, §63.1510(a)). 11.13 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 as established in §63.1501. The owner or operator of any new affected source must submit the OM&M plan to the Division within 90 days after a successful initial performance test under §63.1511(b), or within 90 days after the compliance date established by §63.1501 if no initial performance test is required. The plan must be accompanied by a written certification by the owner or operator that the OM&M plan satisfies all requirements of §63.1510 and is otherwise consistent with the requirements of Subpart RRR. The owner or operator must comply with all of the provisions of the OM&M plan as submitted to the Division unless and until the plan is revised in accordance with the procedures of §63.1510. If the Division determines at any time after receipt of the OM&M plan that any revisions of the plan are necessary to satisfy the requirements of §63.1510(b) or Subpart RRR, the owner or operator Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 57 must promptly make all necessary revisions and resubmit the revised plan. If the owner or operator determines that nay other revisions of the OM&M plan are necessary, such revisions will not become effective until the owner or operator submits a description of the changes and a revised plan incorporating them to the Division. Each plan must contain the information as set forth in §63.1510(b)(1) through (9) (40 CFR Part 63, §63.1510(b)). 11.14 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 §63.1506(b) (Condition 11.6) are intact and legible (40 CFR Part 63, §63.1510(c)). 11.15 Capture/collection system. The owner or operator must (40 CFR Part 63, §63.1510(d)): 11.15.1 Install, operate, and maintain a capture/collection system for each affected source and emission unit equipped with an add-on air pollution control device (40 CFR Part 63, §63.1510(d)(1)); and 11.15.2 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) (Condition 11.8) and record results of each inspection. This inspection shall include a volumetric flow rate measurement taken at a location in the ductwork downstream of the hoods that is representative of the actual volumetric flow rate without interference due to leaks, ambient air added for cooling or ducts from other hoods. The flow rate measurement must be performed in accordance with §63.1510(d)(2)(i), (ii) or (iii) (Conditions 11.15.2.1 or 2). As an alternative to the flow rate measurement specified in this paragraph, the inspection may satisfy the requirements of this paragraph, including the operating requirements in §63.1506(c), by including permanent total enclosure verification in accordance with §63.1510(d)(2)(i) or (iv) (Conditions 11.15.2.1 or 3). Inspections that fail to successfully demonstrate that the requirements of §63.1506(c) are met, must be followed by a repair or adjustment to the system operating conditions and a follow up inspection with 45 days to demonstrate that §63.1506(c) requirements are fully met (40 CFR Part 63, §63.1510(d)(2)). 11.15.2.1 Conduct annual flow rate measurements using EPA Reference Methods 1 and 2 in Appendix A to 40 CFR Part 60, or conduct annual verification of a permanent total enclosure using EPA Method 204; or the Source may follow one of the three alternate procedures described in §63.1510(d)(2)(ii), (iii), or (iv) (Conditions 11.15.2.2 or 3) to maintain system operations in accordance with an operating limit established during the performance test. The operating limit is determined as the average reading of a parametric monitoring instrument (Magnehelic®, manometer, anemometer, or other parametric monitoring instrument) and technique as described in §63.1510(d)(2)(ii), (iii), and (iv). A deviation, as defined in §63.1510(d)(2)(ii), (iii), and (iv), from the parametric monitoring Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 58 operating limit requires the owner or operator to make repairs or adjustments to restore normal operation within 45 days (40 CFR Part 63, §63.1510(d)(2)(i)). 11.15.2.2 As an alternative to annual flow rate measurements using EPA Reference Methods 1 and 2, measurement with EPA Reference Methods 1 and 2 can be performed once every 5 years, provided that the requirements of §63.1510(d)(2)(ii)(A) through (E) or §63.1510(d)(2)(iii)(A) through (D) are met (40 CFR Part 63, §63.1510(d)(2)(ii) and (iii)). 11.15.2.3 As an alternative to the annual verification of a permanent total enclosure using EPA Reference Method 204, verification can be performed once every 5 years, provided that the requirements of §63.1510(d)(2)(iv)(A) through (C) are met (40 CFR Part 63, §63.1510(d)(2)(iv)). 11.16 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. 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 (40 CFR Part 63, §63.1510(e)). 11.16.1 The accuracy of the weight measurement device or procedure must be 1 percent (%) of the weight being measured. The Source may apply to the Division for approval to use a device of alternative accuracy if the required accuracy cannot be achieved as a result of equipment layout or charging practices. A device of alternative accuracy will not be approved unless the Source proves assurance through data and information that the affected source will meet the relevant emission standard (40 CFR Part 63, §63.1510(e)(1)). 11.16.2 The Source 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 (40 CFR Part 63, §63.1510(e)(2)). 11.17 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 §63.1510(f)(1) (Condition 11.17.1) or a continuous opacity monitoring system (COMS) as required in §63.1510(f)(2) (40 CFR Part 63, §63.1510(f)). 11.17.1 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 (40 CFR Part 63, §63.1510(f)(1)) Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 59 11.17.1.1 The owner or operator must install and operate a bag leak detection system for each exhaust stack of a fabric filter (40 CFR Part 63, §63.1510(f)(1)(i)). 11.17.1.2 Each bag leak detection system must be installed, calibrated, operated, and maintained according to the manufacturer's operating instructions (40 CFR Part 63, §63.1510(f)(1)(ii)). 11.17.1.3 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 (40 CFR Part 63, §63.1510(f)(1)(iii)). 11.17.1.4 The bag leak detection system sensor must provide output of relative or absolute PM loadings (40 CFR Part 63, §63.1510(f)(1)(iv)). 11.17.1.5 The bag leak detection system must be equipped with a device to continuously record the output signal from the sensor (40 CFR Part 63, §63.1510(f)(1)(v)). 11.17.1.6 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 (40 CFR Part 63, §63.1510(f)(1)(vi)). 11.17.1.7 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 (40 CFR Part 63, §63.1510(f)(1)(vii)). 11.17.1.8 Where multiple detectors are required, the system's instrumentation and alarm may be shared among detectors (40 CFR Part 63, §63.1510(f)(1)(viii)). 11.17.1.9 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 (40 CFR Part 63, §63.1510(f)(1)(ix)). 11.17.1.10 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 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 (40 CFR Part 63, §63.1510(f)(1)(x)). 11.18 Afterburner. These requirements apply to the owner or operator of an affected source using an afterburner to comply with the requirements of Subpart RRR (40 CFR Part 63, §63.1510(g)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 60 11.18.1 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 (40 CFR Part 63, §63.1510(g)(1)). 11.18.2 The temperature monitoring device must meet each of these performance and equipment specifications (40 CFR Part 63, §63.1510(g)(2)): 11.18.2.1 The temperature monitoring device must be installed at the exit of the combustion zone of each afterburner (40 CFR Part 63, §63.1510(g)(2)(i)). 11.18.2.2 The monitoring system must record the temperature in 15 -minute block averages and determine and record the average temperature for each 3 - hour block period (40 CFR Part 63, §63.1510(g)(2)(ii)). 11.18.2.3 The recorder response range must include zero and 1.5 times the average temperature established according to the requirements in §63.1512(m) (Condition 11.35) (40 CFR Part 63, §63.1510(g)(2)(iii)). 11.18.2.4 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 Division (40 CFR Part 63, §63.1510(g)(2)(iv)). 11.18.3 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 (40 CFR Part 63, §63.1510(g)(3)): 11.18.3.1 Inspection of all burners, pilot assemblies, and pilot sensing devices for proper operation and clean pilot sensor (40 CFR Part 63, §63.1510(g)(3)(i)); 11.18.3.2 Inspection for proper adjustment of combustion air (40 CFR Part 63, §63.1510(g)(3)(ii)); 11.18.3.3 Inspection of internal structures (e.g., baffles) to ensure structural integrity (40 CFR Part 63, §63.1510(g)(3)(iii)); 11.18.3.4 Inspection of dampers, fans, and blowers for proper operation (40 CFR Part 63, §63.1510(g)(3)(iv)); 11.18.3.5 Inspection for proper sealing (40 CFR Part 63, §63.1510(g)(3)(v)); 11.18.3.6 Inspection of motors for proper operation (40 CFR Part 63, §63.1510(g)(3)(vi)); 11.18.3.7 Inspection of combustion chamber refractory lining and clean and replace lining as necessary (40 CFR Part 63, §63.1510(g)(3)(vii)); 11.18.3.8 Inspection of afterburner shell for corrosion and/or hot spots (40 CFR Part 63, §63.1510(g)(3)(viii)); Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 61 11.18.3.9 Documentation, for the burn cycle that follows the inspection, that the afterburner is operating properly and any necessary adjustments have been made (40 CFR Part 63, §63.1510(g)(3)(ix)); and 11.18.3.10 Verification that the equipment is maintained in good operating condition (40 CFR Part 63, §63.1510(g)(3)(x)). 11.18.3.11 Following an equipment inspection, all necessary repairs must be completed in accordance with the requirements of the OM&M plan (40 CFR Part 63, §63.1510(g)(3)(xi)). 11.19 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 Subpart RRR (40 CFR Part 63, §63.1510(h)). 11.19.1 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 40 CFR Part 60, Subpart A (40 CFR Part 63, §63.1510(h)(1)). 11.19.2 The temperature monitoring device must meet each of these performance and equipment specifications 40 CFR Part 63, §63.1510(h)(2)): 11.19.2.1 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 (40 CFR Part 63, §63.1510(h)(2)(i)). 11.19.2.2 The recorder response range must include zero and 1.5 times the average temperature established according to the requirements in §63.1512(n) (Condition 11.36) (40 CFR Part 63, §63.1510(h)(2)(ii)). 11.19.2.3 The reference method must be a National Institute of Standards and Technology (NIST) calibrated reference thermocouple -potentiometer system or alternate reference, subject to approval by the Division (40 CFR Part 63, §63.1510(h)(2)(iii)). 11.20 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 Subpart RRR (40 CFR Part 63, §63.1510(i)). 11.20.1 The owner or operator of a continuous lime injection system must verify that lime is always free -flowing by either (40 CFR Part 63, §63.1510(i)(1)): 11.20.1.1 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 62 least once every 8 hour period if corrective action results in no further blockages of lime during the 3 -day period (40 CFR Part 63, §63.1510(i)(1)(i)). 11.20.2 The owner or operator of a continuous lime injection system must record the lime feeder setting once each day of operation (40 CFR Part 63, §63.1510(i)(2)). 11.20.3 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 (40 CFR Part 63, §63.1510(i)(3)). 11.20.4 At least once per month, the Source shall verify that the lime injection rate in pounds per hour (lb/hr) is no less than 90 percent of the lime injection rate used to demonstrate compliance during the most recent performance test. If the monthly check of the lime injection rate is below the 90 percent, the owner or operator must repair or adjust the lime injection system to restore normal operation within 45 days. The owner or operator may request from the Division an extension of up to an additional 45 days to demonstrate that the lime injection rate is no less than 90 percent of the lime injection rate used to demonstrate compliance during the most recent performance test. In the event that a lime feeder is repaired or replaced, the feeder must be calibrated, and the feed rate must be restored to the lb/hr feed rate operating limit established during the most recent performance test within 45 days. The owner or operator may request from the Division an extension of up to an additional 45 days to complete the repair or replacement and establishing a new setting. The repair or replacement, and the establishment of the new feeder setting(s) must be documented in accordance with the recordkeeping requirements of §63.1517 (40 CFR Part 63, §63.1510(i)(4)). 11.21 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 (40 CFR Part 63, §63.1510(j)): 11.21.1 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 (40 CFR Part 63, §63.1510(j)(1)). 11.21.1.1 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 (40 CFR Part 63, §63.1510(j)(1)(i)). 11.21.1.2 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 A Golden Aluminum, Inc. Page 63 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 (40 CFR Part 63, §63.1510(j)(1)(ii)). 11.21.1.3 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 (40 CFR Part 63, §63.1510(j)(1)(iii)). 11.21.2 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) (Condition 11.37) (40 CFR Part 63, §63.1510(j)(2)). 11.21.3 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 (40 CFR Part 63, §63.1510(j)(3)): 11.21.3.1 Gaseous or liquid reactive flux other than chlorine (40 CFR Part 63, §63.1510(j)(3)(i)); and 11.21.3.2 Solid reactive flux (40 CFR Part 63, §63.1510(j)(3)(iii)). 11.21.4 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) (Condition 11.37). For solid flux that is added intermittently, record the amount added for each operating cycle or time period used in the performance test using procedures in §63.1512(o) (40 CFR Part 63, §63.1510(j)(4)). 11.21.5 The owner or operator of a group 1 furnace or in -line fluxer performing reactive fluxing may apply to the Division 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 (40 CFR Part 63, §63.1510(j)(5)). 11.22 Sidewell group 1 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 (40 CFR Part 63, §63.1510(n)): 11.22.1 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 64 during reactive flux injection, unless the furnace hearth was also equipped with an add-on control device. If visual inspection of the molten metal level is not possible, the molten metal level must be determined using physical measurement methods (40 CFR Part 63,§63.1510(n)(1)). 11.22.2 Submit a certification of compliance with the operational standards in §63.1506(m)(6) (Condition 11.11.5) for each 6 -month reporting period. Each certification must contain the information in 63.1516(b)(2)(iii) (Condition 11.47.2) (40 CFR Part 63, §63.1510(n)(2)). 11.23 Site -specific requirements for secondary aluminum processing units (40 CFR Part 63, §63.1510(s)). 11.23.1 An 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) (Condition 11.13), the information set forth in §63.1510(s)(1) (40 CFR Part 63, §63.1510(s)(1)). 11.23.2 The SAPU compliance procedures within the OM&M plan may not contain any of the provisions set forth in §63.1510(s)(2) (40 CFR Part 63, §63.1510(s)(2)). 11.23.3 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) (Condition 11.23.1) and obtain approval of the Division prior to implementing any revisions (40 CFR Part 63, §63.1510(s)(3)). 11.24 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 (40 CFR Part 63, §63.1510(u)). 11.25 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 Division for approval of an alternative method for monitoring the lime addition in accordance with the provisions of §63.1510(v) (40 CFR Part 63, §63.1510(v)). 11.26 Alternative monitoring methods. If an owner or operator wishes to use an alternative monitoring method to demonstrate compliance with any emission standard in this subpart, other than those alternative monitoring methods which may be authorized pursuant to §63.1510(j)(5) (Condition 11.21.5) and §63.1510(v) (Condition 11.25), the owner or operator may submit an application to the Division. Any such application will be processed according to the criteria and procedures set forth in §63.1510(w)(1) through (6) (40 CFR Part 63, §63.1510(w)). §63.1511 Performance test/compliance demonstration general requirements. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 65 11.27 Site -specific test plan. Prior to conducting any performance test required by Subpart RRR, the owner or operator must prepare a site -specific test plan which satisfies all of the rule requirements, and must obtain approval of the plan pursuant to the procedures set forth in §63.7. Performance tests shall be conducted under such conditions as the Division specifies to the owner or operator based on representative performance of the affected source for the period being tested. Upon request, the owner or operator shall make available to the Division such records as may be necessary to determine the conditions of performance tests (40 CFR Part 63, §63.1511(a)). 11.28 Test methods. The owner or operator must use the methods in 40 CFR Part 60, as referenced in 63.1511(c)(1) through (9), to determine compliance with the applicable emission limits or standards (40 CFR Part 63, §63.1511(c)). 11.29 Alternative methods. The owner or operator may use an alternative test method as provided in §63.1511(d)(1) through (3), subject to approval by the Division (40 CFR Part 63, §63.1511(d)). 11.30 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 (Conditions 11.13 through 11.26) that ensures compliance with the applicable emission limit or standard. To establish the minimum or maximum value or range, the owner or operator must use the appropriate procedures in §63.1511(g) and submit the information required by §63.1515(b)(4) (Condition 11.46) in the notification of compliance status report. The owner or operator may use existing data in addition to the results of performance tests to establish operating parameter values for compliance monitoring provided the requirements in §63.1511(g)(1) through (5) are met to the satisfaction of the Division (40 CFR Part 63, §63.1511(g)). 11.31 Testing of commonly -ducted units within a secondary aluminum processing unit. When group 1 furnaces and/or in -line fluxers are included in a single existing SAPU or new SAPU, and the emissions from more than one emission unit within that existing SAPU or new SAPU are manifolded to a single control device, compliance for all units within the SAPU is demonstrated if the total measured emissions from all controlled and uncontrolled units in the SAPU do not exceed the emission limits calculated for that SAPU based on the applicable equation in §63.1505(k) (Condition 11.3) (40 CFR Part 63, §63.1511(h)). §63.1512 Performance test/compliance demonstration requirements and procedures. 11.32 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)(1) and (2) (40 CFR Part 63, §63.1512(c)). 11.33 Group 1 furnace with add-on air pollution control devices. 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(d)(1) through (4) (40 CFR Part 63, §63.1512(d)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 66 11.34 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 (40 CFR Part 63, §63.1512(k)). 11.35 Afterburner. The owner or operator of an affected source using an afterburner must comply with the requirements of §63.1512(m)(1) and (2) (40 CFR Part 63, §63.1512(m)). Note: The delacquering kiln (S002) is equipped with an afterburner having a design residence time of 1 second and the afterburner is operated at a temperature of at least 1400 °F. This kiln (S002) complies with the alternative dioxin/furan limit (Condition 11.1.1) and so the 3 -hour block average operating temperature shall be at or above 1400 °F. 11.36 Inlet gas temperature. The owner or operator of a scrap dyer/delacquering kiln/decorating kiln or a group 1 furnace using a lime -injected fabric filter must use the procedures in §63.1512(n)(1) through (3) to establish an operating parameter value or range for the inlet gas temperature (40 CFR Part 63, §63.1512(n)). 11.37 Flux injection rate. The owner or operator must use the procedures in §63.1512(o)(1) through (5) to establish an operating parameter value or range of the total reactive chlorine flux injection rate (40 CFR Part 63, §63.1512(o)). 11.38 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)(1) and (2) 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 (40 CFR Part 63, §63.1512(p)). 11.39 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(f) (Condition 11.17) (40 CFR Part 63, §63.1512(q)). 11.40 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) (Condition 11.46) as part of the notification of compliance status report to document conformance with the operational standard in §63.1506(b) (Condition 11.6) (40 CFR Part 63, §63.1512(r)). 11.41 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) (Condition 11.46) as part of the notification of compliance status report to Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 67 document conformance with the operational standard in §63.1506(c) (Condition 11.8)(40 CFR Part 63, §63.1512(s)). §63.1513 Equations for determining compliance. 11.42 The owner or operator shall use the equations set forth in §63.1513 to determine compliance with emission limits (40 CFR Part 63, §63.1513). §63.1514 Change of furnace classification. The requirements of this section are in addition to the other requirements of Subpart RRR that apply to group 2 and group 2 furnaces. 11.43 Should the owner or operator elect to change the furnace classification they shall follow the requirements in §63.1514 as applicable. The potential reclassifications are included by reference as follows: 11.43.1 Changing from a group 1 controlled furnace processing other than clean charge to group 1 uncontrolled processing other than clean charge (40 CFR Part 63, §63.1514(a)). 11.43.2 Changing from a group 1 controlled furnace processing other than clean charge to a group 1 uncontrolled furnace processing clean charge (40 CFR Part 63, §63.1514(b)). 11.43.3 Changing from a group 1 controlled or uncontrolled furnace to a group 2 furnace (40 CFR Part 63, §63.1514(c)). 11.43.4 Changing from a group 1 controlled or uncontrolled furnace to a group 2 furnace, for tilting reverberatory furnaces capable of completely removing furnace contents between batches (40 CFR Part 63, §63.1514(d)). 11.44 Limit on frequency of changing furnace operating mode (40 CFR Part 63, §63.1514(e)). 11.44.1 Changing furnace operating mode including reversion to the previous mode, as provided in §63.1514(a) through (d) (Conditions 11.43.1 through 4), may not be done more frequently than 4 times in any 6 -month period unless the Source receives approval from the Division for additional changes pursuant to §63.1514(e)(2) (Condition 11.44.2) (40 CFR Part 63, §63.1514(e)(1)). 11.44.2 If additional changes are needed, the owner or operator must apply in advance to the Division for approval of the additional changes in operating mode (40 CFR Part 63,, §63.1514(e)(2)). §63.1515 Notifications. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 68 11.45 Initial notifications. The owner or operator must submit initial notifications to the Division as described in §63.1515(a). 11.46 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. 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(a)(1) through (10). The report may be submitted as set forth in §63.1515(b) (40 CFR Part 63, §63.1515(b)). §63.1516 Reports. 11.47 Excess emissions/summary report. The owner or operator of a major or area source must submit semiannual reports according to the requirements in §63.10(e)(3). Except, the owner or operator must submit the semiannual reports within 60 days after the end of each 6 -month period instead of within 30 days after the calendar half as specified in §63.10(e)(3)(v). 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 (40 CFR Part 63, §63.1516(b)). 11.47.1 A report must be submitted if any of the conditions listed in §63.1516(b)(1) occurs during a 6 -month reporting period. 11.47.2 Each report must include each of the certifications listed in §63.1516(b)(2), as applicable. 11.47.3 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 (40 CFR Part 63, §63.1516(b)(3)). 11.47.3.1 Within 60 days after the date of completing each performance test (as defined in §63.2) required by Subpart RRR, the Source must submit the results of the performance tests, including any associated fuel analyses, following the procedure specified in either §63.1516(b)(3)(i)(A) or (B) (40 CFR Part 63, §63.1516(b)(3)(i)). 11.47.4 A malfunction report that is required under §63.1515(d) (Condition 11.49) shall be submitted simultaneously with the semiannual excess emissions/summary report required by §63.1515(b) (Condition 11.47) (40 CFR Part 63, §63.1515(b)(4)). 11.48 Annual compliance certifications. For the purpose of annual certifications of compliance required by 40 CFR Part 70 or 71, the owner or operator must certify continuing compliance based upon, but not limited to, the following conditions (40 CFR Part 63, §63.1516(c)): Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 69 11.48.1 Any period of excess emissions, as defined in §63.1516(b)(1) (Condition 11.47.1), that occurred during the year were reported as required by Subpart RRR (40 CFR Part 63, §63.1516(c)(1)); and 11.48.2 All monitoring, recordkeeping, and reporting requirements were met during the year (40 CFR Part 63, §63.1516(c)(2)). 11.49 If there was a malfunction during the reporting period, the owner or operator must submit a report that includes the emission unit ID, monitor ID, pollutant or parameter monitored, beginning date and time of the event, end date and time of the event, cause of the deviation or exceedance and corrective action taken for each malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must include a list of the affected source or equipment, an estimate of the quantity of each regulated pollutant emitted over any emission limit, and a description of the method used to estimate the emissions, including, but not limited to, product -loss calculations, mass balance calculations, measurements when available, or engineering judgment based on known process parameters. The report must also include a description of actions taken by an owner or operator during a malfunction of an affected source to minimize emissions in accordance with §63.1506(a)(5) (Condition 11.6) (40 CFR Part 63, §63.1516(d)). 11.50 All reports required by Subpart RRR not subject to the requirements in §63.1516(b) (Condition 11.47) must be sent to the Administrator at the appropriate address listed in §63.13. If acceptable to both the Administrator and the owner or operator of a source, these reports may be submitted on electronic media. The Administrator retains the right to require submittal of reports subject to §63.1516(b) in paper format (40 CFR Part 63, §63.1516(e)). §63.1517 Records 11.51 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. Records shall be maintained as set forth in §63.1517(a)(1) through (3) (40 CFR Part 63, §63.1517(a)). 11.52 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)(1) through (20), as applicable (40 CFR Part 63, §63.1517(b)). §63.1518 Applicability of General Provisions 11.53 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 (40 CFR Part 63, §63.1518): Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 70 11.53.1 Prohibited activities (§63.4); and 11.53.2 Operation and maintenance requirements (§63.6(e)(1)); and 11.53.3 Startup, shutdown and malfunction plan requirements (§63.6(e)(3)); and 11.53.4 Performance test requirements (§63.7); and 11.53.5 Monitoring requirements (§63.8); and 11.53.6 Notification requirements in (§63.9); and 11.53.7 Recordkeeping requirements (§63.10). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 71 12. Gasoline Tank: 297 Gallons 12.1 This gasoline tank is not subject to Operating Permit emissions or throughput limits as it is considered an insignificant activity under Colorado Regulation No. 3, Part A, Section II.E.1.ccc.; however, the Source shall be required to maintain records to verify that the daily fuel throughput is no more than four hundred gallons per day, averaged annually. 12.2 40 CFR Part 63, Subpart CCCCCC — National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities 12.2.1 This source is subject to 40 CFR Part 63, Subpart CCCCCC — National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities. The requirements of this Subpart pertain to establishing standard emission limitations and management practices for HAP emitting from the loading of gasoline storage tanks at gasoline dispensing facilities (40 CFR Part 63, §63.11110). Specifically, the facility is subject to the following requirements: [The requirements below reflect the current rule language as of the revisions to 40 CFR Part 63 Subpart CCCCCC published in the Federal Register on January 24, 2011. However, if revisions to this Subpart are published at a later date, the owner or operator is subject to the requirements contained in the revised version of 40 CFR Part 63, Subpart CCCCCC.] The Source shall, upon request by the Administrator, demonstrate that the monthly throughput is less than the 10,000 gallon threshold level. As specified in §63.11112(d), recordkeeping to document monthly throughput must begin on January 10, 2008. Records required under this condition shall be kept for a period of 5 years (40 CFR Part 63, §63.11111(e)). 12.2.2 Monthly throughput is the total volume of gasoline loaded into, or dispensed from, all the gasoline storage tanks located at a single affected gasoline dispensing facility (GDF) (40 CFR Part 63, §63.11111(h)). 12.2.3 If the Source's total throughput of gasoline exceeds 10,000 gallons per month, the Source shall remain subject to the requirements for sources above the threshold, even if the Source throughput later falls below the applicable throughput threshold (40 CFR Part 63, §63.11111(i)). 12.2.4 The emission sources to which this subpart applies are gasoline storage tanks and associated equipment components in vapor or liquid gasoline service at new, reconstructed, or existing GDF that meet the criteria specified in §63.11111 (Conditions 0 through 12.2.3). Pressure/Vacuum vents on gasoline storage tanks and the equipment necessary to unload product from cargo tanks into the storage tanks at GDF are covered emission sources. The equipment used for the refueling of motor vehicles is not covered by Subpart CCCCCC (40 CFR Part 63, §63.11112(a)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 72 12.2.5 The Source shall comply with the standards in Subpart CCCCCC no later than January 10, 2011 (40 CFR Part 63, §63.11113(b)). 12.2.6 The Source shall, at all times, operated and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source (40 CFR Part 63, §63.11115(a)). 12.2.7 The Source shall not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to, the following (40 CFR Part 63, §6311116(a)): 12.2.7.1 Minimize gasoline spills (40 CFR Part 63, §63.11116(a)(1)); 12.2.7.2 Clean up spills as expeditiously as practicable (40 CFR Part 63, §63.11116(a)(2)); 12.2.7.3 Cover all open gasoline containers and all gasoline storage tank fill -pipes with a gasketed seal when not in use (40 CFR Part 63, §63.11116(a)(3)); 12.2.7.4 Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators (40 CFR Part 63, §63.11116(a)(4)). 12.2.8 The Source is not required to submit notifications or reports as specified in §63.11125, §63.11126, or Subpart A of 40 CFR Part 63, but shall have records available within 24 hours of a request by the Administrator to document the gasoline throughput (40 CFR Part 63, §63.11116(b)). 12.2.9 Portable gasoline containers that meet the requirements of 40 CFR Part 59, Subpart F, are considered acceptable for compliance with §63.11116(a)(3) (40 CFR Part 63, §63.11116(d)). 12.2.10 GDF covered under Subpart CCCCCC are subject to 40 CFR Part 63, Subpart A, General Provisions. These requirements include but are not limited to (40 CFR Part 63, §63.11130): 12.2.10.1 Prohibited activities and circumvention (§63.4); and 12.2.10.2 Compliance with operation & maintenance (§63.6(e)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 13. Insignificant Activity Tracking Golden Aluminum, Inc. Page 73 13.1 The potential to emit (PTE) of VOC emissions from all insignificant activities and permitted points combined shall not exceed 100 tons per year. Compliance with the limitation shall be monitored by conducting a PTE analysis of VOC emissions from all insignificant activities and permitted points. The PTE for insignificant activities is estimated using the maximum design/emission rate of the unit and assuming operation at 8760 hours per year. The PTE for the permitted points is based on the permitted consumption/throughput limits; a summary of the permitted points emissions may be found in the Technical Review Document (TRD) associated with this permit. All emission factors used as part of the PTE analysis shall be cited and documented. This PTE analysis shall be completed within 60 days of this permit issuance. 13.2 The PTE analysis shall be reviewed once per calendar year to assure all insignificant emission units are included and that the emission estimates are still suitable. New insignificant activities that can potentially emit VOC that are added to the facility shall be added to the PTE analysis. Updated emission factors shall be used where appropriate. The Division reserves the right to contest and change Source -chosen emission factors if there are more appropriate emission factors available. 13.3 The analysis, calculations, and supporting documentation shall be retained on site and made available to the Division upon request. 13.4 For the purposes of Condition 13, insignificant activities shall be defined as any process or equipment which emits any amount of VOC but does not require an Air Pollutant Emission Notice (APEN), is exempt from the construction permitting requirements in Colorado Regulation No. 3, Part B, or is a listed insignificant activity in Colorado Regulation No. 3, Part C. 13.5 The list of insignificant activities is displayed in Appendix A (note that this will also include the gasoline tank in Condition 12 and may include the emergency engine in Condition 9, if applicable). The recordkeeping requirements in Appendix A may satisfy some of the requirements in Condition 13, and vice versa; however, neither replace the other and as such sufficient records must be kept for the satisfaction of the requirements of both. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 74 14. Compliance Assurance Monitoring 14.1 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 10 and S006 — Melt Area Baghouse with respect to the particulate matter and facility wide HAP limitations identified in Conditions 4.1 and 10 as follows: 14.1.1 The permittee shall follow the CAM Plan provided in Appendix H of this permit. Excursions, for purposes of reporting, are as follows: 14.1.1.1 For S006 (Melt Area Baghouse): Any instance in which the bag leak detection system alarms. 14.1.1.2 For S006 (Melt Area Baghouse): Any day in which the bag leak detection system is not operational for any time during that day. 14.1.1.3 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. 14.1.1.4 For S002 (Delaquering Kiln) and S006 (Melt Area Baghouse): Any day in the daily check reveals that lime is not free -flowing. 14.1.1.5 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 delacquering 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. 14.1.2 Operation of Approved Monitoring 14.1.2.1 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)). 14.1.2.2 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 75 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)). 14.1.2.3 Response to excursions or exceedances a. Upon detecting an excursion or exceedance, the owner or operator shall restore operation of 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)). 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)). 14.1.2.4 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 76 of additional parameters (40 CFR Part 64, §64.7(e)).. 14.1.3 Quality Improvement Plan (QIP) Requirements 14.1.3.1 Based on the results of a determination made under the provisions of Condition 14.1.2.3.b, the Division may require the owner or operator to develop and implement a QIP (40 CFR Part 64, §64.8(a)). 14.1.3.2 The owner or operator shall maintain a written QIP, if required, and have it available for inspection (40 CFR Part 64, §64.8(b)(1)). 14.1.3.3 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)). b. Process operation changes (40 CFR Part 64, §64.8(b)(2)(ii)). c. Appropriate improvements to control methods (40 CFR Part 64, §64.8(b)(2)(iii)). d. Other steps appropriate to correct control performance (40 CFR Part 64, §64.8(b)(2)(iv)). e. More frequent or improved monitoring (only in conjunction with one or more steps under Conditions 14.1.3.3.a through d) (40 CFR Part 64, §64.8(b)(2)(v)). 14.1.3.4 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)). 14.1.3.5 Following implementation of a QIP, upon any subsequent determination pursuant to Condition 14.1.2.3.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)); or b. Failed to provide adequate procedures for correcting control device performance problems as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions (40 CFR Part 64, §64.8(d)(2)). 14.1.3.6 Implementation of a QIP shall not excuse the owner or operator of a Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 77 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)). 14.1.4 Reporting and Recordkeeping Requirements 14.1.4.1 Reporting Requirements. The reports required by Section V, Condition 22.d, shall contain the information specified in Appendix B of the permit and the following information, as applicable: a. Summary information on the number, duration and cause (including unknown cause, if applicable), for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable) (40 CFR Part 64, §64.9(a)(2)(ii)); and b. 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 14.1.3 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)). 14.1.4.2 General Recordkeeping Requirements. In addition to the recordkeeping requirements in Section V, Condition 22.a through c. a. The owner or operator shall maintain records of any written QIP required pursuant to Condition 14.1.3 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)). b. 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)). 14.1.5 Savings Provisions 14.1.5.1 Nothing in these CAM requirements shall 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 78 requirement that may apply under federal, state, or local law, or any other 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)). 14.1.5.2 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)). 14.1.5.3 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)). Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 79 SECTION III - Permit Shield Regulation No. 3, 5 CCR 1001-5, Part C, §§ I.A.4, V.D. & XIII.B; § 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 modifications 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. 3. Stream -lined 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 80 Permit Condition Streamlined (Subsumed) Requirements Section II, Conditions 1.1.1, 2.1.1, 3.1.1, and 4.1.1 Colorado Regulation No. 6, Part B, Section III.C.1 [particulate matter standard - E = 3.59(P)0'62] - State - only provision. Section II, Conditions 6.1.1 and 7.1.1 Colorado Regulation No. 6, Part B, Section III.C.2 [particulate matter standard - E = 17.31(P)016] - State -only provision. - Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 81 SECTION IV - General Permit Conditions (ver 5/22/2012) 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, ti§ 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) 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 § 112(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 && II.A., II.B., II.C., II.E., II.F., II.I, 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. b. Emission Monitoring Requirements Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 82 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. Nothing in this section shall abrogate the Division's authority to conduct its own performance test(s) if so warranted. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 83 d. Affirmative Defense Provision for Excess Emissions during Malfunctions 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 credible 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 of the 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, credible 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 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 84 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. Credible 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 credible 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, credible 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 submit written quarterly notification following the initial occurrence of the excess emissions. The notification shall address the criteria set forth above. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 85 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.11. & 16.d. and 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 XI. 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 permittee 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: (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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 86 g. (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.E 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, credible 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 91st day after the date of invoice, unless a permittee has filed a timely protest to the invoice amount. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 87 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 with the 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, § 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. 11. 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 88 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. 15. Off -Permit Changes to the Source Regulation No. 3, 5 CCR 1001-5, Part C, 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, §§ I.- II. 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 I., II.C., II.D., HI. 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, && II1.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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 89 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: 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 otherwise 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 specify 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, § II.; Part C, §S 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 90 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. 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 requirements must be 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, § II.D. A revised APEN shall be filed annually whenever a significant change in emissions, as defined in Regulation No. 3, Part A, § II.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, tz 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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 91 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. 26. Significant Permit Modifications Regulation No. 3, 5 CCR 1001-5, Part C, § III.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, 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. The requirements in paragraphs a, b and e apply to sources located in an ozone non -attainment area or the Denver 1 -hour ozone attainment/maintenance area. The requirements in paragraphs c and d apply statewide. a. 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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 92 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. b. 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. c. The permittee shall not dispose of volatile organic compounds by evaporation or spillage unless Reasonably Available Control Technology (RACT) is utilized. d. 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. e. Beer production and associated beer container storage and transfer operations involving volatile organic compounds with a true vapor pressure of less than 1.5 PSIA actual conditions are exempt from the provisions of paragraph b, above. 30. Wood Stoves and Wood burning Appliances Regulation No. 4, 5 CCR 1001-6 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Appendices OPERATING PERMIT APPENDICES A: INSPECTION INFORMATION B: REPORTING REQUIREMENTS AND DEFINTIONS C: REQUIRED FORMAT FOR ANNUAL COMPLIANCE CERTIFICATION REPORTS 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 the permit, and is presented to assist the source, permitting authority, inspectors, and citizens. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report APPENDIX A - Inspection Information 1. Directions to Plant: The facility is located one half mile east of highway 85 on 14th street. 2. Safety Equipment Required: Appendix B Page 94 Eye Protection, Safety Shoes, Hearing Protection, Gloves and Tap Coats (Tap Coats will be furnished by Golden Aluminum). 3. 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. 4. 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. For insignificant activities marked with an asterisk (*) the owner or operator must maintain sufficient recordkeeping to verify that the exemption applies (i.e., annual throughput is less than 400,000 gallons). Such records shall be made available for Division review upon request for review (Colorado Regulation No. 3, Part C, Section II.E). Insignificant Activities Unit /Process Colorado Reg 3, Part C Records Required Washline Detergent tank burners II.E.3.k. Rinse tank burners II.E.3.k. Predryer burner exhaust II.E.3.k. * Coatingline process tank burners 1 II.E.3.k. 2 II.E.3.k. 3 II.E.3.k. 5 II.E.3.k. Coatingline cure ovens 1 II.E.3.k. 2 II.E.3.k. 3 II.E.3.k. 4 II.E.3.k. 5 II.E.3.k. Waste water pretreatment II.E.3.a. Air handler units (fans only) II.E.3.c. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix B Page 95 Machining equipment II.E.3.iii. QA/QC lab ventilation II.E.3.i.(i.) Various heating units II.E.3.ggg. Welding and fabricating operations II.E.3.r. Crashed -mill strip -cutting operations II.E.3.kk. Lab and office activities II.E.3.tt. Furnace rebuilding II.E.3.w. Delacquering kiln rebuilding II.E.3.w. Lancing operations rebuilding II.E.3.w. Thermite fires II.E.3.ff. Baghouse fires II.E.3.ff. Grass and weed fires II.E.3.ff. (25) 301b propane tanks' II.E.3.zz. (2) 1000 gallon propane tanks' II.E.3.zz. (2) 12,000 gallon cold mill coolant tanks' II.E.3.aaa. Hot mill Hoffman exhaust II.E.3.c. 1078 gallon and 4800 gallon hot -mill, used, water -based coolant tanks II.E.3.mm. Morgoil working tank 2674 gallon' II.E.3.aaa. Forklifts (14) II.E.3.kkk. Paint storage room II.E.3.mm. Thermal oxidizer rebuilds II.E.3.w. Hot gas generator rebuilds II.E.3.w. Chemical totes II.E.3.n Street and parking lot stripping II.E.3.s. Battery recharging areas II.E.3.t. Landscaping use of herb and pesticides II.E.3.ttt. Office demolition and remodeling' II.E.3.vvv. Winter parking lot sanding II.E.3.p. Lawnmowing and trimming equipment' II.E.3.bb. Vacuum cleaning for facility housekeeping II.E.3.ii. (2) Lime silos II.E.3.a. Note that these tanks are subject to Colorado Regulation No. 7 requirements as described in Section IV, Condition 3 Note that this exemption only applies for non -asbestos demolition 3 Note that this exemption only applies to equipment with horsepower less than or equal to 10 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Figure: 1 •-• } F } MI `�1 i i t • I i i l I i i I a i I I I I I I I I I i I s I! Appendix B Page 96 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix B Page 97 APPENDIX B — Reporting Requirements and Definitions with codes version 8/20/14 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 such deviations, and any corrective actions or preventive measures taken. All Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report (1) Appendix B Page 98 deviations from any term or condition of the permit are 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: 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: 8=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. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix B Page 99 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 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. 1 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Startup, Shutdown, Malfunctions and Emergencies, Appendix B Page 100 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 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report APPENDIX B — Monitoring and Permit Deviation Report - Part I Appendix B Page 101 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: 96OP WE 125 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 Particle Separator Drop Box, 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: B1N221Controlled by a Thermal Oxidizer and baghouse. S003 Custom Melter # 1 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 TPH, Controlled with an Air Purifier Centrifugal Separator. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report Appendix B Page 102 Operating Permit Unit ID Unit Description Deviations noted During Period?' 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. S012 Emergency Engine, Make: Detroit Diesel, Model: 16V -149T, SN: 16E4255, Horsepower: 1310 N/A Gasoline Tank General Conditions Insignificant Activities See previous discussion regarding what is considered to be a deviation. Determination of whether or not a deviation has occurred shall be based on a reasonable inquiry using readily available information. 2 Use the following entries, as appropriate 1 = Standard: 2 = Process: 3 = Monitor: 4 = Test: 5 = Maintenance: 6 = Record: 7 = Report: 8=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 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report APPENDIX B — Monitoring and Permit Deviation Report - Part II FACILITY NAME: Golden Aluminum, Inc. OPERATING PERMIT NO: 96OPWE 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 Appendix B Page 103 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Compliance Certification Report EXAMPLE FACILITY NAME: U.S.S. Enterprise OPERATING PERMIT NO: 64OPZZXXX REPORTING PERIOD: , 1/1/2369 - 6/30/2369 Appendix B Page 104 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: Holodeck generator with nanobot-repaired filtration system — Unit TNG Operating Permit Condition Number Citation Section II, Condition 3.1 - Opacity Limitation Explanation of Period of Deviation Tribbles in the console Duration START- 1730 4/10/2369 END- 1800 4/10/2369 Action Taken to Correct the Problem Transported Tribbles to Klingon vessel. Measures Taken to Prevent Reoccurrence of the Problem Permanent ban of Tribbles as pets. Increased structural integrity of console. Dates of Malfunction/Emergencies Reported (if applicable) 5/30/2369 to J.L. Picard, APCD Deviation Code Division Code QA: Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix C Page 105 APPENDIX B — Monitoring and Permit Deviation Report - Part III REPORT CERTIFICATION SOURCE NAME: Golden Aluminum, Inc. FACILITY IDENTIFICATION NUMBER: 123-0089 PERMIT NUMBER: 96OPWE 125 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. 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix C Page 106 APPENDIX C — Required Format for Annual Compliance Certification Reports 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: I. 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 Particle Separator Drop Box, 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix C Page 107 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 S003 Custom Melter # 1 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 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. 5011 Custom Hunter Coil Coating, 26.1 MMBtu Grace Tec Natural Gas Fired Burner, Controlled with an incinerator. S012 Emergency Engine, Make: Detroit Diesel, Model: 16V -149T, SN: 16E4255, Horsepower: 1310 N/A Gasoline Tank General Conditions Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix C Page 108 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 Insignificant Activities 4 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 1) 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. 4 Compliance status for these sources shall be based on a reasonable inquiry using readily available information. Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix C Page 109 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. 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Notification Addresses Appendix D Page 110 APPENDIX D — Notification Addresses February 5, 2014 Version 1. Air Pollution Control Division Colorado Department of Public Health and Environment Air Pollution Control Division Operating Permits Unit APCD-SS-B1 4300 Cherry Creek Drive S. Denver, CO 80246-1530 ATTN: Matt Burgett 2. United States Environmental Protection Agency Compliance Notifications: Office of Enforcement, Compliance and Environmental Justice Mail Code 8ENF-AT U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 502(b)(10) Changes, Off Permit Changes: Office of Partnerships and Regulatory Assistance Mail Code 8P -AR U.S. Environmental Protection Agency, Region VIII 1595 Wynkoop Street Denver, CO 80202-1129 Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 111 APPENDIX E — Permit Acronyms Listed Alphabetically: 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 MMBtu/hr FR - Federal Register g - Grams Gal - Gallon GPM - Gallons per Minute HAP - Hazardous Air Pollutants 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 NSPS - New Source Performance Standards OM&M - Operating, Maintenance and Monitoring (Plan) P - Process Weight Rate in Tons/Hr Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution. Control Division Colorado Operating Permit Permit Acronyms Appendix E Page 112 PE - Particulate Emissions PM - Particulate Matter PMIo - Particulate Matter Under 10 Microns PSD - Prevention of Significant Deterioration PTE - Potential To Emit RACT Reasonably Available Control Technology 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix F Page 113 APPENDIX F — Permit Modifications DATE OF REVISION TYPE OF REVISION SECTION NUMBER, CONDITION NUMBER DESCRIPTION OF REVISION Operating Permit 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix G Page 114 APPENDIX G — Fuel Allocation *The methods outlined will be used to calculate fuel use for Units S009 and S011 A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design Rate-II-Hrs. of Operation] X [Facility Fuel Use for Month — Fuel Use for Units S002 + S003 + S004 + S0051 [Sum of Numerator for Each Piece of Equipment] Unit Number Fuel Design Rate S009 17.5 MMBtu/hr S011 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 115 APPENDIX H — Compliance Assurance Monitoring Plan I. Background a. Emission Unit Description: S002 — Delacquering Kiln — The kiln bums 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 PM,o (S006) 4.1.1 11.90 tons/year Bag leak detection system HAPs 0 8 tons/year any single 2Htons/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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 116 II. Monitoring Approach 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 HC1 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 delacquering 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(f) (Section II, Condition 11.17). 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT Air Pollution Control Division Colorado Operating Permit Permit Modifications Appendix H Page 117 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 HC1 emission. The Secondary Aluminum Production MACT requires that delacquering 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 96OPWE125 First Issued: 11/1/1999 Renewed: DRAFT TECHNICAL REVIEW DOCUMENT For DRAFT RENEWAL OF OPERATING PERMIT 96OPWE125 Golden Aluminum, Inc. Weld County Source ID 123-0089 March 2016 DRAFT Operating Permit Engineer: Operating Permit Supervisor review: Field Services Unit review: I. Purpose Nicholas Dummer Matt Burgett Dave Huber This document establishes the basis for decisions made regarding the applicable requirements, emission factors, monitoring plan and compliance status of emission units covered by the renewed Operating Permit. The Operating Permit for this facility was first issued on 11/1/1999, was renewed on 5/1/2010 and was last revised on 12/3/2013 and expired on 5/1/2015. However, since a timely and complete renewal application was submitted, under Colorado Regulation No. 3, Part C, Section IV.C all of the terms and conditions of the existing permit shall not expire until the renewal operating permit is issued and any previously extended permit shield continues in full force and operation. This document is designed for reference during the review of the proposed permit by the EPA, the public, and other interested parties. The conclusions made in this report are based on information provided in the original application submitted on April 29, 2014, comments on the draft permit submitted February — May, 2017], previous inspection reports and various email 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 www.colorado.qov/cdphe/airTitleV. 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 123-0089 Page 1 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 Golden Aluminum, Inc. (the Source) is an aluminum sheet manufacturing plant: Standard Industrial Classification 3353. The Source 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; the shredders have a baghouse for particulate matter (PM) emission control. The shredded aluminum is sent to a delacquering kiln to remove coating; emissions from the kiln are controlled with a thermal oxidizer and a lime -injected baghouse to remove PM, volatile organic compounds (VOC), and hazardous air pollutants (HAP) — a HAP of specific concern is hydrochloric acid (HCI). The shreds are melted in two of three furnaces with prime aluminum and alloying elements; plant scrap is melted in any of the three furnaces, and coated charge may be melted in the furnace sidewells with some limitations. Dross is removed from the furnaces and pressed into crucibles for cooling prior to shipment to another facility for processing. The molten aluminum goes through a series of three degassing boxes where they are agitated with rotors and bubbled with argon and chlorine gas to remove impurities. The gaseous emissions from the melting furnaces and the degassing boxes are vented through a lime -injected baghouse for PM and HAP emission control. The aluminum is solidified at a proprietary caster and milled in a hot mill where it is pressed into a long, continuous sheet and then coiled; PM from the hot mill is controlled with a centrifugal separator. The coils are loaded onto large carts and put into an annealing furnace which changes the molecular structure and tensile strength to specifications. The coils are removed from the annealing furnace and decoiled and milled to thickness specifications in a cold mill; the aluminum is sprayed with an atomized, mineral oil coolant in the mill, and the overspray is vented to a purifier for VOC emissions control. The aluminum sheet is pulled through a tension leveler which removes imperfections caused by the milling process. It is then washed and either re -coiled, packaged, and shipped, or sent to the coating line to add a coat to customer specifications; VOC emissions from the coating line are controlled with a thermal oxidizer. The coated aluminum is cured in a multiple - oven process, and washed with potassium hydroxide (KOH) and/or sodium hydroxide (NaOH) (wastewater from the process is treated on site to permitted levels before drainage to a municipal treatment facility or shipping of hazardous materials as required). After the wash line the aluminum is lubricated (if applicable), re -coiled, packaged and shipped. Per customer specifications, the aluminum may be cut into thinner strips prior to packaging and shipping. The facility has a small emergency generator for lighting and air compressors. 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 the 8 -hr ozone standard and is part of the 8 -hr Ozone Control Area as defined in Colorado Regulation No. 7, Section II.A.1.There are no other Operating Permits associated with this facility for purposes of determining applicability of Prevention of Significant Deterioration regulations. 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. 123-0089 Page 2 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 Based on the information provided by the applicant, this source is categorized as a synthetic minor stationary source for both NANSR and PSD as of the issuance date of this permit. [NANSR] Any future modification at this facility which is major by itself (i.e. a potential to emit of ≥100 tons per year (TPY) of either VOC or oxides of nitrogen (NOx)) may result in the application of the NANSR review requirements. [PSD] Any future modification at this facility for which is major by itself (potential to emit of ≥250 TPY) for any pollutant listed in Colorado Regulation No. 3, Part D, Section II.A.44 for which the area is in attainment or attainment/maintenance may result in the application of the PSD review requirements. Actual and potential emission summaries from the facility are summarized on pages 4 and 5. 123-0089 Page 3 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 Actual emissions at the facility are as follows (obtained from the July 22, 2015 inspection by the Division, showing the largest values of the rolling 12 -month averages): Emission Unit Actual Emissions (tons/yr) PM PM10 NOx CO VOC Lead HAPs S001 — preheaters, shredders, cyclones 2.41 2.41 2.78 (largest individual (surface coating constituent)) 6.01 (facility - wide total) S002 — delaquering kiln 0.42 0.42 1.65 1.19 0.59 0.08 S003 -S005 — Melters # 1 thru 3 17.63 17.63 16.63 13.97 3.78 S006 — Melt Area Baghouse 5.71 5.71 S008 — Hot Mill 1.83 1.83 S009 — Two (2) Annealling Furnaces 0.48 0.48 1.69 1.42 2.31 S010 — Cold Mill 6.03 6.03 43.68 S011 — Coil Coating Line 0.16 0.16 2.07 1.77 6.04 S012 — Emergency Engine* N/A N/A N/A N/A N/A Insignificant Activities* N/A N/A N/A N/A N/A Total 34.67 34.67 22.04 18.35 56.4 0.08 6.01 *Tracking emissions from the emergency engine and insignificant activities was not required until this issuance. Potential emissions at the facility are as follows: Emission Unit Potential (Permitted) Emissions (tons/yr) PM PM,o NOx CO VOC Lead HAPs S001 — preheaters, shredders, cyclones 9.8 9.8 See Table on Page 5 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 28.4 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 11 S012 — Emergency Engine 0.11 0.11 3.91 0.9 0.1 Insignificant Activities 0.9 0.9 12.0 9.8 0.6 Total 77.14 77.14 64.78 50.89 93.63 0.32 12.67 123-0089 Page 4 of 17 Potential Total HAP Emissions (tons/yr) Emission Unit C • O 0) M M M CO O O O N CO CO N CO O O N O O • V O V O O O O O N O O N C N CO C > U C Q co O O O O O O O O O O O O O O M O N O O O O O O O O O O O C O O O N O O O O O O N 0 U O CO O N co co O r -- as O M O N O co O O O O N O N_ N CO C) C) = O Q) (I) C O r- 6 M co O O O O O O O O CO O O a) U) O L O O) 0 03 U)(0 a) 2 M co O O LO N O CO O CO N M (C) O O N u) N M 7D - o (I) O N O O O O O O O M O O C N 0 C O C CO UO a) 0 O O O O co M O O O N O O O co O co O O O co O O U) ✓ N -o c CO N O a 2 (0 a) 2 l _ U 2 methyl ethyl ketone a) C a) ethyl benzene O C CO L a) 0 7 N a) C co N L a) T L a) 2 o a) C a) N a) .n a) C m (7, O F CO N O O CO C) C) N C 0 U a) U) O U co C O N N E a) N a C O a) a) a) a) a) C) C C 7 L a) 7 O a 2 (-4 O CV N O C O v' Ma) M w N 0a oQ c • E o O O_ To:' U 'O_ a7 d N (O C O U) C A E U N N C Ta) C E - O o a Q N • E C o c N O N w 'E O_ a) = C (q O C O O U N N co ▪ w C) CD C O Q E O • a C C O (0 N M N Qa) L Ill. Applicable Requirements Hazardous Air Pollutants (HAP) The facility is a synthetic minor source of HAP. The Source is subject to MACT RRR for D/F emission limitations. A breakdown of emitted HAP is displayed in the table on page 4 of this TRD. Emission factors for HAP come from AP -42 and stack testing from the original synthetic minor construction permit application from 2002. Note that the Source is not required to obtain a Title V permit as it maintains federally enforceable HAP (and VOC) limitations (8 tpy of any individual HAP, and 20 tpy of total facility HAP, <100 tpy VOC). The Source has elected to remain in the Title V program due to the comparative ease by which Title V permits are modified compared with an alternative synthetic minor construction permit. 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production The Source is not a major source of HAP and thus is only subject to the requirements for dioxins and furans (D/F) in this Subpart (40CFR Part 63, §63.1500(f)). Units S002 (delacquering kiln), S003 (Secondary Aluminum Processing Unit (SAPU) — furnace), S004 (SAPU — furnace), S005 (SAPU — furnace), and S006 (SAPU — in -line fluxers) are subject to the requirements of Subpart RRR. All furnaces are defined as Group 1 furnaces per §63.1503 as they all use in -line reactive fluxing (chlorine and argon demagging/degassing). The requirements of §63.1505(j) do not apply to the Source because they only apply to major sources of HAP; i.e. the requirements are for HCI and PM and not for D/F and the Source is only subject to the D/F requirements of this Subpart. Per §63.1511(e), the Source is not subject to performance testing every 5 years as it is not a major source of HAP emissions. Per the revision to the rule, §63.1511(g)(5) allows the Source to conduct new performance testing to establish different operating parameter values. The only shared ductwork between emissions units is between the sidewells and in -line fluxers which vent to a shared baghouse, as such, this SAPU may be tested in accordance with §63.1511(h) and no emission units may be tested in accordance with §63.1511(i). Note that the performance testing required for SAPU in §63.1512(j) is not required as it is covered under the testing for group 1 furnaces in §63.1512(d). This is allowed under §63.1505(k)(5) which allows that the owner or operator of a SAPU at an area source may demonstrate that each emission unit in the SAPU is in compliance with the Subpart RRR requirements as required under §63.1505(i)(3) for group 1 furnaces (this is described in permit condition 11.4). However, since there are no D/F emission requirements for in -line fluxers, compliance with the SAPU emission requirement is assumed so long as emissions from the group 1 furnace are in compliance with Condition 11.35. The amendment to Subpart RRR, published in the Federal Register on June 13, 2016, added a requirement to include a malfunction report under §63.1515(b)(4). This requirement has been added to the permit, as appropriate. The requirements for the total reactive flux injection rate under §63.1510(j) currently only apply to solid fluxes added to the Group 1 furnaces (sidewell melters). There are no gaseous or liquid fluxes used for Group 1 furnaces- the in -line fluxers only serve 123-0089 Page 6 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 Group 2 furnaces at this time. The requirements for gaseous and liquid fluxes were left in the permit in the event that Source decides to use the provisions of MACT RRR to change the classification of the Group 2 furnaces to Group 1 furnaces which could affect the requirements for flux injection via the in -line fluxers under §63.1510(j). 40 CFR Part 60, Subpart TT — Standards of Performance for Metal Coil Surface Coating The coil coating line (S011) is subject to the requirements of Subpart TT as it is an applicable source as described in 40 CFR Part 60, §60.460(a) & (b). It is subject to the requirements in the Subpart for a facility that continuously uses an emission control device; which for this unit is a thermal oxidizer. The provisions of the Subpart require that the thermal oxidizer be operated according to the parameters by which it was originally tested during an initial performance test. This test was performed in July 1996 at a temperature of 1317°F with a VOC destruction efficiency of >99.9%. The thermal oxidizer shall be operated at a temperature of 1267°F or higher (40 CFR Part 60, §60.464(c)). 40 CFR Part 60, Subpart S - Standards of Performance for Primary Aluminum Reduction Plants This facility is not subject to NSPS Subpart S because it does not manufacture aluminum by electrolytic reduction. 40 CFR Part 63, Subpart ZZZZ — National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines The emergency engine at the facility is now subject to Subpart ZZZZ requirements. These requirements were added in Condition 9.5. The engine is classified as existing, stationary, diesel -fuel fired, compression ignition, emergency RICE greater than 500 HP. It is not subject to NSPS IIII because it was not constructed or modified after July 11, 2005 (40 CFR Part 60, §60.4200(3)), thus it is not exempt from the requirements in Subpart ZZZZ under §63.6590(c). The engine in Condition 9 is only subject to work practice standards under MACT ZZZZ. Note that §63.6640(f)(2)(ii) and (iii) have been remanded and vacated and as such were not included in this permit. §63.6640(f)(4)(ii)(A) through (E) has been voluntarily remanded but not vacated and has been included in the permit, as applicable. Colorado Regulation No. 7 The Source is not subject to Section X for the Use of Solvents for Degreasing and Cleaning as it does not use cold cleaners, non-conveyorized vapor degreasers, or conveyorized degreasers. The Source does use solvents for cleaning the coil coating process S011 wherein solvents are flushed through the coating applicator lines to remove residual coating before changing the type of coating. The used solvent is collected and treated on site before being disposed of as hazardous waste or flushed to the municipal water treatment facility, as applicable, per their wastewater permit. However, this process does not fit the requirements as an applicable process for Section X and is thus not subject to said requirements. 123-0089 Page 7 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 Section IX for Surface Coating Operations is applicable to the Source and as such the requirements were added to the permit. Note that the performance test for add-on control devices required under IX.A. was satisfactorily conducted in July, 1996. Since the Source has a specific requirement in Colorado Regulation No. 7 the Alternative Control Plan and Test Methods language from Section II.D was also added to the permit. The Source is subject to Section III for General Requirements for Storage and Transfer of VOC and Section V for Disposal of VOC. The Source uses solvents for cleaning and has two large storage tanks of mineral oil which is used as a lubricant for the milling processes. Despite the low vapor pressure of the mineral oil (0.034 mmHg, 0.0045 KPa), it is considered a VOC as it is not listed as a negligibly reactive VOC in the Common Provisions of Colorado Regulation No. 7. These requirements apply to the mineral oil tank and are covered in Section IV — General Conditions of the permit. The Source is not subject to Section IV for Storage of Highly Volatile Organic Compounds as they have told the Division that they do not use any HVOC (vapor pressure > 750 torr (11 psia @ 20°C, 75.99 KPa)). Reasonably Available Control Technology (RACT) VOC emitting units are not subject to RACT under Colorado Regulation No. 7 since they have a federally enforceable permit condition which limits the VOC emissions to less than 100 tons per year (tpy) (Colorado Regulation No. 7, II.C.1.a.(iii)). Further, these units are not subject to RACT under Colorado Regulation No. 3 because none of the units were new or modified after the designation of the area as non -attainment of ozone in 2008 (Colorado Regulation No. 3, Section III.D.2.). Accidental Release Program — 112(r) Section 112(r) of the Clean Air Act mandates a new federal focus on the prevention of chemical accidents. Sources subject to these provisions must develop and implement risk management programs that include hazard assessment, a prevention program, and an emergency response program. They must prepare and implement a Risk Management Plan (RMP) as specified in the 112(r). 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). Compliance Assurance Monitoring (CAM) 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: 123-0089 Page 8 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 AIRS points: 002 and 016 (emission units S002 — delacquering kiln, and S006 — melt area baghouse) for HAP and PM emissions. Greenhouse Gases The potential -to -emit of greenhouse gas (GHG) emissions from this facility is less than 100,000 TPY CO2e. Future modifications greater than 100,000 TPY CO2e may be subject to regulation (Regulation No. 3, Part A, I.B.44). IV. Modifications Requested by the Source The source's requested modifications were addressed as follows: Section II — Specific Permit Terms • Condition 2 — The Source installed a gas usage meter at the delacquering kiln afterburner (S002). They have requested a change to the fuel allocation in Appendix G to remove the allocation for S002 and instead use a fuel meter with monthly monitoring. This request was reviewed and granted. The table in Condition 2 has been updated; the language in Condition 2.3 has been updated. • Condition 3 — The Source provided an updated APEN to reduce the requested NOx limit from the melters from 70.6 tpy to 28.4 tpy. They do not anticipate that this will cause an issue due to the low oxygen participation level in the melters. No changes to the emission factors or throughput were requested as part of this change. • Condition 8 — The Source provided an updated APEN to reduce the requested VOC limit from the coil coating line from 14 tpy to 11 tpy. Their historical mass balance calculations have been such that they do not anticipate any issues with this change. No changes to the emission factors or throughput were requested as part of this change. Appendices • Appendix G was modified to accommodate the change requested for unit S002. The fuel allocation for the unit was removed and S002 was added to the equation as appropriate for calculating the fuel use for units S009 and S011. V. Other Modifications In addition to the source requested modifications, the Division has included 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 renewal. These changes are as follows: Page Following Cover Page 123-0089 Page 9 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 • It should be noted that the monitoring and compliance periods and report and certification due dates are shown as examples. The appropriate monitoring and compliance periods and report and certification due dates will be filled in after permit issuance and will be based on permit issuance date. Note that the source may request to keep the same monitoring and compliance periods and report and certification due dates as were provided in the original permit. However, it should be noted that with this option, depending on the permit issuance date, the first monitoring period and compliance period may be short (i.e. less than 6 months and less than 1 year). • Modified the language concerning postmarked dates for report submittals to reflect the Division's current standard language. Section I — General Activities and Summary • Revised the facility description based on conversations with the Source to better represent the process train and the control devices used at the facility. Section II — Specific Permit Terms S001 — Prebreakers, Shredders, and Particle Separator Drop Out Box with Baghouse • Condition 1.1.3.3 — This was reworked to clarify that the processes that vent to the baghouse must be halted during necessary repairs. The previous 1.1.3.4 was merged into this condition to improve clarity. • Condition 1.5 was added for HAP emissions to clarify the HAP requirements in the permit and associate them with the appropriate emissions units. S002 — Delacquering Kiln with Multicyclone, Thermal Oxidizer, and Lime Injected Baghouse • Condition 2 (where necessary) — Changed "aluminum consumption" to "aluminum throughput" for clarity of process as aluminum is not consumed by the delacquering kiln. • Condition 2.1.4.3 — This was reworked to clarify that the processes that vent to the baghouse must be halted during necessary repairs. The previous 2.1.3.4 was merged into this condition to improve clarity. • Condition 2.8 was added for HAP emissions to clarify the HAP requirements in the permit and associate them with the appropriate emissions units. S003, S004, and S005 — Melters #1, #2, and #3 (Main Hearths) • Condition 3.3 — Updated the formatting for clarity of calculations. Added 3.3.1 for VOC calculation and 3.3.2 for CO calculation. • Condition 3.6 — This condition was separated into subsections to improve clarity of the applicable requirements. There were no changes to the specific requirements. 123-0089 Page 10 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 • Condition 3.7 — This condition was separated into subsections to improve clarity of the applicable requirements • Condition 3.8 — Subpart RRR requirements have been moved to Condition 10 in their entirety due to changes since the last issuance. This Condition was modified to reference those requirements. S006 — Melt Area Baghouse • Condition 4.1.3.3 — This was reworked to clarify that the processes that vent to the baghouse must be halted during necessary repairs. The previous 4.1.3.4 was merged into this condition to improve clarity • Condition 4 — The table description was updated to include the degassing units. These degassers (defined as in -line fluxers by Subpart RRR) have always been vented to the same baghouse as the melter sidewells and are responsible for a large percentage of the HCI emissions from the facility. This description was updated to clarify the operational process. • Note that Condition 4.6.1 originates from the methodology of the performance test wherein only one of the furnaces was processing coated charge at the time of the test. S011 — Coil Coating Line with Thermal Oxidizer • Condition 8.11 — The coil coating line is subject to the requirements of Colorado Regulation No. 7. This condition was added which includes all applicable requirements as described by the regulation. The applicable VOC limitation is less stringent than what is required by Condition 8.5 for NSPS Subpart TT; however, there are additional, daily recordkeeping requirements in Regulation No. 7 that were not included in NSPS Subpart TT so the requirements could not be streamlined out of the permit. Additionally, EPA Reference Method testing shall be performed per Condition 8.11.2 unless the provisions for manufacturer's composition records are adequately maintained per Condition 8.11.5. S012 — Compression Ignition Emergency Engine • Condition 9 — This condition was added to the permit. This emergency generator was on the insignificant activities list, but is now required to be in the main body of the permit due to MACT ZZZZ requirements associated with its operation. Per discussion with the Source, this engine is classified as an emergency engine as defined in MACT ZZZZ. The relevant applicable requirements are described in the condition. Note that this engine predates NSPS 1111 applicability. o The emission factors associated with this engine were taken from AP -42, Table 3.4-1 using the lb/MMBtu emission factors, multiplied by 0.1387 MMBtu/gallon of diesel (standard energy content of the fuel). 123-0089 Page 11 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 o This engine currently does not have an APEN associated with its use and shall not require one until the APEN de minimis level of 1 tpy has been reached. This will occur when the engine has operated for 63 hours per year. Condition 9.1 addresses this for the clarity of inspections. o The opacity conditions are standard per Colorado Regulation No. 1. o The engine may only be operated using diesel fuel. Any change in the fuel use shall necessitate the re -opening of the permit to revise the emission factors. o Condition 9.4 — The Colorado Regulation No. 1 requirements for 30% opacity for certain operational activities are not applicable with the exception of during startup. Fire building, cleaning of fire boxes, and soot blowing do not apply to diesel engines. Further, cleaning of control equipment does not apply because the engine is not controlled. Additionally, process modification is unlikely to occur. o Condition 9.5 outlines the Subpart ZZZZ requirements for this engine. Notable requirements for this engine include work practices and recordkeeping. This engine is required to comply with the restrictions placed on it for the emergency engine designation per the Subpart. o Note that the Colorado Regulation No. 1 SO2 requirements were subsumed under the MACT ZZZZ requirement to only burn ULSF diesel fuel. 40 CFR Part 63, Subpart RRR — National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum Production • Condition 11 (previously. Condition 10) — This condition was updated to include changes to MACT RRR as described in the final rule in the Federal Register dated: September 18, 2015. Changes to this condition include: o Updating the Federal Register publication date. o Added a sentence that clarifies that the Source is only subject to D/F requirements in Subpart RRR. o Condition 11.1 — Corrected the afterburner temperature to 760°C from 750°C as is described in the rule (the 1400°F was correctly listed in the previous permit, this is not a change of condition). o Condition 11.2.3 — This condition was removed as the facility does not perform reactive fluxing in the hearth or in the sidewell, but in in -line fluxers. o Condition 11.3 — This condition was expanded to include more of the rule language for increased clarity of applicable requirements. 123-0089 Page 12 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 o Condition 11.3 — Changed "for reach secondary aluminum production facility" to "for each secondary aluminum processing unit at a secondary aluminum production facility" to match the language in the rule. This change does not affect the results of historical testing. o Condition 11.4 — This was previously tacked onto Condition 11.3, it was separated to increase clarity of applicable requirements. o Condition 11.5 — This condition was not included in the previous permit as it was implied with the reference in 11.3, it was included to increase clarity of applicable requirements. o Condition 11.7.1 — §63.1506(c)(1) was changed in the most recent Federal Register. It was originally, "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."" It was changed to, "Design and install a system for the capture and collection of emissions to meet the engineering standards for minimum exhaust rates or facial inlet velocities as contained in the ACGIH Guidelines (incorporated by reference, see §63.14)." o Conditions 11.8.3.1 & 2 — These conditions, which were contained in the previous Condition 11.8.3, were added to increase clarity of applicable requirements. o Condition 11.9.4 — Changed the condition to match the change in the rule language from, "maintain the lime feeder setting at the same level established during the performance test," to, "maintain the lime feeder setting at or above the level established during the performance test." This same change was required for Condition 11.10.3. o Condition 11.10.6 — Condition added to this section as it was added to the most recent issuance of the Subpart. o Condition 11.12 — This condition was expanded to include all relevant language from the rule text to increase clarity of applicable requirements. o Condition 11.13 — Corrected a reference typo from §63.2506(b) to §63.1506(b). o Condition 11.14 — This condition was expanded to include new language and requirements per updates to Subpart RRR. There is a new requirement for the demonstration of compliance for the capture/collection system that includes either a yearly flow rate measurement or a permanent total enclosure. o Condition 11.15 — This wording for this condition was slightly changed to reflect the current rule language. This change does not affect the requirements of this condition. 123-0089 Page 13 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 o Condition 11.16 — Updated the language to reflect the language in the rule. This change allows the Source to elect to use a COMS system instead of a bag leak detection system. Note that the requirements for scrap shredders in §63.1510(f) only apply to major sources (see §63.1500 for unit applicability). Some of the references in this section were erroneously labeled as §63.1506 when they should read §63.1510, this was corrected where applicable. o Condition 11.16.1.2 — This condition was changed to reflect the change in the rule language. The requirement for operations has been simplified to per manufacturer's operating instructions. o Condition 11.16.2 — This condition was added to reflect the language related to COMS usage in the rule text. This is an optional applicable requirement where either Condition 11.16.1 or 11.16.2 may satisfy the requirements for baghouse operation. o Condition 11.17.2 & 3 — These conditions were expanded to include the requirements listed in the rule text instead of incorporating them by reference for increase clarity of applicable requirements. o Condition 11.19 — The references in these conditions were erroneously written as §63.1506, they were corrected to §63.1510. o Condition 11.19.4 — This condition is new as a result of revisions to the rule text. The Source is now required to verify that the lime injection rate is no less than 90% of the injection rate during the most recent performance test. o Condition 11.19.1 — This condition was broken into Conditions 11.19.1.1, 2, and 3 to better reflect the rule language. Conditions 11.19.1.2 and 3 are new options for the demonstration of free -flowing lime. o Condition 11.20.4 — This condition was updated to match the updated rule language. Specifically, this was modified for intermittent solid flux addition recordkeeping. o Condition 11.21.1 — This condition was updated to match the updated rule language. Specifically, this was modified to require measurement of the molten metal by physical methods if visual observation is not possible. o Condition 11.21.2 — Corrected the reference to match the rule from §63.1506(m)(6) to §63.1506(m)(7). Note that this was a change in the rule text and not an erroneous reference in the previous issuance of the operating permit. o Condition 11.23 — This condition was added to reflect the rule. This condition was referenced in the previous issuance of the permit, but was added as a new condition to the current permit to increase clarity of applicable requirements. Specifically this condition addresses calculation 123-0089 Page 14 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 of D/F from group 1 furnaces. The Source has historically complied with this requirement by way of §63.1510(u) and may continue to do so; however, this condition reflects an alternative method for compliance demonstration should the Source elect to do so. Note that the addition of this condition shifted the subsequent numbering in Condition 11. o Condition 11.26 — This condition was reworded to avoid potential paraphrasing issues. It now matches the rule language. Note that there was no change in the rule language for this section. o Condition 11.27 — This condition was modified to reflect the change in the rule language. This rule change clarifies that the performance testing requirements are subject to Division requirements as well as the rule requirements. Future performance testing must first undergo Division approval prior to testing to verify that the rule requirements are met to sufficiently demonstrate compliance. o Condition 11.28 — The language was changed to better clarify and reflect the rule language. Note that the initial performance testing requirements are added by reference and they have changed from the previous issuance of the permit; however, initial performance testing has been performed and will not be required again. New or reconstructed units may be required to comply with the new requirements in §63.1511(b). o Condition 11.29 — Clarified the language to better reflect the rule language. There were no changes to this applicable requirement. o Condition 11.31 — This language was expanded to prevent potential paraphrasing issues and to increase the clarity of applicable requirements. Note that the only change to this rule was the addition of §63.1511(g)(5) which allows the Source to conduct new performance tests to establish different operating parameter values. o Condition 11.32 — This condition was added to address the shared ductwork with the in -line fluxers and sidewells (together SAPU) which vent to a shared baghouse. This is not a change of applicable requirements. Note that subsequent numbering in Condition 11 has been shifted. o Conditions 11.44 and 11.45 — These conditions were added due to the revision to Subpart RRR for changes in furnace classification as described in §63.1514. o Condition 11.48 — This condition was removed as the original SSM reporting requirement in §63.1516(a) was deleted. Note that the subsequent numbering in Condition 11 has been shifted. o Condition 11.48 — The language in this condition was updated to match the language in the Subpart to prevent paraphrasing issues. There are no changes to the applicable requirements. 123-0089 Page 15 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 o 11.49.4 — This condition was added to the permit as a new requirement based on the updates to Subpart RRR published in the Federal Register on June 13, 2016. o Condition 11.50 — This condition was added as it was added to Subpart RRR. This replaces the previous SSM reporting requirements. o Condition 11.51 — This condition was added as it was added to Subpart RRR. o Condition 11.48.3.1 — This condition was added as it was added to Subpart RRR. This clarifies requirements for the reporting of performance tests. o Condition 11.49 — An omission of some of the rule language was corrected: updated "required by 40 CFR Part 70" to "required by 40 CFR Part 70 or 71." This was not a change in the rule, but an error in the previous permit. This does not affect the Source as they are not required to have any reports under 40 CFR Part 71 (federal operating permits). Further, the formatting of this condition was changed to match the formatting in the rule to clarify the applicable requirements. o The reference in the section heading for "Applicability of General Provisions" was corrected from §63.1516 to §63.1518 40 CFR Part 63, Subpart CCCCCC — National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities • A previously listed insignificant gas tank was moved to the main body of the permit as it is subject to MACT CCCCCC (§63.11111(b)). These requirements are now reflected in Condition 12. A TANKS model of this tank showed that the tank was below de minimis levels for APEN reporting. Insignificant Activity Tracking • Condition 13 was added for insignificant activity tracking. New recordkeeping requirements were added to verify that the Source does not exceed 100 tons per year of VOC emitted due to emissions from insignificant activities. This must be verified on a yearly basis. Should this condition be violated, the Source may be subject to RACT requirements as a major source of VOC. Compliance Assurance Monitoring • Condition 14.1.4 — The requirements for reporting and recordkeeping were updated to match the current version CAM language. Other Changes • There was a typo in Section Ill, Condition 3 for stream -lined conditions where the permit condition was referenced in Section I when it was supposed to reference Section II. 123-0089 Page 16 of 17 Golden Aluminum, Inc. Operating Permit No. 96OPWE125 Technical Review Document — Operating Permit: Renewal 3 • Where applicable — The unit summary tables were updated to include Colorado Regulation No. 7 and HAP. • Where applicable — Updated the AP -42, Section 1.4 for natural gas combustion publication date from 3/98 to 7/1998. The emissions factors were verified to be the same. • Added table captions to all tables in the permit for increased ease of cross- referencing and clarity of presentation. Section III — Permit Shield • There were no changes to this section. Section IV — General Permit Conditions • There were no changes to this section. Appendices • The list of insignificant activities was updated by the Source. There were a number of tanks that are now subject to Colorado Regulation No. 7 requirements for storage and transfer of VOC as described in Section IV, Condition 29. The appropriate references were made. The emergency engine that was listed as insignificant has been moved to the main body of the permit in Section II as it is subject to MACT ZZZZ. The lime silos which feed the lime - injected baghouse were added to the list (241,040 lb lime added to silos/yr, 2.2 lb PM/ton lime added, vented to the baghouse at 99% removal efficiency). • Updated Appendices B and C (Monitoring and Permit Deviation Reports and Compliance Certification Reports) to the newest versions (8/20/2014). • EPA's mailing address was revised (Appendix D). • Cleared the list of modifications from Appendix F related to the previous issuance. • Appendix G was updated per the modification request by the Source to remove the fuel allocation for the delacquering kiln (S002). The equation was updated as appropriate. 123-0089 Page 17 of 17 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION OPERATING PERMIT RENEWAL SUMMARY PERMIT NUMBER: 96OPWE125 APPLICANT: Golden Aluminum, Inc. REVIEW ENGINEER: Nicholas Dummer AIRS ID #: 123/0089 DATE: May 8, 2017 SOURCE DESCRIPTION Golden Aluminum, Inc. has applied for renewal of their Operating Permit issued for their facility located 1405 East 14th Street, Fort Lupton, CO 80621 in Weld County. The facility performs secondary aluminum processing, converting aluminum scrap into clean aluminum coils; it is classified under SIC 3353. The facility is located an area designated as non -attainment for the 8 -hour ozone standard. There is only one Operating Permit associated with this facility. This source is categorized as a Non -Attainment New Source Review (NANSR) minor stationary source and a minor stationary source with respect to Prevention of Significant Deterioration (PSD) requirements. There are no affected states within 50 miles of this facility. Rocky Mountain National Park is a Federal Class I designated areas within 100 km of this facility. The emission units covered under this permit are not subject to the Accidental Release provisions of section 112(r) of the Federal Clean Air Act. Two of the emission units at this facility are subject to the Compliance Assurance Monitoring (CAM) requirements in 40 CFR Part 64: the delacquering kiln, and the hot melt area baghouse. FACILITY EMISSION SUMMARY Emission Unit Potential (Permitted) Emissions (tons/yr) PM PM10 NOx CO VOC Lead HAPs S001 — preheaters, shredders, cyclones 9.8 9.8 See technical review document for details S002 — delaquering kiln 1.54 1.54 4.97 3.33 2.28 0.32 S003 -S005 — Melters # 1 thru3 37.6 37.6 28.4 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 11 S012 — Emergency Engine 0.11 0.11 3.91 0.9 0.1 Insignificant Activities 0.9 0.9 12.0 9.8 0.6 Total 77.14 77.14 64.78 50.89 93.63 0.32 12.67 EMISSION SOURCES The following discussion identifies the changes that were made in the renewal permit. The requirements for Colorado Regulation No. 7 were updated in the permit, as applicable. The requirements of MACT RRR for secondary aluminum processing was updated to reflect the current version in the Federal Register. Requirements for gasoline dispensing under MACT CCCCCC were added for a small gasoline tank at the facility. MACT ZZZZ requirements were added for an emergency generator at the facility. ALTERNATIVE OPERATING SCENARIOS No changes were made to the alternative operations scenarios as a result of this renewal. INSIGNIFICANT ACTIVITIES The list of insignificant activities was updated, as appropriate. Additionally, the requirement to track the emissions of insignificant activities for VOC emissions was added to verify that the facility remains under major source thresholds. PERMIT SHIELD The permit shield was not changed as a result of this renewal. APR292014+ April 23, 2014 Colorado Department of Public Health & Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 303-692-3267 RE: Operating Permit Renewal for Golden Aluminum Inc., 96OPWE125 Dear Ms. Joyce Golden Aluminum Inc. wishes to continue to operate within the limits defined by our Title V Operating Permit 96OPWE125. No changes are being requested for our Operating Permit except as identified below. Golden Aluminum has recently installed gas usage metering capability at our delacquering kiln afterburner (S002). This addition will allow a more accurate gas usage measurement than our current Appendix G Fuel Allocation calculation. With this change, only our annealers (S009) and coatingline incinerator (S011) will require Fuel Allocation calculation as found in Appendix G. The enclosed Appendix G Fuel Allocation calculation has been amended to reflect the change. Golden Aluminum Inc. is not a major source of greenhouse gas (GHG) emissions. Sinc Don Fbrchette Environmental Engineer Golden Aluminum Inc. Operating Permit Application FORM 2000-800 Colorado Department of Health 09-94 Air Pollution Control Division CERTIFICATION FOR STATE -ONLY CONDITIONS Facility Name: Golden Aluminum Inc. Facility Identification Code: CO 96OPWE125 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 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 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 lmowingly, 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 25-7 provisions of § 122.1, C.R.S. Printed or Typed Name Chris Moellers Title Chief Technical Officer Sign _lire Date Signed SEND ALL MATERIALS TO: COLORADO DEPARTMENT OF HEALTH APCD-SS-B1 4300 CHERRY CREEK DRIVE SOUTH DENVER, CO 80246-1530 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) 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 § 25-7 122.1, C.R.S. Printed or Typed Name Chris Moellers Title Chief Technical Officer Si nature Date Signed , Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. 2. S002 - Delaquering Kiln w/ Multicyclone, Thermal Oxidizer, and Lime Injected Baghouse Page 8 Parameter Permit Number Limitations Short Term Long Term Compliance Emission Factor Monitoring g 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 Monthly PKo NA 1.54 tons/yr Operating: 0.08 lb/ton Al Idle: 7.6 lb/MMscf Control Equipment Maintenance See Conditions 2.1.3 through NOx NA 4.97 tons/yr Operating: 0.24 lb/ton Al Idle: 100 lb/MMscf 2.1.5 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 meter 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 µg 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: 5/1/10 Last Revised: 12/3/13 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 10 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 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 Operating Permit Number: 96OPWE 125 First Issued: 11/1/99 Renewed: 5/1/10 Last Revised: 12/3/13 Air Pollution Control Division Colorado Operating Permit Permit # 96OPWE125 Golden Aluminum, Inc. Page 11 modified under the provisions of Section I, Condition 1.3). The natural gas consumption rate shall be determined using the fuel meter 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. 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. 1. (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: 96OPWE 125 First Issued: 11/1/99 Renewed: 5/1/10 Last Revised: 12/3/13 Air Pollution Control Division Colorado Operating Permit Fuel Allocation APPENDIX G Fuel Allocation *The methods outlined will be used to calculate fuel use for Units S009 and S011 A) FUEL ALLOCATION TO INDIVIDUAL UNITS For Each Piece of Equipment, Fuel Use = [Fuel Design RatelfHrs. of Operation] [Sum of Numerator for Each Piece of Equipment] Appendix G Page 1 X [Facility Fuel Use for Month — Fuel Use for S002 + S003 + 5004 + S005] IUnit Number I Fuel Design Rate S009 17.5 MMBtu/hr S011 26.1 MMBtu/hr 1 *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. 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It CO 0 .0 O d CO CO 0 00 O .0 0. 0 a 0 O U O J 0 0 .q 00 0 V 0) td) Environmental Engineer Don Forchette Renewal 2014 CDPHE APEN S002up (2).doc M 0 O N a) to ^^O 1�1 Renewal 2014 CDPHE APEN S002up (2).doc as 0 0 a Q) u 0 a O 0 0 z N o. a) 0 O 0 O 1) 2 ci w ci Lw r O z J J 0 a Q w J CO Q 0 a NwN w 1 U z 0 z O O a, U a v) 0 N a, ci) a, a, a) a) N C a) C Q 0 co a) 0 N O U) L .Q z 0 96OPWE125 Permit Number: Golden Aluminum Inc. N CO O CO a) a O O d a a) c O O ai E c o Z C O o co Q. J E C o U a 303-654-8366 a) Q z a) C O r a Don Forchette Person to Conta Fax Number: donforchette@goldenaluminum.com E-mail Address: Emission Factor Uncontrolled I Controlled Actual Source Actual Emissions Emissions (lbs/vear) (Ihchicnrl 0 ) 1 z VNI z z `° (° i N co N 0O O O M r O 1.8 LBS/ MMSCF IAP 42 0.075 LBS/MMSCF IAP 42 .0.0021 LBS/MMSCF IAP 42 0.0034 LBS/MMSCF AP 42 10.002LBS/ T PROD LAB TEST 0.020LBS/ T PROD STACK TEST 0.0167LBS/ T PROD ENG CALC & TEST Emission Factor (Include Units) Control Equipment / Reduction (%) Chemical Name HEXANE FORMALDEHYDE BENZENE TOLUENE HAP METALS 0 W `\ ' Chemical Abstract Service (CAS) Number c+ 0 O p tO M V N. aO o OT O O ti V N- 7 O) d) Tt N- () O N C a) To co 0 N N a) a) C O) C w To C () E C a) o O ▪ C w CO CO O 0. 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Q.y.F. m ://www.colorado. -C Form Revision Date: A w O CD 0) Permit Number: 0 O V U a 0 (21 g s a .5 W w a) O a Facility Equipment ID: Y! 0 .O a aC V a) O d CU Ca a) ICI N 0 V z Section 01— Administrative Information .C ' y6. C O C �7 i L O x y C U O d 47 .a E E C. v C0.0 ❑ ❑ Ca r O >' >, 3 t, >7 "C L C .)) V L O L z a. Z - 7 @ Ca O C7' •� o U Oy C a) Q cti v et 7 �i a � 7 yCL 0 .. E O 00 E a ;° y t° a ..0 - o .r 5/ b o n H y U U y 44. W L 0 7 0 0 7 0 0 Cr CT Cr z rz a ❑ ❑ a a a) E Ca Ca Source Name: a) 0 a) yoa U N W Fort Lupton Colorado Source Location: 1405 East 14`h St Mailing Address: Fort Lupton Colorado donforchette@goldenaluminum.com E-mail Address: Ca C b u O 4-. a4z Section 03 — General Information N 00 �-r a) -v 0. Ca a) O 0. a) a) a) U O n 'D a) 2 C 0 U u a) o i U, a L a) Oa) > L vA a) a) Ca c L w N L Ca O L a a)aor C) C -Ly L 1� C 4— >, �t Ca * L n v N 0 E. C b o O D if a) o N E CL 0 a) a, a) O CO C O 0 , 4 a O O. CJ I. 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"O g o o w' O U +r w vi CIC $ .2 pi 9 9 :5,N u .0 S .E a)� .E 1..,0 O b O 0 a0 a > O •a.O c'-‘.4 E g ��i C o .O H 0 C 3 o 0co , a m o 7 c+ O k > W C .g I a) c u r C 0o O E a ow co C..) ¢ 0 ❑ V) Estimation U Method or Emission Factor Source stack test factor a) C) CO rn 0 U W % CO AP -42 AP -42 stack test factor II 23.85 I I AP -42 t d b is e a ove. miccinnc Requested Permitted Emissions4 Controlled (Tons/Year) Uncontrolled (Tons/Year) 37.6 37.6 o N "0 O is cal O 00 Actual Calendar Year Emissions3 Controlled (Tons/Year) 13 •ennrt pollutants Uncontrolled Tons/Year) 15.24 a N 1/) 4- 0 U w a a a) 00 Cd [Q C Control Device Description CO C 0 O a C. 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Company Name: r N (O O CO a) O U N C) C O U 0 U C O 0_ J t O EL L U) w U) O Plant Location: Don Forchette Person to Contact: Fax Number: donforchette@goldenaluminum.com E-mail Address: Emission Factor Emission Factor Uncontrolled Controlled Actual (Include Units) Source Actual Emissions Emissions (Ibs/year) llhs/vaarl i z z z z 1520 (fl N CO O O AP 42 AP 42 AP 42 AP 42 11.8 LBS/ MMSCF 0.075 LBS/MMSCF 0.0021 LBS/MMSCF 0.0034 LBS/MMSCF Control Equipment / Reduction (%) Chemical Name HEXANE FORMALDEHYDE BENZENE TOLUENE Chemical Abstract Service (CAS) Number M . 3A O O 6c72 O i0 N Y N- ch CD a0 O ctual Data Applies: U O C - (U C a) (U U a) a) c .rn c w (U C a) E c a) O N � C w is a A d Q O N O C Q a CU O) a) J c O N a) a a) a) _c L U O • • O (no (U (U a CL Q O a) N .` O L Q T (U O) a) J O CD a 0 CD H Q. U) CU (U (U a Q. Q O a) N O L 3 Q a (U a) a) J C O U) a`) a O a) E CU Z 0 N Form Revision Date: A z w ci O w U I- 0 z z 0 U) U) W Z H D J -J a re W J H a w W I-� U Z 0 O w U z 0 m a) M Q. 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April 14. 2014 Form Revision Da Emission Source AIRS ID: 96OPWE125 Permit Number: S008 Hot Mill Facility Equipment ID: y O C «t ❑ fa 0 n .0 V) K DI 0 0 C u .a .a L. .0 u CO y CC O Cam) Cr • C) y N .0 it .vi u «+ CC 'O i a, a 0 ° 0A ❑ ❑ CO L 4-. C _ h .d q n. o : o L z 7 O Y y d uV 1.4 W d a .a U 3 d w 4) z a o L a, w LL cn I a, a, a, •J• = a a a 0 0 10 a) ❑ ❑ ❑ Change company name Transfer of ownership Section 01— Administrative Information E CC v7 Source Name: 3 Change fuel or equipment 00 7 o 0 cd 0 U N Fort Lupton Colorado Source Location: Change permit limit W C O F ^ > C a. y a C 2 C E y s as W CU u O , C) C 0 .0 •y c C Y, y a) ou Ts .. CLU ' L ... a, . >, R. w b O w n H yu•, R, O a . Z L d o at En c0 aa)- 2 a O E O E Z 01,j W Y u 4. .< u a o �H L 0 a cr a a® ❑® 4.1 00 00 I) 0 U N 1405 East 14th St Mailing Address: Fort Lupton Colorado Section 03 — General Information Cd O. 7 CC 0 u U U 0. u vi u L 0 0 ate) U C 0 L O C O i >, C) u U 0 ELo N) O C a L as a) o a, Ea CO U 5 u to - _0. u O O V 0 C C" V) O L Ca . 7 O a. O 4") •U O ti O • G L '0 a) u CC L°zO 3 C u C O wU no CC C _ let N C) e o" g o u c c o E a Q L O •0 CC 0 0 U O O 00 N S4-4 M M M C Cl N N "Clp, N '47:-.C.' O ..O 'O " H > E M M M 0 O O co > O O O LO .Mi .M.) .M.. C cd • 0 O\ C O u w w _ C t 69 .C E C U L < al ct W .o u 3 E v r u CC ll" izi .� O" CC C CI) ¢' OL a)Ca, sa a, •tea v>> , a) `o .> o o '5 v OL cct C ee C A VM1 A b> o o f a 'Y, '.o o '� cC > U aC L N G C > `CC O E a ,.,., U o0o O U y L a, 0 o O 2m , t.iO Ci a u U.. C.. , C) C O , L,,.". U C y O CL) 'L3 y •O .0 Cr) o iC C U L U > a '0. U •m ,5 Om O C L L E Fes-•, aX)'� �UdvMO LL. dan .cdphe.state.co.us/a APEN forms: h G U V) 0 J C) C) .0 -0 .0 Application statu O z cn %' N ment Information & Material Use Section 04 — Processin 0 z CV z N 0 Manufacturer: COO c4 0 cn 0 €b CC N 0. L .0 r r 00 F 00 00 M b on M Cast Al sheet Hot Band Al Sheet y CO U, S`+ O u U .c .g C C • U 0 o O O L 0 0 h fa. o O. O. CY, Q CLC -b 'O O O >, >; O O C) .) U 0 C o 0 00 C) N U U 0 L01 O o 0 N U b o CC N 0 E 6 0 O EEr t d D. 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A, b a) • O 7,1 V 0) 0 0 Pro Az reNewal 2014 CDPHE form APEN S008up.doc Emission Source AIRS ID: Permit Number: 0 bU 0 0 O C) a) 5 T) 0 ca o. a 7.5 ac.): Facility Equipment ID: Section 01— Administrative Information C .0 a O C. T CO C ❑ 0 .C w N C o C. ) a) W C I- X C "� a v)^ 0 .O ea C co C Mt e O .i co v a) .C C �y oCo .151 61 RI ; w o •C) a. •C U a C bo U H .c .� et a. 0 i! U o o. jz 8 C , ao L •,..,[ ❑ tom, ...., cLa >' o y sa .Y > 3 `' ate) C)) 1- C "O L. s. z L1 s .. co z E° C E O a W, c • >. F °� h y; i a o n. ..4 d 0 p" Ca ro r, d b v rA dc p o ° a) W F ca a, z o z o eo C p 0W� ° CO H L. a r `dc 0. a ) C. P aP. v7 0 y 7 3 7 7 a rz rz ❑ ❑ a ❑ ❑ ❑ E as Source Name: C) C C 0 U Fort Lupton Colorado Source Location: h 00 O� 0 v 1-u 0 El 00 N 1405 East 14th St Mailing Address: Fort Lupton Colorado cC C _ H fl 0 r -o o dz Section 03 - General Information . .U, 'C C Co en C) a C. co" L 0 0 -o a) en C 0 a) O C O u. 00 CO a) a) 3 N 00 3 •1 d ro o Fa v >. � O O L C CO 0 C o C)) C CO o b o 0 O a) 7 O En I✓ 0 Co o w en 0 0 C C CO C) •8 C. 0 C) 0 C O C. U a) ) C- C) C C E 0 WU a At o CO O L = C a O o +� c 0 d. o �a ate) r. 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CO en 0 CO W 00 O� o, 0 ment & Fuel Consumption Information .5 Section 06 — Combustion E 0 z CO a) 0 0 Manufacturer: 0 p0 Company equipment Identification No.: O 6. OA b O ti 3 a) i 'J• U ,b 4 En Y. PLO eso 3Gp Q co x5 O in w N W E cc 00 19.62mmscf(2013) (2)17.5mmscf CO C s O .2 0 a+ CO bc y Y. C "5o O v U o y 0 V y C) or cG 0 c 5 5 O •� H L. O d 4) V 0 0 co, 5 'g W N V a) caIoc,t11'4h 1.38 4.22 Eng Cale, Test&AP42 4.21 3.54 If ted above. xDove ke.g. AM/): LUIS Actual Calendar Year Emissions3 Uncontrolled Controlled Tons/Year (Tons/Year) .40 T Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not lis Annual emission fees will be based on actual emissions reported here. If left blank. annual emission fens will he hasarl O 7 1.45 T 2.10 T N N - ,.. ... ,...� . �.... 0, tin. uuginpu. Emission Factor Uncontrolled Units Basis Control Efficiency (% Reduction) 0 >, = O j a> U c..) Lt., Control Device Description Primary Secondary 0 o a H a w O V) H-701-711 O , O U a O t W o. < . R 0 L R � L O ti C V 0 0L cCd C O • as r •� V 0 K C co O , z aver o v E 0 0 U A O 0 g a) o c CO Y d ❑ p a> 0 N W d 6 a 4) V CL) 0. O V b CO CO i y as 5 en 0 C▪ O a CO en 4) O) 4) 5 0.1 es L a) .Li O V y W 1-4 e0 ›-a i4 a) u .0 0) 0) 164 Environmental En Don Forchette reNewal 2014 CDPHE form APEN S009up.doc M O N a) O a 0 • ss, 0 CU 0 cn i a b 0 on a� a w 0 au z reNewal 2014 CDPHE form APEN S009up.doc w a a w U F- O z _O Co o N -� w Z L U f p - J v O rn a8 C N QU) d w�, J � a "3 a w _Q W EE U Z AIRS ID Number: S009 Combined Annealers 96OPWE125 Permit Number: Golden Aluminum Inc. N CO O CO a) a O 0 C 0 0 a) E a, o z > C o d J C E co 0 a 303-654-8366 a) z a) C 0 t a Don Forchette Person to Contact: Fax Number: donforchette@goldenaluminum.com E-mail Address: -... k,ua, yca! ) AP 42 35.3 NA AP 42 1.47 NA AP 42 0 04 NA AP 42 0.07 NA Control Equipment Emission Factor Reduction (%) (Include Units) 11.8 LBS/ MMSCF 10.075 LBS/MMSCF 0.002 LBS/MMSCF 10.0034 LBS/MMSCF Chemical Name HEXANE I FORMALDEHYDE BENZENE TOLUENE 4 Chemical Abstract Service (CAS) Number Cpl V O o t c)) M U) o c.") 0 N U) a) a n. 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O O o o • u Cl.) CO CO 0 I. 0 0 0 0 a a° u 0 a E U U up o o d, u i. w 0 O cl CID O p O Cit .y V CA z W next five yt d 0 U C) ho ° z,C0 O C V ci) G b V~' u 0 CW_ g 81) [- w a) 0 F y 8. 2 a.2 x ate. 0 a-03 U 00. 0 G O b0 if C x 96OPWE125 6) a, .0 8 a z .2 H C7 O(/j ki pG. o • 0. ti A d N o g 's 8 O . 1/40 a 00 F `- Cr) 00 o; ti 0 a U aa)) 0 O Width (inches) = 0 Horizontal 0 Down 0 Other: Length (inches) = ment & Fuel Consumption Information Section 06 — Combustion E CO .1 0 O Manufacturer: Company equipment Identification No.: CO 0 a) z a) L7 00 7 0 N CO N 6D) c.) a) A IA N T a°) v a Q ° hE > `R b0 bo 8 as 2 N N E Ire N N 35.85mmscf(2013) N N 8 CD C 0 o t0 17 a. .1 w a 4 o N 0 5 O O -0 U 0 t O N ...l a) aA > v) 'o W CC 2C E e. •2 w 9- 0 0. a) a) E > 0 S 3 cla O .CO 1iL W 6) C4 I1 .86 AP -42 .86 A o _ 41 11.28 AP -42 14.00 Stack test 9.47 AP -42 ted above. Requested Permitted Emissions4 Uncontrolled Controlled (Tons/Year) (Tons/Year) r•• ougnpui aouve(e.g. huu/): LU1J Emission Factor Actual Calendar Year Emissions3 Uncontrolled Units Uncontrolled Controlled Basis (Tons/Year) (Tons/Year) 7.61b/mmscf .14 vs) o vi j Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not lis Annual emission fees will be based on actual emissions renorted here_ f left blank a.. oat c e ...:u t_ t___� ,zt• rr N .4 v) - mass bal 7.61b/mmscf W E E .0 O 0 1.1 841b/mmscf I Control Efficiency (% Reduction) C >. - O C • U Uw Control Device Description Primary Secondary Therm Oxidzr o o a a. i 0 O v) OX Z O > O U u v t. O O u b CO ee d 0 0 U 0 41 a CO 0. 0 a, i .y O CE w d as U res RI d a, O CC 140 'i at Section 08 —A reNewal 2014 CDPHE form APEN SOI lup.doc M C O N a) OQ CO a reNewal 2014 CDPHE form APEN SOllup.doc l up.doc M 4, 0 M 0 e4 Mt a z W 0 Q W U H O z z 0- ( E 0 CO N E a, W ._ a z E <L U r O J —1 -g O a, 0- .5 Ca) a Q w W J m a) < °' I U) et O a W W H U O z AIRS ID Number: S011 coil coating • 96OPWE125 Permit Number: Golden Aluminum Inc. Zip Code: 80621 14th St. Fort Lupton Co. U) (U W to O T ai (U • 0 z >, 0 C O CQ E C CU 0 a 303-654-8366 Don Forchette Person to Conte Fax Number: donforchette@goldenaluminum.com E-mail Address Uncontrolled Controlled Actual Actual Emissions Emissions (lbs/year) (Ibs/vear) CO O N N 440 N O OCV Z NA 1 dN NA 1 CO (O O) CO (\I 00 O O N O Emission Factor Source Eng. Calc & test IEng. Cale & test AP 42 IAP 42 AP 42 0.0034 LBS/MMSCF ,AP 42 l Emission Factor (Include Units) 1.8 LBS/ MMSCF 0.075 LBS/MMSCF 0.002 LBS/MMSCF Control Equipment / Reduction (%) thermal oxidizer L. IHEXANE Chemical Name co 2 XYLENE ETHYL BENZENE TOLUENE CUM=NE From natural gas FORMALDE'WDE BENZENE 'o' TOLUENE C C Chemical Abstract Service (CAS) Number O 00 O T 11330-20-7 I V O O M co 00 00co O , N Op 0) C) V. CO p I-- O O O o UA N C) V .= 1� r') 00 CO 0 0 N C2 CZ Q (U co O CM r O C Cr) N a) a) C O) C w To C a) E C O O (U > O C w cU (UU a 0 C2 -o O a) N 0 3 Q A CU O) O J C O U) a 0 CU Don Forchette CO m a O 0 3 U) 0 Cb N O O Q (U O) m J 4C 0 N a O a) I- Name of Person Legally Authorized to Supply Data (Please print) Form Revision Date: April 14, 2014 0 z W 0 0 W U 17- O z z 0 U) U) W F z H J J 0 a. ll W J H ELF 0 a W cc W Z Z fC 0 LL w U z 0 - if ` w o W CE .0 c .- C a) 0 C O ` C E o 0 o a`- c u) o .� C cD a) N O� C 'V 'v m += m� ?? 0 0 °� 0 0 �) € 0 c m O Ei 4Ei To 0 o '" cc a E 2E E... 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Some of these comments have brought up additional questions for you. Please review the document again in tandem with my comments and let me know what you think. Thanks Don! Page 1: the description was updated using the language you provided. Just a small change that helps explain our process! OK Page 5 (and others): thanks for catching all of the HAP referencing issues. Sometimes these blow up. This has been corrected throughout the permit as necessary. Not a significant issue; I also added a note to self that HAPs appeared in our old permit somewhere else. I actually like them represented this way! OK Page 34: I've added a note to this section that allows for the reading to be performed in Fahrenheit and then converted to Celsius for comparison with the limit. Usually requirements like this have specific stipulations related to what the units are (in this case, degrees Celsius). This is due to the underlying regulatory requirement from which the requirement was based. Since the inspectors are inspecting against the underlying, the permit condition shares that unit of measure. That said, there is no reason why a conversion would be inappropriate. Let me know if you have questions about this. Thanks! The conversion is easy enough to do. Thank you internet. OK Page 36: For the coating requirement under Reg 7, I've verified that this value may apply after the control efficiency correction. For the purposes of monitoring compliance with this limit you will be required to perform testing (starting 8.11.2) or in lieu of testing you may maintain records from your supplier (8.11.5). If the VOC content exceeds the limitation, you must verify the operability of your add-on control device (thermal oxidizer) according to 8.11.6. This is sort of a vague requirement, but you will mostly just need records to show that your thermal oxidizer was operating at or above the testing temperature of 1317F which was approved for allowing the control percentage reductions. Currently we use coating VOC certs supplied by our coating manufactures'. ****** Great- this shouldn't be an issue then. If you ever have questions about this, give the inspector a call since they're the ones you need to impress. Page 37: The sampling requirement is only applicable when sampling is being performed. This would apply if you were to choose to perform the sampling instead of using manufacturer's specs for the surface coatings (re: 8.11.2). You will not need to worry about this if you are demonstrating compliance via recordkeeping and control device operation; however, this requirement needs to be in the permit as you have the option of using sampling. If you would like, I can remove this and the language related to testing in 8.11.2; however, you would then be bound to ONLY use manufacturer's records. If for some reason you were to lose the records and wanted to instead perform sampling for demonstrating compliance, you would need to submit a permit modification. I would recommend leaving this language in the permit as it stands, simply for compliance flexibility; it does not oblige you to perform testing, but gives you the option should you choose. All of this also applies for 8.11.8 with regard to the alternative demonstrations. I can take this out, but it really just gives you additional options for demonstrating compliance, should you so choose. Again, I recommend leaving this in there because it gives you flexibility if you need it and doesn't require anything additional on its own. I am going to leave this in unless you specifically request it's removal. Let me know if you have any questions about this or if you are confused about my recommendation. That said, this is up to you on whether or not you'd like this to be in the permit. I agree; let's leave this in. OK Page 39: I'm not sure if you wanted clarification here or if this was just a note for you, but I'll expand anyway. This requirement for demonstrating compliance under Reg 7 has been developed as standard language for this type of equipment. I am under the impression that these are generally standard operating parameters that are monitored regardless of the requirement. This would be an additional requirement for recordkeeping to demonstrate to us that the equipment is operating as appropriate and that when there are issues, they are resolved in a timely manner. Let me know if there was another question here or if I've misinterpreted your comment. Yes these were "notes to self". No issues with this paragraph. OK Page 40: There is a question about whether or not the calculation is a new requirement. This is directly from Reg 7 and is sort of confusing. This was intended to standardize the calculation methodology for surface coating which can sometimes be quite complicated depending on dilutions with various solvents and/or mixtures of multiple coatings. The document that is referenced in this condition is supposed to outline the EPA approved methodology so sources don't use different equations. The equation that I wrote in the permit was added as a recommendation from my supervisor to add an example of a basis calculation for a surface coating from the EPA document. If there is another equation from that document that better reflects how you would calculate your VOC content, I would be happy to change it up to whatever you use. Otherwise you are free to use whatever calculation methodology is appropriate given your specific formulation/dilution/mixture schema. I'm sure it would be helpful for the inspector to have these equations as explicit as possible for ease of review. Perhaps you could review the EPA document and see if there's something more specific that I could incorporate by reference. Else, be careful when doing complex calculations such that they conform to the standards of the referenced document. Realistically, if the inspector has been happy with what you've been doing thus far, you probably don't need to change anything, but just be aware that this is a requirement directly out of Reg 7. We do this to calculate the VOC load to the incinerator. The spreadsheet we use has been OK with our inspectors so far. OK, great. As long as the inspector is satisfied then it isn't an issue. Page 40: You have a question about whether or not using a thermal oxidized exempts you from the calculation requirement. It does not; however, provided that you have the records that show that your TO is operating properly, it should be straightforward to show that, given the high VOC destruction efficiency, you are in compliance with the Reg 7 requirement. That said, I cannot streamline out the Reg 7 requirement solely due to the operation of the control device. While it may not be feasible that you would have a surface coating that has VOC in excess of the limit even with your control device, it is mathematically possible. Additionally, and perhaps of more relevance, if the control device were to stop working or begin working atypically, we would want records of exactly what the emissions were during that period of upset so we could have an accurate inventory of emissions for the event. My first reading of this citation lead me to believe this was a restriction of coatings used period. My concern here was that, perhaps this was a limitation as delivered to the coating applicator. Further reading clarifies this for me. Its' stated as "discharged to the atmosphere"; which in our case is after destruction by the thermal oxidizer. Reg 7 is notoriously challenging to interpret and I had to clarify this issue with management. In practice, the most important thing will be the operation of the thermal oxidizer; only in the event of some TO issue would this calculation then be more relevant for VOC compliance. Page 46: You had a question about a non-resettable hour meter. I'm not sure if that was for me, but generally whatever timer you have installed on your engine is probably fine. You can ask the inspector if you'd like to verify since they're the ones you need to impress with this. If you want, you can snap a photo and I can send it to whomever is slated to inspect you all next. Checking with our Maintenance Superintendent has verified our meter is not re-settable. I feel we are OK here. OK Page 47: I know you didn't really have a question here, but I wanted to bring to your attention that this section of MACT ZZZZ is currently undergoing review by the EPA. It was remanded during the Obama administration but nothing ended up happening. I have no idea what changes might be made given the new administration wants to scrap a bunch of rules. If you have any questions about the status of this feel free to reach out, I am usually up-to-date in my knowledge of rule changes. However, we do not currently have any systems in place which inform sources about regulatory changes that I am aware of. Thanks for the info. We 're going to include compliance and record keeping mentioned on this page. It's better for us to embrace all the requirements as we ramp the Emergency Gen into our monitoring procedures. OK Page 56: There was an issue with a cross reference on this page. It was a condition that was previously in the permit, but I removed it because it wasn't really applicable. As far as Condition 11.13 is concerned, the second part of that condition won't really apply unless your operation changes such that you have a new/modified unit that is subject to MACT RRR. Thank you. OK Page 57: There is a reference circled for 63.1506(c) and labeled as "wrong." I verified that the reference is correct per the rule and the cross reference in the document is correct. If there was a different error you were referencing, please let me know, otherwise this will not be changed. I reviewed this and don't understand the comment I wrote. I must have referenced something else here. I've found this and you are correct! OK Page 57: There is a question as to whether or not the visual inspections would be suitable for demonstrating compliance with the volumetric flow requirements. It may be possible per 11.15.2.1 provided that the inspections conform to the requirements of EPA Method 204 to verify the permanent total enclosure as required by RRR. I am not sure if your current inspection methodology is sufficient or not, you would need to verify this and maintain records to this effect. Page 57: I am unclear about how the flow rate was not established during the performance test. It is my understanding that without an accurate flow, the concentration data may not be used to verify the emissions. Can you please verify that your performance testing complied with the requirements of 63.1511(c)? This may be a problem if we do not know the operable range for the flow rate to be verified under 11.15.2.1. This is confusion on my part. YES, flow information was collected during the testing by APT. My interpretation of this was that there was a new request to collect data at locations up stream of the test port used by APT, specific to each of the sidewell hoods. We sampled at the same test port for each of our sidewell performance tests. An annual recheck at this port would satisfy this I believe. Our capture hoods were designed to meet criteria required by Industrial Ventilation Vol. 23 stated as the design standard. This design was submitted with our Minor Modification application. Prior to our annual inspection required by this citation, we will check that all hoods and ducting are as per the submitted design. OK, great. I'm not super familiar with the nuances of these testing requirements, but I'd recommend reaching out to the inspector if you have any further questions about this. It sounds like this would satisfy the requirement so long as this flow rate measurement was performed in accordance with the MACT RRR requirements. Page 57: There is a note that you were unable to fmd citations. I am unclear as to what this is referencing, but all of my citations came from https://www.ecfr.gov/cgi-bin/text- idx?node=sp40.13.63.rrr#se40.14.63 11510 which is the current version of the rule text. As far as being able to find the citations, I did find them. It was necessary to update my copy of RRR. OK Page 58: I removed an erroneous reference. In the event that you were ever to decide to use a COMS, the reference to 63.1510(f)(2) would suffice. I omitted it because it is currently unnecessary. If you were to decide to use a COMS, I would likely outline the requirements in the next issuance of the permit, but it would not require a modification to do so. Thanks. OK Page 59: There is a "?" by one of the conditions related to having the manufacturer of the bag leak detection bags to be able to certify PM at 10 mg/m3. This should be a simple document from your manufacturer that the bags comply with the Federal EPA requirements related to PM. Again "note to self". Our Triboguard System was sourced to comply; unless the 10mg/M3 requirement has changed since installation we are good. I would almost guarantee that these bags are appropriately certified. I think it would be hard to find bags that weren't anymore given that everyone needs them for EPA compliance demonstrations. In the event that the inspector wants to look at these, it would be worthwhile having the tech specs for your bags handy. Page 59: Two of the conditions related to specific bag filter systems are crossed -through. Please expand on this. If you'd like these to be removed because they do not apply, please let me know and let me know the reason they do not apply. The cross through was simply to indicate that neither of these conditions are in use in our design. I have no problem with their inclusion. OK, great. As a personal preference when drafting these permits, I prefer to leave in these alternates on the off chance that they may become relevant to you somehow. It gives you operational flexibility if you want it and saves me the work of opening up the permit for modification if you decide to use it. Page 61: There is a comment "no mention of periodic TC replacement." Please clarify- is there a requirement that appears to be omitted? What is "TC"? We replace our NIST certified thermocouples "TC" semi-annually; at great expense. Although it is not stated here, I did check and we are required to verb calibration on this schedule as stated in 40CFR §63.1510(b)(4)(i). The only way the verify calibration is to replace them. We are re- using them, if they aren't damaged during removal, in other processes that are outside of RRR. §63.1510(b) requirements are related to the OM&M plan. The requirements under (b)(1) through (9) are inclusive of this TC operation verification under (b)(1)(4). I've clarified in 11.13 that the OM&M requirements are outlined in (b)(1) through (9) (before it simply said (b)). Please let me know if there was something else you had in mind regarding this requirement. Page 61: There is a note that lime -injection is not used for MACT RRR compliance and only apply to major HAP sources. I am unclear on this comment. The lime -injected fabric filter is used to control emissions, but are you saying that the D/F emissions are not controlled with the lime -injection so these requirements are not applicable? I thought that the group 1 furnace and the in -line fluxers vented to the lime -injected baghouse and when the D/F test was performed, it was downstream of the baghouse? Can you please elaborate a bit on this comment so we can verify whether or not this condition is applicable. Section 11.19 &11.20. Of these two control methods, we use 11.19 for Affected Source RRR D/F control. Section 11.19(all parts) is followed for Baghouse Inlet temperatures determined by our performance tests. Our belief is this is responsible for our low D/F formation indicated by our performance test results. By staying below the D/F formation temperatures we are capable of continuing to replicate these results. Yes the lime injected baghouses are controlling emissions. Particularly Criteria PMs and HAPs (HCl and HF), plus lime is afire suppressor to protect the bags. OK Section 11.20: Although we do follow these parameters implicitly, this citation appears to be specific to Major Sources that are required to control HAPs or for Affected Sources to control D/F. We control D/F with temperature as stated in 11.19(all parts) Fabric Filter Inlet Temperature. We follow 11.20(all parts)as a means to control HAPs as an Affected Source under NESHAPS not RRR. §63.1510(a) states: Area sources are subject to monitoring requirements for those affected sources listed in §63.1500(c)(1) through (4) of this subpart, and associated control equipment as required by paragraphs (b) through (k), (n) through (q), and (s) through (w) of this section §63.1510(a)(8) states: The requirements for monitoring lime injection described in paragraph (i) of this section applicable to all lime injected fabric filters used to control emissions from group 1 furnaces processing other than clean charge, thermal chip dryers, sweat furnaces and scrap dryer/delacquering kiln/decoating kilns Unless I am mistaken about your operation, this appears to state that your lime -injected baghouse would be subject to the requirements of §63.1510(i) as outlined in 11.20. Please let me know if you believe this reading to be inappropriate and we can discuss it- for the moment I'm going to leave it in there. Page 62: Can you please clarify your comment? I am unclear on why the in -line fluxers would not be subject to this requirement. The group 1 furnaces feed into the fluxers and thus would appear to be subject. Our performance tests were conducted on the melter sidewells which are Group 1 furnaces. There is an under surface -level port that allows molten aluminum to circulate to the main -bath that is adjacent to the sidewell. The main -baths are Group 2 furnaces, and all feedstock charge to them is clean charge including molten aluminum transferred from the sidewell. We are prohibited f rom letting the level drop below the transfer port. This would allow dirty charge to enter the main bath. By the time dirty material charged to the sidewell reaches the under surface transfer port all coatings and oil have been burned off. Our D/Fperformance testing was conducted on our Group 1 sidewells. Our inline fluxers are associated with a separate process. Clean aluminum is transferred from our main -baths (Group 2) by -way of a trough system. The inline fluxers (3individual units) are part of the trough network that transfers clean metal to our caster. Chlorine gas is used in the inline fluxers to remove unwanted sodium and lithium, which are detrimental to our process. Chlorine fugitive emissions, as HCl, are captured by hoods above each inline fluxer and ducted to the melt baghouse to be neutralized by injected lime. The HCl emissions are subject to NESHAPS and reported as such. Called about this for clarification. If it is true that inline fluxers are not subject, perhaps these requirements should be left in the permit in case the Source wants to change furnace classification from Group 2 to Group 1- if not, there are still requirements for recordkeeping for solid reactive flux under §63.1510(j). Page 65: There was a referencing error here. I originally had included the calculation requirement under 63.1510(t); however, you performed the D/F testing which exempts you from that requirement. If you'd like the calculation to be added back into the permit, I can do that, but I don't think it is necessary since you don't actually need to do it. I agree, Thank -you. OK Page 66: Please elaborate on your comment "we do not inject ??" You are using a lime -injected fabric filter and I assume it was used during the D/F testing. Confusion on my part. Yes we inject lime. My comment was we don't inject chlorine to the sidewells; I failed to remove the comments after realizing my mistake here. All good, thanks for the clarification. Page 67: "No" is written a bunch of times, please elaborate on your comment/s. This condition would only apply should you elect to change the classification of your furnace. If you anticipate that there will never be an operational change related to this, I can pull this out of the permit; however, it gives you potential flexibility should you decide that you'd ever like to change the furnace class. This was one of the more recent, larger updates to this rule after sources provided comments related to operational flexibility limitations under the rule. I assumed you'd prefer it in the permit just in case. Let me know if you'd like this removed. My comment was about the applicability of the paragraphs to our process to -date. I like these as additions to the Permit for future reference. OK Please let me know if you have questions and how long it might take you to prepare replies to my questions above. Thanks for your patience and for your help. Cheers, Nick Nicholas Dummer Air Quality Engineer, Title V Operating Permits Unit Stationary Sources Program++++++++ ,seW A mfitt'- August 31, 2016 Colorado Department of Public Health and Environment APCD Operating Permits Unit Dear Sirs; YEARS d OF INNOVATION GOLDEN u .. t Golden Aluminum is submitting changes to the PTE requested for two of our emission units covered by Title V Operating Permit 96OPWE125: grouped source melters S003, S004, S005 -Main Hearths and Coil Coatingline w/Thermal Oxidizer. The APEN for grouped source melters S003, S004, S005 -Main Hearth's has been changed. This source's NOx "Requested Annual Permit Emissions Limit" is lowered to reflect our operations currently and our expected future production. The previous NOx limit request was based on expectations that Golden would use oxygen participation to increase burner efficiency. Gas prices in today's market verses oxygen costs have changed that strategy. The APEN for 5011 -Coil Coating Line w/Thermal Oxidizer has also been change. VOC "Requested Annual Permit Emission Limits" is adjusted lower to better reflect our actual use. An APEN for our emergency generator set has also been submitted. A check to cover the $152.90 per APEN filing fee is being sent as a separate item. Thank you Don Forchette Environmental Engineer Golden Aluminum Inc. Hello