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Clean Air Act Compliance Inspection Report
United States Environmental Protection Agency Region 10 - Seattle, WA
Partial Compliance Evaluation
Real Alloy Recycling, Inc.
Post Falls, Idaho
Inspection Date: September 28, 2021
JON KLEMESRUD
Report Author Signature
Digitally signed by JON KLEMESRUD Date: 2021.11.29 10:19:34 -08'00'
Date
Jon Klemesrud Inspector EPA Region 10
ZACHARY HEDGPETH Date: 2021.11.29 10:43:19 -08'00' Digitally signed by ZACHARY HEDGPETH
Peer Review Signature
Date
Zach Hedgpeth, PE Environmental Engineer EPA Region 10
KATHERINE MCCLINTOCK Date: 2021.11.30 06:38:09 -08'00' Digitally signed by KATHERINE MCCLINTOCK
Manager Signature
Date
Katie McClintock Supervisor, Air & Toxics Enforcement Section EPA Region 10
2021 Real Alloy Recycling, Inc. Inspection Report
Contents
I. Facility Information ............................................................................................................ 3
II. Inspection Information........................................................................................................ 3
III. Facility Background............................................................................................................ 4
IV. Inspection Chronology........................................................................................................ 5
V. Opening Conference ........................................................................................................... 6
VI. Site Review ..................................................................................................................... 6
VII. Records/Permit Conditions Review .................................................................................. 10
VIII. Closing Conference........................................................................................................... 10
IX. Post Inspection Correspondence ....................................................................................... 11
X. Potential Compliance Concerns ........................................................................................ 11
ATTACHMENT A - Aerial Image (Google Earth) ATTACHMENT B - IDEQ Permit to Construct (P-2009.0139) ATTACHMENT C - IDEQ Permit (P-2009.0139) Statement of Basis ATTACHMENT D - Photograph Log ATTACHMENT E - Records Request
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I. Facility Information
Facility Name:
Real Alloy Recycling, Inc. - Post Falls
Facility Owner:
Real Alloy Holding, LLC
Facility Address:
16168 West Prarie Avenue Post Falls, Idaho 83854
Mailing Address:
16168 West Prarie Avenue Post Falls, Idaho 83854
Facility Contact(s):
Jeff Bohannon - Plant Manager Real Alloy Recycling, Inc. - Post Falls (208) 733-1527 ext. 1608, jeff.bohannon@realalloy.com
Gary Milan - Maintenance Supervisor Real Alloy Recycling, Inc. - Post Falls
Jeff Ferg, Environmental Health & Safety Real Alloy Recycling, Inc. - Headquarters jeff.ferg@realalloy.com
Latitude/Longitude:
N 47.74244 W -117.004636
NAICS Code(s):
331314 - (Secondary Smelting and Alloying of Aluminum)
AFS/FRS Number:
ID0000001605500031
IDEQ Facility ID:
055-00031
Permit Number:
Permit to Construct, P-2009.0139 Issued 01/02/2020
Disclaimer: Unless otherwise noted, all details in this inspection report were obtained from conversations with Jeff Bohannon, Gary Milan, or from observations made during the inspection and/or file review. The report is a summary of observations and information gathered, it does not constitute a final decision regarding compliance with the Clean Air Act (CAA) and applicable regulations or permits.
II. Inspection Information
Inspection Date:
September 28, 2021
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EPA Inspector(s):
Jon Klemesrud, Inspector EPA Region 10 (206) 553-5068 klemesrud.jon@epa.gov
Zach Hedgpeth, PE EPA Region 10 (206) 553-1217 hedgpeth.zach@epa.gov
Other Individuals Present:
Almer Casile, CAA Compliance Analyst Idaho Department of Environmental Quality Coeur d'Alene Regional Office (208) 666-4600 almer.casile@deq.idaho.gov
Shawn Sweetapple, Air Quality Manager Idaho Department of Environmental Quality Coeur d'Alene Regional Office (208) 666-4602 shawn.sweetapple@deq.idaho.gov
Inspection Start/End Times: 8:50am - 3:50pm
Inspection Notice:
Unannounced
This was a partial compliance evaluation (PCE) by the Environmental Protection Agency Region 10 (EPA R10) and the Idaho Department of Environmental Quality (IDEQ). to determine the facility's compliance with the State issued Permit (P-2009.0139) and federal regulations under the Clean Air Act (CAA).
III. Facility Background
Real Alloy Recycling, Inc. - Post Falls ("Facility") is owned and operated by Real Alloy Holding, LLC. According to the company's website (www.realalloy.com), there are twenty-three Real Alloy facilities in six countries across North America and Europe. The company is headquartered in Beachwood, Ohio. The Facility is located along the northwestern edge of Post Falls, Idaho and has operated at its current location since 1988.
The Facility operates as a secondary aluminum production plant, producing recycled scrap ingots (RSI) from the melting and recovery of aluminum scrap and aluminum dross. For a general footprint and location, an aerial image from Google Earth is attached to this report as (Attachment A).
The facility operates under State-issued Idaho Title V Permit to Construct No. P2009.0139 (Attachment B). The permit was most recently reissued on January 2, 2020.
Major components of the Facility include aluminum scrap and aluminum dross receiving and storage, two natural gas fired rotary furnaces, aluminum casting, flux
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handling/storage, product storage, associated environmental control equipment and supporting operations.
Production of aluminum RSI at the Facility consists of the following processes:
1. receiving and storing of aluminum scrap and aluminum dross 2. melting the scrap/dross in a rotary furnace 3. addition of solid flux material and alloying agents 4. pouring the molten metal into sow molds 5. casting into various grade RSI for sale and distribution 6. byproduct ("salt cakes") is poured out of the rotary furnace and disposed of via
approved landfill.
A more detailed process and emission unit description can be found in the Statement of Basis (Attachment C) associated with the IDEQ Permit.
There are seven sources of regulated emissions listed within the current version of the IDEQ Permit including: Rotary Furnace #3 (RF3), Rotary Furnace #6 (RF6), Salt Cake Staging and Handling for RF3, Salt Cake Staging and Handling for RF6, Crucible Cleaning, Scrap Receiving/Hauling, and Dross Receiving/Hauling.
The Facility has been determined to be an area source as defined by 40 CFR 63.2 (Subpart A General Provisions) for hazardous air pollutants (HAP). The Facility is subject to federal requirements under the National Emission Standards for Hazardous Air Pollutants (NESHAP) standards for Secondary Aluminum Production (40 CFR Part 63 Subpart RRR). The furnaces at the Facility are considered Group 1 furnaces as defined in the NESHAP. Regulated pollutants from the emission units include criteria pollutants, dioxins and furans (D/F) and fluoride.
According to EPA's Enforcement Compliance History Online (ECHO), the Facility was last inspected by IDEQ on October 18, 2017. The inspection report documented that the Facility was in compliance with the terms and conditions of the permit at the time of inspection.
The most recent source compliance testing at the facility occurred in August of 2021 and July 2020.
IV. Inspection Chronology
This inspection was unannounced. On day of the inspection, Zach Hedgpeth (EPA) and I arrived at the Facility and met with Jeff Bohannon (Plant Manager) near the entrance. We had our initial introductions, I informed Mr. Bohannon that Zach Hedgpeth and I had been asked to conduct a routine inspection at the Facility to assess compliance with the CAA and associated Idaho Department of Environmental Quality (IDEQ) Permit. Mr. Bohannon welcomed the visit and we followed him into the Facility's conference
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room to begin the inspection. I informed Mr. Bohannon that we would be joined on the inspection by representatives of IDEQ, at this time they had yet to arrive. The inspection included an opening conference, a facility walk-through, a records review, and a closing conference.
For the facility walk-though, we observed the general facility operations, toured each emission unit (EU), and observed the monitoring areas associated with the IDEQ Permit. We were allowed to inspect all areas requested.
The records review occurred at various times throughout the walk-through and within the conference room, prior to the closing conference. Records not available at the time of inspection were requested and provided via email post-inspection.
The closing conference occurred within the Facility's conference room following the walk-though. During the closing conference, Zach and I discussed our observations from the walk-through and from the initial records review.
V. Opening Conference
The opening conference was held with Mr. Bohannon inside the Facility's conference room. Almer Casile (IDEQ) and Sean Sweetapple (IDEQ) arrived mid-conference. During the opening conference, Zach and I exchanged business cards with Mr. Bohannon and presented our EPA inspector credentials. I explained that I would be leading the EPA inspection with Zach Hedgpeth (EPA), IDEQ's participation was for observation purposes only.
I discussed the purpose and expectations of the inspection and provided Mr. Bohannon with a copy of the EPA Small Business Resource Information Sheet as well as EPA's Confidential Business Information (CBI) Notice Forms. We discussed the EPA forms and also how photographs would be taken as part of the inspection. In consultation with corporate staff, for CBI purposes Mr. Bohannon requested certain views/angles of the rotary furnaces be excluded from the photographs, as well as direct photographs of the RSI molding/casting process.
VI. Site Review
Following the opening conference, Mr. Bohannon provided a general background of the Facility's history and general operations. Mr. Bohannon stated that he has been employed at the Facility since 1989. During that span, he has worked in a variety of roles since becoming Plant Manager. Mr. Bohannon also stated that the Facility has been without an Environmental, Health & Safety (EHS) position for approximately one-year and that he has assumed those roles in the interim. In addition, the Facility receives additional EHS support from their corporate staff in Ohio, primarily Mr. Jeff Ferg.
When discussing general operations, Mr. Bohannon stated that production has been down overall, mostly attributed to a staffing shortage associated with the COVID-19
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pandemic. Due to the staffing shortage, the Facility has only been operating one of the two rotary furnaces (Rotary Furnace #3).
Scrap aluminum is brought to the Facility in many forms, including traditional scrap, "popcorn" scrap, "sawdust" scrap and compressed "pucks." Once onsite, scrap aluminum is stored outdoors until transported into the rotary furnace for melting/refining. According to Mr. Bohannon, no shredding occurs on-site. Mr. Bohannon also stated that the Facility stopped the transportation of molten aluminum in 2003/2004 (approx.).
According to the Permit, aluminum dross is brought to the dross recovery facility via dump trucks and stored indoors until melted. Mr. Bohannon stated salt flux material (potassium chloride and cryolite) is also added into the furnaces during operations.
The walk-through began at approximately 9:55am. Mr. Bohannon provided a safety briefing prior to us leaving the conference room to begin the walk-through.
Photographs used in this inspection report and a complete photo log appear in (Attachment D). For the entire walk-through we were joined by Mr. Bohannon, we were also joined by Gary Milan (Maintenance Supervisor) for portions of the walkthrough.
At the time inspection, the Facility was melting scrap aluminum within Rotary Furnace #3 (RF3). No operations were occuring at Rotary Furnace #6 (RF6). According to Mr. Bohannon, RF6 has not operated in 2021 with the exception of the month of July and the first weeks of August for testing.
RF3 and RF6 are separate operations and located in different buildings within the Facility. According to Mr. Bohannon, production at Rotary Furnace #3 (RF3) is a continuous operation 7/days a week. Prior to the staffing shortages, Rotary Furnace #6 (RF6) was also operated continuously, approximately 4/days a week.
Alliance Source Testing, LLC conducted the recent (2020 & 2021) source testing. Target parameters for the testing included Particulate Matter (PM10), Nitrogen Oxides (NOx), Visible Emissions (VEE), and hood flow measurements for RF6. NOx, VEE, and hood flow measurements for RF3 were also competed. The Source Test Reports showed emission rates below the limits set in their IDEQ permit.
For the walk-through we first observed areas where RSI's and scrap aluminium are stored/handled outdoors, no fugitive dust/emissions were observed. These outdoor storage areas are generally present throughout the Facility (Photo 1 & Photo 2).
According to the Mr. Bohannon, raw materials brought to the Facility for processing are approximately 70% scrap and 30% dross. Raw materials are primarily transported to the Facility via truck, with a limited amount transported via rail. According to Mr.
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Bohannon, the Facility's primary scrap supplier is Kaiser Aluminum, aluminum also comes from "Hydro Aluminum" and "CASS" out of California among other sources.
Our walkthrough continued into the building that houses RF3, and we observed RF3 operating within it's enclosure (Photo 3). According to Mr. Bohannon, the Facility was currently producing aluminum 7050 alloy and "running scrap" in RF3 at the time of inspection.
Aluminum charged in the rotary furnace is handled by a front loader. The load is weighed and recorded prior to every charge into the furnace (Photo 4). The IDEQ Permit establishes a feed charge limit for RF3 of 175 tons per day on a monthly average and 63,875 tons per year.
According to Mr. Bohannon, each "heat" is approximately 25,000 - 30,000 lbs. The scale used for weighing/tracking each feed charge is calibrated monthly by Unitec Dorsch, LLC. According to Facility records, the scale was last calibrated on September 17, 2021.
Aluminum is charged directly into the front opening of the furnace along with the flux material and any alloying agents. At the conclusion of the "heat", the furnace is tapped by tilting the furnace and pouring the molten metal into a trough where it is transferred into sow molds and cast into RSI. According to Mr. Bohannon the total process takes about 2 or 2 hours.
RF3 is contained in a vestibule that includes a hood and ducting designed to capture process emissions (Photo 5). The captured emissions are routed to a trona-injected, shaker style baghouse (RFB3) that consists of six compartments and then exits via an exhaust stack.
After the aluminum is tapped, the byproduct (salt cake) is poured out of the furnace into pans and placed under a hood adjacent to the furnace to cool (Photo 6). The hood for this salt cake staging area is routed to Baghouse 9 (BH9).
Following our initial observations of the charging and tapping of RF3, we continued our walk-through outside and observed the components of RFB3 and its associated cooling tower and exhaust stack (Photo 7, Photo 8 & Photo 9). No opacity was observed from the RFB3 stack at the time of inspection. We also briefly observed BH9 (Photo 10).
According to the 2021 Semiannual Report, the RF3 Baghouse is equipped with a bag leak detection system which includes a PCME DT990 sensor and a Pyrotek 001532 thermocouple. The Facility conducts an Electronic Drift Check each month. According to Facility records, the last occurrence was on August 30, 2021 (Photo 11). The PCME DT990 is calibrated annually and the thermocouple calibration is verified every 6 months.
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We continued our walk-through back inside to view the Trona-feed system (Photo 12). According to Mr. Bohannon, approximately 2000 lbs of Trona is added every 18 hours. At the time of inspection, the Trona-feed system was set to 99 lbs/hour. The feed rate is verified once per month via a pan test/calibration. The Trona-feed system is checked each shift (3x daily) as a component of the RF3 #3 Baghouse Checklist.
We then viewed the dross and salt-cake storage areas (Photo 13) and broke for lunch at approximately 11:15am. As we were leaving the RF3 building, Zach Hedgpeth (EPA) observed potential visible emissions near the rear of the RF3. We discussed with Mr. Bohannon that we would like to return to this area during the next heat cycle.
We regrouped from lunch at approximately 12:45pm, we first observed/discussed the monitoring display of the bag leak detection system for RFB3. According to Mr. Bohannon, settings/alarms for the bag leak detection systems are maintained by engineers out of Real Alloy's corporate office in Ohio.
We continued the walk-through back to the RFB3 to view the location of the associated probes/monitoring equipment. Mr. Milan also provided a demonstration of the pan test procedures of the RFB3 Trona-feed system.
The walk-through continued to the building that houses RF6, we first viewed the salt cake staging area associated with RF6 (Photo 14). Similar to operations at RF3, when RF6 is operating, the salt cake staging area is equipped with a hood which is intended to capture and route emissions to Baghouse 8 (BH8) (Photo 15). We observed the components of the RF6 enclosure and capture system as well as labeling required by the NESHAP.
Our walk-through continued outside, and we viewed RFB6 (Photo 16). RFB6 is a pulsejet style baghouse that consists of five compartments, each compartment has 330 bags. According to Mr. Bohannon, RFB6 was replaced in 2015. RFB6 utilizes a Filter Sense EM 30LGX bag leak detector that is calibrated annually.
At this time, Almer Casile (IDEQ) and Sean Sweetapple (IDEQ) departed the inspection, we continued the walk-through with Mr. Bohannon back to RF3. A new heat cycle had started, and we revisited the area where potential visible emissions were observed earlier in the day. While viewing RF3 from rear, visible emissions were observed for approximately one minute or less (Photo 17) as emissions appeared to exit from the rear of the enclosure of RF3. It was unclear what stage in the heat cycle RF3 was in at the time of the observed visible emissions. The roof of the building that houses RF3 is vented from the ceiling.
The walk-through concluded and we returned to the Facility's conference room to review/request additional records that hadn't been observed during the walk-through.
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VII. Records/Permit Condition Review
Throughout the course of the on-site inspection, the following permit related records were reviewed:
1. 2021 Excess Emissions/Summary Report [40. CFR 63.10(e)(3)(v)] Permit Citation 2.21.
2. Operation, Maintenance, & Monitoring Plan for Rotary Furnace #3 [(40.CFR 63.1510(b)] Permit Citation 2.13.
3. Operation, Maintenance, & Monitoring Plan for Rotary Furnace #6 [40.CFR 63.1510(b)] Permit Citation 2.1.
4. Rotary Furnace #3 Baghouse Checklist (September 2021) [40.CFR 63.1510(j)] [40 CFR 63.1510(h)] Permit Citation 2.10, 2.13.
5. Trona Feed Flow Rate Verification (August 16, 2021) [40.CFR 63.1510(j)] Permit Citation 2.10.
6. Rotary Furnace #3 Baghouse Malfunction Occurrence Log [40 CFR 63.1506(m) Permit Citation 2.11.
7. Rotary Furnace #6 Baghouse Malfunction Occurrence Log [40 CFR 63.1506(m) Permit Citation 2.11.
8. Rotary Furnace #3 Baghouse PCME DT 990 Response Test Monthly Record (August 2021) [40 CFR 63.1510(f)] Permit Citation 2.13.
VIII. Closing Conference
Following the walk-through and initial file review, a closing conference was held with Mr. Bohannon inside the Facility's conference room. We discussed our inspection observations and noted that additional records were requested in order to evaluate compliance related to the RF3 capture system and the visual emissions observed at RF3.
Additional records were also requested in order to evaluate compliance with the bag leak detection system settings for RFB3. See (Attachment E), for a list of records requested at the time of the closing conference.
We discussed that potential compliance concerns could be identified during the postinspection records review. We then thanked Mr. Bohanon for his time and cooperation with the inspection.
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IX. Post Inspection Correspondence
Post-inspection, on September 29, 2021, Mr. Bohannon called Mr. Hedgpeth to provide verbal clarification regarding the bag leak detection system equipment on RF3. Mr.
Bohannon followed up the call with an email containing photos of the equipment (Photo 18 & Photo 19).
Also, on September 30, 2021, Mr. Ferg submitted documentation via email to address the records requested at the time of the closing conference. The following records were provided by Mr. Ferg:
1. Source Test Report (Rotary Furnace #3 & Rotary Furnace #6) August 17 &18, 2021 [40 CFR 63.1505(a), 40 CFR 63 1505(i)(3) and 40 CFR 63.1505(k)(3)] Permit Condition(s) 2.6 and 2.7.
2. 2020 Capture and Control System Annual Inspection Report [40 CFR 1506(c)] Permit Citation 2.13.
3. 2021 Capture and Control System Annual Inspection Report [40 CFR 1506(c)] Permit Citation 2.13.
4. October 2020 Bag Leak Sensor Setup for Rotary Furnace Baghouse #3 [40 CFR 1501(f)] Permit Citation 2.13.
5. September 2021 Bag Leak Sensor Setup for Rotary Furnace Baghouse #3 [40 CFR 1501(f)] Permit Citation 2.13.
6. February 2020 Bag Leak Sensor Setup for Rotary Furnace Baghouse #3 [40 CFR 1501(f)] Permit Citation 2.13.
7. PCME DT 990 Aleris Operating Procedure[40 CFR 1501(f)] Permit Citation 2.13.
8. FilterSense 70 & 30 Series Control Units PS 10 Sensors Installation & Operating Manual [40 CFR 1501(f)] Permit Citation 2.13
X. Potential Compliance Concerns
Observations during the on-site inspection and post-inspection records review identified one potential compliance concern:
A. Hood Opening Area Measurements from the Rear of RF3
Within Part 2.11 of the Facility's Permit (40 CFR 63, Subpart RRR - Operation Requirements), the permit states that the permittee shall "design and install a system for the capture and collection of emissions to meet the engineering
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standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists (ACGIH) in Chapters 3 and 5 of Industrial Ventilation: A Manual of Recommended Practice." The hood opening flow/exhaust rate is determined by the measured hood flow divided by the measured hood opening area (ft2). Based upon a review of the submitted Rotary Furnace #3 hood opening area measurements, only openings from the front of the furnace appear to be accounted for in the calculation of hood opening area that is used to document compliance with the minimum exhaust rates contained in the ACGIH Guidelines. As described earlier in this report, at the time of inspection, visible emissions were observed coming from openings near the rear of the Rotary Furnace #3 (Attachment D, Photo 17). Openings from the rear of the furnace did not appear to be included in the hood opening area measurements.
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ATTACHMENT A
Aerial Image (Google Earth)
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ATTACHMENT B
IDEQ Permit to Construct #P-2009.0139
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ATTACHMENT C
IDEQ Statement of Basis Permit to Construct #P-2009.0139
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SM80 =
SM =
B
=
UNK =
HAPs) has permitted emissions > 25 T/yr.
Use if a synthetic minor (uncontrolled HAPs emissions are > 10 T/yr or if the aggregate of all uncontrolled HAPs (Total HAPs) emissions are > 25 T/yr and permitted emissions fall below applicable major source thresholds) and the permit sets limits > 8 T/yr of a single HAP or 20 T/yr of Total HAPs.
Use if a synthetic minor (uncontrolled HAPs emissions are > 10 T/yr or if the aggregate of all uncontrolled HAPs (Total HAPs) emissions are > 25 T/yr and permitted emissions fall below applicable major source thresholds) and the permit sets limits < 8 T/yr of a single HAP and/or < 20 T/yr of Total HAPs.
Use when the potential to emit (i.e. uncontrolled emissions and permitted emissions) are below the 10 and 25 T/yr HAP major source thresholds.
Class is unknown.
For All Other Pollutants:
A
= Use when permitted emissions of a pollutant are > 100 T/yr.
SM80 = Use if a synthetic minor for the applicable pollutant (uncontrolled emissions are > 100 T/yr and permitted emissions fall below 100 T/yr) and permitted emissions of the pollutant are 80 T/yr.
SM = Use if a synthetic minor for the applicable pollutant (uncontrolled emissions are > 100 T/yr and permitted emissions fall below 100 T/yr) and permitted emissions of the pollutant are < 80 T/yr.
B
= Use when the potential to emit (i.e. uncontrolled emissions and permitted emissions) are below the
100 T/yr major source threshold.
UNK = Class is unknown.
Table 9 REGULATED AIR POLLUTANT FACILITY CLASSIFICATION
Pollutant
PM PM 10 PM 2.5 SO2 NO X CO VOC HAP (single) Total HAPs
Uncontrolled PTE (T/yr)
2,588 316.2 316.2 0.25 28.72 59.17 2.10 >10 >25
Permitted PTE (T/yr)
52.52 5.70 5.70 0.25 28.72 59.17 2.10 7.4 8.20
Major Source Thresholds (T/yr)
100 100 100 100 100 100 100 10 25
AIRS/AFS Classification
SM SM SM B B B B SM SM
Permit to Construct (IDAPA 58.01.01.201)
IDAPA 58.01.01.201 ........................................... Permit to Construct Required
The permittee has requested that a PTC be issued to the facility for the increase in allowable production and elimination of salt cake production limits. Therefore, a permit to construct is required to be issued in accordance with IDAPA 58.01.01.220. This permitting action was processed in accordance with the procedures of IDAPA 58.01.01.200-228.
Tier II Operating Permit (IDAPA 58.01.01.401)
IDAPA 58.01.01.401 ........................................... Tier II Operating Permit
The application was submitted for a permit to construct (refer to the Permit to Construct section), and an optional Tier II operating permit has not been requested. Therefore, the procedures of IDAPA 58.01.01.400-410 were not applicable to this permitting action.
2009.0139 PROJ 62290
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ATTACHMENT D
Photograph Log
All photographs taken by Jon Klemesrud (unless otherwise noted) on September 28, 2021
Nikon Coolpix AW100
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Photo Log - Real Alloy Recycling, Inc. - Post Falls
Photo #:01 (DSCN2487) Description: Facing southwest, photo of finished recycled scrap ingots (RSI) produced at the facility, stored on-site ready for shipment.
Photo #:02 (DSCN2488) Description: Facing northeast, photo of shredded "popcorn" scrap aluminum being stored on- site (foreground). RSI's also stored in area (background).
Photo #:03 (DSCN2489) Description: Facing north, photo of Rotary Furnace #3 enclosure and capture hood.
Photo #:04 (DSCN2505) Description: Facing northeast, photo of a loader being weighed prior to adding aluminum to Rotary Furnace #3.
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Photo Log- Real Alloy Recycling, Inc. - Post Falls
Photo #:05 (DSCN2490) Description: Facing north, photo of Rotary Furnace #3 capture hood and ducting.
Photo #:06 (DSCN2491) Description: Facing northeast, photo of the salt cake storage/cooling area and associated capture hood near Rotary Furnace #3.
Photo #:07 (DSCN2499) Description: Facing west, photo of Baghouse #3.
Photo #:08 (DSCN2498) Description: Facing northwest, photo of Baghouse #3 cooling tower.
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Photo Log- Real Alloy Recycling, Inc. - Post Falls
Photo #:09 (DSCN2497) Description: Facing east, photo of Baghouse #3 outdoor ducting to cooling tower.
Photo #:10 (DSC2496) Description: Facing south, photo of Baghouse #9. Used as a pollution control device for the salt cake staging and handling area near Rotary Furnace #3.
Photo #:11 (DSCN2516) Description: Photo of the monthly (August 2021) PCME Drift Check and Response Test for Baghouse #3.
Photo #:12 (DSCN2503) Description: Facing east, photo of the Trona feed system for Baghouse #3.
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Photo Log - Real Alloy Recycling, Inc. - Post Falls
Photo #:13 (DSCN2506) Description: Facing southwest, photo of the dross storage area near Rotary Furnace #3.
Photo #:14 (DSCN2519) Description: Facing north, photo of the salt cake storage/cooling area and associated capture hood near Rotary Furnace #6.
Photo #:15 (DSCN2524) Description: Facing north, photo of Baghouse #8. Used as a pollution control device for the salt cake staging and handling area near Rotary Furnace #6.
Photo #:16 (DSCN2523) Description: Facing northeast, photo of Baghouse #6.
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Photo Log - Real Alloy Recycling, Inc. - Post Falls
Photo #:17 (DSCN2526) Description: Facing southwest, photo of visible emissions near the rear of the Rotary Furnace #3 enclosure.
Photo #:18 (IMG_0932) Description: Photo of the baghouse leak detection probe. Photo was provided post-inspection via email by Jeff Bohannon.
Photo #:19 (IMG_0927) Description: Photo of the location of the baghouse leak detection probe. Photo was provided post-inspection via email by Jeff Bohannon.
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Complete list of photographs taken during the inspection:
DSCN2487 - Facing southwest, photo of finished recycled scrap ingots (RSI) produced at the facility, stored on-site ready for shipment.
DSCN2488 - Facing northeast, photo of shredded "popcorn" scrap aluminum being stored on- site (foreground). RSI's also stored in area (background).
DSCN2489 - Facing north, photo of Rotary Furnace #3 enclosure and capture hood. DSCN2490 - Facing north, photo of Rotary Furnace #3 capture hood and ducting. DSCN2491 - Facing northeast, photo of the salt cake storage/cooling area and associated
capture hood near Rotary Furnace #3. DSCN2492 - Facing north, photo of the scrap staging area near heat/charge bay. DSCN2493 - Facing northeast, photo of Rotary Furnace #3 capture hood and ducting. DSCN2494 - Facing northeast, photo of Rotary Furnace #3 capture hood and ducting. DSCN2495 - Facing south, photo of Baghouse #9. Used as a pollution control device for
the salt cake staging and handling area near Rotary Furnace #3. DSCN2496 - Facing south, photo of Baghouse #9. Used as a pollution control device for
the salt cake staging and handling area near Rotary Furnace #3. DSCN2497 -Facing east, photo of Baghouse #3 outdoor ducting to cooling tower. DSCN2498 -Facing northwest, photo of Baghouse #3 cooling tower. DSCN2499 -Facing west, photo of Baghouse #3. DSCN2500 -Facing northwest, photo of Baghouse #3 and associated cell dampers. DSCN2501 -Facing north, photo of a damper arm for a Baghouse #3 cell. DSCN2502 -Facing southeast, photo of the Trona feed control system for Baghouse #3. DSCN2503 -Facing east, photo of the Trona feed system for Baghouse #3. DSCN2504 -Photo of a page from the September 2021 Daily Operation Inspection Log
for Baghouse #3. DSCN2505 -Facing northeast, photo of a loader being weighed prior to adding aluminum
to Rotary Furnace #3. DSCN2506 -Facing southwest, photo of the dross storage area near Rotary Furnace #3. DSCN2507 -Photo of monthly (August 2021) Trona Feed Flow Rate Verification Log. DSCN2508 -Photo of the Baghouse #3 operation/control display. DSCN2509 -Photo of Malfunction Occurrence Log for Baghouse #6. Alarm Testing
occurred 08/31/2021. DSCN2510 -Photo of the Smart Air Velocity Transmitter installed on the Baghouse #3
stack. Photo taken by Zach Hedgpeth (EPA). DSCN2511- Photo of the Smart Air Velocity Transmitter installed on the Baghouse #3
stack. Photo taken by Zach Hedgpeth (EPA). DSCN2512 - Photo of the Smart Air Velocity Transmitter installed on the Baghouse #3
stack. Photo taken by Zach Hedgpeth (EPA). DSCN2513 - Photo of the Smart Air Velocity Transmitter probe inside the Baghouse #3
stack. Photo taken by Zach Hedgpeth (EPA). DSCN2514- Photo of the thermocouple installed to the Baghouse #3 outlet. DSCN2515- Photo of thermocouple installed to Baghouse #3 inlet.
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DSCN2516- Photo of the monthly (August 2021) PCME Drift Check and Response Test for Baghouse #3.
DSCN2517- Photo of the semi-annual inlet thermocouple calibration test for Baghouse #3, dated February 25, 2021.
DSCN2518- Photo semi-annual inlet bag break test for Baghouse #3, dated August 30, 2021.
DSCN2519- Facing north, photo of the salt cake storage/cooling area and associated capture hood near Rotary Furnace #6.
DSCN2519- Facing north, photo of the salt cake storage/cooling area and associated capture hood near Rotary Furnace #6.
DSCN2520 - Facing south, photo of Rotary Furnace #6 capture hood and ducting. DSCN2521- Photo of the semi-annual inlet thermocouple calibration test for Baghouse
#3, dated August 31, 2021. DSCN2522- Photo of labeling on Rotary Furnace #6 enclosure. DSCN2523- Facing northeast, photo of Baghouse #6. DSCN2524 - Facing north, photo of Baghouse #8. Used as a pollution control device for
the salt cake staging and handling area near Rotary Furnace #6. DSCN2525 - Photo of the super sacks attachment method on Baghouse #8. DSCN2526 - Facing southwest, photo of visible emissions near the rear of the Rotary
Furnace #3 enclosure. DSCN2527 - Photo of an example (September 2021) baghouse operational checklist. DSCN2528 - Photo of Malfunction Occurrence Log for Baghouse #3. Dated 08/24/21. IMG_0927 - Photo of the location of the baghouse leak detection probe. Photo was
provided post-inspection via email by Jeff Bohannon. IMG_0932 - Photo of the baghouse leak detection probe. Photo was provided post-
inspection via email by Jeff Bohannon.
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ATTACHMENT E
Records Request (at the time of the Closing Conference)
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