regon Kate Brown, Governor
January 8, 2020
CERTIFIED MAIL: 7017 1450 0000 8310 3213
Hydro Extrusion USA, LLC c/o Corporation Service Company, Registered Agent 1127 Broadway Street NE Suite 310 Salem, OR 97301
Re: Notice of Civil Penalty Assessment and Order Case No. AQN-ER-2019-199
Department of Environmental Quality Office of Compliance and Enforcement
700 NE Multnomah Street, Suite 600
Portland, OR 97232-4100
(503) 229-5696
FAX (503) 229-5100
TTY 711
This letter is to inform you that the Oregon Department of Environmental Quality (DEQ) has issued you a civil penalty of $1,296,885 for violations of the Oregon Title V Operating Permit for your aluminum casthouse at 2929 West Second Street in The Dalles.
Specifically, you violated multiple permit conditions derived from the National Emission Standards for Hazardous Air Pollutants, Subpart RRR for Secondary Aluminum Production (NESHAP RRR). The Permit requires that you process only "clean charge" material, which is defined in the NESHAP RRR to include aluminum scrap that is "known by the owner or operator to be entirely free of paints, coatings, and lubricants". Despite the express requirement in the Permit to process only clean charge, between at least July 2018 and August 8, 2019, you processed aluminum scrap in the facility's induction furnaces that does not meet the definition of clean charge.
In addition to violating the clean charge requirement, from at least May 1, 2018 to April 24, 2019 you failed to conduct monitoring and training required by the Permit and designed to prevent the acceptance and processing of unclean aluminum scrap at the facility. More specifically, you failed to inspect each load of incoming scrap material accepted by the facility to ensure that it is clean. You also failed to inspect the material prior to charging the furnaces and to conduct required employee training.
In addition to the violations described above, you exceeded the operating limit for addition of reactive flux, a chloride and fluoride salt added in your holder furnaces, on fifty eight occasions between May 2, 2018 and March 12, 2019. You also failed to calculate and record the rate at which you used reactive flux in your holder furnaces between May 1, 2018 and March 18, 2019. Between March 19, 2019 and April 30, 2019, you kept no flux addition records.
The Notice also cites you, without penalty, for additional Permit violations including: failure to keep operating logs for your Spinning Nozzle Inert Floatation (SNIF) degassing units, failure to keep furnace scale calibration records, failure to maintain labels on your emissions units that describe operating requirements, failing to inspect those labels, failing to operate and maintain one of your holder furnaces
Hydro Extrusion USA, LLC Case No. AQN-ER-2019-199 Page 4
cc: Dave Bolich, Health, Safety and Environmental Manager, Hydro Extrusion USA, LLC, 2929 West Second Street, The Dalles, OR 97058 Chase Reeves, Plant Manager, Hydro Extrusion USA, LLC, 2929 West Second Street, The Dalles, OR 97058 Nancy Cisek, Senior Legal Counsel, Hydro Extrusion USA, LLC, 6250 North River Road, Suite 5000, Rosemont, IL 60018 Clay Long, Director, Environmental Programs & Sustainability, Hydro Extrusion USA, LLC, 318 E. Liberty Street, Schuylkill Haven, PA 17972 Ashley Jones, Trinity Consultants, 1391 N. Speer Blvd, Suite 350, Denver, CO 80204 Katie McClintock, US EPA, Region 10, 1200 Sixth A venue, Seattle, WA 98101 Zach Hedgepeth, US EPA, Region 10, 1200 Sixth Avenue, Seattle, WA 98101 Paul De Vito, DEQ Frank Messina, DEQ Mark Ludwiczak, DEQ Mark Bailey, DEQ Accounting, DEQ Donald Hendrix, AQ, DEQ