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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 inrm you that the Oregon Department of Enviroental Quality (DEQ) has issued you a civil penalty of $1,296,885 r violations of the Oregon Title V Operating Permit r your aluminum casthouse at 2929 West Second Street in The Dalles. Specifically, you violated multiple permit conditions derived om the National Emission Standards r Hazardous Air Pollutants, Subpart RRR r 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 ee 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 cility's induction aces that does not meet the definition of clean charge. In addition to violating the clean charge requirement, om at least May 1, 2018 to April 24, 2019 you iled to conduct monitoring and training required by the Permit and designed to prevent the acceptance and processing of unclean aluminum scrap at the cility. More specifically, you iled to inspect each load of incoming scrap material accepted by the cility to ensure that it is clean. You also iled to inspect the material prior to charging the aces and to conduct required employee training. In addition to the violations described above, you exceeded the operating limit r addition of reactive flux, a chloride and fluoride salt added in your holder aces, on fiſty eight occasions between May 2, 2018 and March 12, 2019. You also iled to calculate and record the rate at which you used reactive flux in your holder aces 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, r additional Permit violations including: ilure to keep operating logs r your Spinning Nozzle Inert Floatation (SNIF) degassing units, ilure to keep rnace scale calibration records, ilure to maintain labels on your emissions units that describe operating requirements, iling to inspect those labels, iling to operate and maintain one of your holder aces
