West Virginia Department of Environmental Protection

Division of Air Quality

	


Pursuant to

Title V

of the Clean Air Act

Issued to:

	








 !" "#

		



	


Issued: April 13, 2010 • Effective: April 27, 2010

Expiration: April 13, 2015 • Renewal Application Due: October 13, 2014
Title V Operating Permit R30-03500002-2010 Page 1 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Permit Number: R30-03500002-2010

Permittee: Century Aluminum of West Virginia, Inc.

Facility Name: Ravenswood Operations

Permittee Mailing Address: P. O. Box 98 Ravenswood, WV 26164-0098

This permit is issued in accordance with the West Virginia Air Pollution Control Act (West Virginia Code §§ 22-5-1 et seq.) and

45CSR30 — Requirements for Operating Permits. The permittee identified at the above-referenced facility is authorized to

operate the stationary sources of air pollutants identified herein in accordance with all terms and conditions of this permit.

Facility Location: Ravenswood, Jackson County, West Virginia

Telephone Number: 304-273-7300

Type of Business Entity: Corporation

Facility Description: Primary Aluminum Plant

SIC Codes: 3334

UTM Coordinates: 428.3 km Easting • 4308.6 km Northing • Zone 17

Permit Writer: Bobbie Scroggie

Any person whose interest may be affected, including, but not necessarily limited to, the applicant and any person who

participated in the public comment process, by a permit issued, modified or denied by the Secretary may appeal such action

of the Secretary to the Air Quality Board pursuant to article one [§§ 22B-1-1 et seq.], Chapter 22B of the Code of West

Virginia. West Virginia Code §22-5-14.

Issuance of this Title V Operating Permit does not supersede or invalidate any existing permits under 45CSR13, 14 or 19,

although all applicable requirements from such permits governing the facility's operation and compliance have been

incorporated into the Title V Operating Permit.
Title V Operating Permit R30-03500002-2010 Page 2 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Table of Contents

1.0. Emission Units and Active R13, R14, and R19 Permits . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1.1. Emission Units . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1.2. Active R13, R14, and R19 Permits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.0. General Conditions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.1. Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.2. Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.3. Permit Expiration and Renewal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2.4. Permit Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2.5. Reopening for Cause . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2.6. Administrative Permit Amendments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.7. Minor Permit Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.8. Significant Permit Modification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.9. Emissions Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.10. Off-Permit Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.11. Operational Flexibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.12. Reasonably Anticipated Operating Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2.13. Duty to Comply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.14. Inspection and Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.15. Schedule of Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.16. Need to Halt or Reduce Activity not a Defense . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.17. Emergency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.18. Federally-Enforceable Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.19. Duty to Provide Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.20. Duty to Supplement and Correct Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.21. Permit Shield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.22. Credible Evidence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.23. Severability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.24. Property Rights . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.25. Acid Deposition Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

3.0. Facility-Wide Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

3.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

3.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

3.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

3.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

3.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

3.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

3.7. Permit Shield . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

4.0. Manufacturing Process Groups A-G Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

4.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

4.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

4.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

4.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

4.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Title V Operating Permit R30-03500002-2010 Page 3 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

5.0. Manufacturing Process Group H Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

5.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

5.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

5.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

5.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

5.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

5.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

6.0. Storage Structure Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

6.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

6.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

6.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

6.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

6.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

6.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

7.0. Manufacturing Process Group I Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

7.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

7.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

7.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

7.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

7.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

7.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

8.0. Fuel Burning Unit Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

8.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

8.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

8.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

8.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

8.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

8.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

9.0. Primary Aluminum MACT Sources Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

9.1. Limitations and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

9.2. Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

9.3. Testing Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

9.4. Recordkeeping Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

9.5. Reporting Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

9.6. Compliance Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

APPENDIX A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
Title V Operating Permit R30-03500002-2010 Page 4 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

1.0 Emission Units and Active R13, R14, and R19 Permits

1.1. Emission Units

Emission

Unit ID

Emission

Point ID Emission Unit Description YearInstalled

Design

Capacity Control Device

GROUP A - BARGE UNLOADING

001P101

001P101A 001S107 Vacuum Truck Unloading/AIF3

 - Cryolite Railcar

Unloading and Conveyor 1957 400,000 lb/hr Baghouse DC-4 905

001P102 Fugitives Barge Unloading (Hartmann Unloader System) 1977 -- --

001P103 001S110 No. 1 North Unloader 1977 350,000 lb/hr Fabric Dust Collector

001P104 001S111 No. 2 South Unloader 1977 350,000 lb/hr Fabric Dust Collector

001P105 001S101

001S102 Conveyor A 1977 960,000 lb/hr Baghouse DC-1 901Baghouse DC-2A 902

001P106 001S102

001S103 Conveyor B 1977 960,000 lb/hr Baghouse DC-2A 902

Baghouse DC-2B 903

001P107 001S102 Alumina Silo No. 1 West 741 1977

960,000 lb/hr

Baghouse DC-2A 902

001P108 001S103 Alumina Silo No. 2 East 742 1977 Baghouse DC-2B 903

001P109 001S106 Parallel Screens 701/702/703/704 1977 240,000 lb/hr Baghouse DC-3 904

001P110 001S108 Conveyor 1 1977 400,000 lb/hr Baghouse DC-3 904

001P111 001S109 Conveyor 2 1977 360,000 lb/hr Baghouse DC-5 906

001P112 001S106 (4) Tote Bins 1977 150 lb/hr Baghouse DC-3 904

001P113 001S104

001S105 Carbon Ore Bin 11-9206 1976 30,000 lb/hr Baghouse DC11-412

Baghouse DC11-429

001P113A -- Blending Station No. 4 Belt 1977 30,000 lb/hr Baghouse DC11-429

001P114 001S108 Fresh Alumina Bin 11-9201 1976 400,000 lb/hr Baghouse DC11-102

001P115 001S108 Vibrating Fresh Alumina Screen 1976 40,000 lb/hr Baghouse DC11-102

001P116 001S108 Fresh Ore Booth Conveying System 1976 40,000 lb/hr Baghouse DC11-102

GROUP B - MATERIAL TRANSFER TO/FROM POTROOM

001P201

001P201A

001P201B

001P201C

001P201D

001P201E

001P201F

001S201

001S201

001S203

001S205

001S205

001S205

001S204

Air Slide 372

Air Lift 374, Disengaging Bin 374

Air Slide 470

Air Lift 471

Disengaging Bin 471, Air Slides 404 & 472

Air Slide 473

Air Slide 405, Air Slide 474

1976 40,000 lb/hr

Baghouse DC 395

Baghouse DC 395

Baghouse DC 495

Baghouse DC 476

Baghouse DC 476

Baghouse DC 476

Baghouse DC 406
Title V Operating Permit R30-03500002-2010 Page 5 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

001P202

001P202A

001P202B

001P202C

001P202D

001S202

001S206

001S204

001S204

001S202

Air Slide 302

Air Slide 400

Air Slide 403

Air Lift 401, Disengaging Bin 401

Air Lift 304, Disengaging Bin 304

1976 40,000 lb/hr

Baghouse DC 430

Baghouse DC 267

Baghouse DC 406

Baghouse DC 406

Baghouse DC 430

001P203

001P203A

001S207

001S208

Air Slide 021, Air Slide 025, Air Lift 022,

Disengaging Bin 022

Air Lift 250, Disengaging Bin 250

1976 80,000 lb/hr

Baghouse DC 030

Baghouse DC 108

001P204 001S210 Parallel Vibrating Screens 004 and 014 and Tote,

Air Slide 102 1976 80,000 lb/hr Baghouse DC 425

001P205 001S210 Alumina Bin 125 1976 80,000 lb/hr Baghouse DC 425

001P206 001S209 Air Slide 172, Air Lift 174, Disengaging Bin 174 1976 80,000 lb/hr Baghouse DC 178

001P207 001S209 Alumina Bin 195 1957 80,000 lb/hr Baghouse DC 178

004P105 004S101 Potroom Silo 1A 1957 360,000 lb/hr Baghouse DC 1A

004P106 004S102 Potroom Silo 1C 1957 360,000 lb/hr Baghouse DC 1C

004P107 004S103 Potroom Silo 1D 1957 40,000 lb/hr Baghouse DC 1D

004P108 004S104 Potroom Silo 1B 1957 360,000 lb/hr Baghouse DC 1B

004P109 004S105 Potroom Silo 2A 1957 360,000 lb/hr Baghouse DC 2A

004P110 004S106 Potroom Silo 2C 1957 40,000 lb/hr Baghouse DC 2C

004P111 004S107 Potroom Silo 2D 1957 40,000 lb/hr Baghouse DC 2D

004P112 004S108 Potroom Silo 2B 1957 360,000 lb/hr Baghouse DC 2B

004P205 004S201 Potroom Silo 3A 1957 40,000 lb/hr Baghouse DC 3A

004P206 004S202 Potroom Silo 3C 1957 360,000 lb/hr Baghouse DC 3C

004P207 004S203 Potroom Silo 3D 1957 360,000 lb/hr Baghouse DC 3D

004P208 004S204 Potroom Silo 3B 1957 40,000 lb/hr Baghouse DC 3B

004P209 004S205 Potroom Silo 4A 1957 40,000 lb/hr Baghouse DC 4A

004P210 004S206 Potroom Silo 4C 1957 360,000 lb/hr Baghouse DC 4C

004P211 004S207 Potroom Silo 4D 1957 360,000 lb/hr Baghouse DC 4D

004P212 004S208 Potroom Silo 4B 1957 360,000 lb/hr Baghouse DC 4B

004P217 004S301 Fill Station 1957 20,000 lb/hr Phase 2 Scrubber

004P218 004S301 Bath Cart 1957 20,000 lb/hr Phase 2 Scrubber

004P219 004S301 Apollo Fill Station 1957 40,000 lb/hr Phase 2 Scrubber

004P301 004S304 Air Slide 270, Air Slide 271, Air Slide 277 1976 40,000 lb/hr Baghouse DC 273

004P302 004S302 Air Slide 200, Air Slide 207 1976 40,000 lb/hr Baghouse DC 203
Title V Operating Permit R30-03500002-2010 Page 6 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

004P303 004S304 Air Slide 370, Air Slide 371 1976 40,000 lb/hr Baghouse DC 273

004P304 004S303 Air Slide 300, Air Slide 301 1976 40,000 lb/hr Baghouse DC 262

004P305 001S202 Air Slide 264, Air Slide 303 1976 40,000 lb/hr Baghouse DC 430

GROUP C - BATH PROCESSING

001P301 N/A Pure Bath Bin 75 T 1957

 20,000 lb/hr

--

001P302 N/A Pure Bath Bin 125 T 1957 --

001P303 N/A Contaminated Bath Bin 125T 1957 --

001P304 001S303 Feed Storage Bin 156-103 1957 26,600 lb/hr Baghouse DC156-400

001P305 001S303 Cascade Mill 156-200 1957 26,600 lb/hr Baghouse DC156-400

001P306 001S303 Magnetic Separator 156-214 1957 26,600 lb/hr Baghouse DC156-400

001P307 001S303 Skip Bucket 1957 20,000 lb/hr Baghouse DC156-400

001P308 001S303 Skip Bucket 1957 20,000 lb/hr Baghouse DC156-400

001P309 001S303 Vibrating Screen 156-203 1957 26,600 lb/hr Baghouse DC156-400

001P310 001S303 Fines Storage Bin 1957 26,600 lb/hr Baghouse DC156-400

001P311 001S303 Bagging Machine 156-501 1957 26,600 lb/hr Baghouse DC156-400

001P312

001P312A

001P312B

001P312C

001P312D

001S305

001S302

001S301

001S304

001S301

Cyclone 156-206

Air Lift 156-304, Disengaging Bin 156-305

Air Slide 156-309

Air Lift 156-309

Disengaging Bin 156-310

1957 26,600 lb/hr

Baghouse DC156-207

Baghouse DC156-407

Baghouse DC156-409

Baghouse DC156-412

Baghouse DC156-412

001P313 001S304 Bath Storage 156-317 1957

 20,000 lb/hr

Baghouse DC156-412

001P314 001S304 Bath Storage 156-315 1957 Baghouse DC156-412

001P314A 001S304 300 Belt 1957 Baghouse DC156-412

001P315 001S303 Skip Hoist 1957 20,000 lb/hr Baghouse DC156-400

GROUP D - ANODE MIX, PRESS & PREP.

002P136 -- Liquid Pitch Unloading 1997 -- --

002P137 -- Liquid Pitch Storage Tank No.1 1997 -- --

002P138 -- Liquid Pitch Storage Tank No. 2 1997 -- --

GROUP E - CATHODE PASTE

002P201 002S101 Vibrating Screening/Sizing 1957 40,000 lb/hr Baghouse R-3

002P202 002S201 Conveyor K-10 1957 40,000 lb/hr Baghouse R-3

002P203 002S201 Roll Crusher M-7 1957 40,000 lb/hr Baghouse R-3
Title V Operating Permit R30-03500002-2010 Page 7 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

002P204 002S201 Mill Feed Bin 1957 40,000 lb/hr Baghouse R-3

002P205 002S201 Fine Grind Mill D-2 1957 40,000 lb/hr Baghouse R-3

002P206 002S201 Conveyor K-11 1957 40,000 lb/hr Baghouse R-3

002P207 002S201 Air Classifier G-2 1957 40,000 lb/hr Baghouse R-3

002P208 002S201 Cyclone P-2 1957 40,000 lb/hr Baghouse R-3

002P209 002S201 Coal Fines Storage Bin 1957 40,000 lb/hr Baghouse R-3

002P210 002S201 Coal Intermediate Storage Bin 1957 40,000 lb/hr Baghouse R-3

002P211 002S201 Coal Storage Bin 1957 40,000 lb/hr Baghouse R-3

002P212 002S201 Coal Fines Storage Bin 1957 40,000 lb/hr Baghouse R-3

002P214 002S201 Weigh Larry 1957 40,000 lb/hr Baghouse R-3

002P215 002V203

002S202

Batch Mixer AF-17 1957 40,000 lb/hr Baghouse R-7

002P216 Batch Mixer AF-18 1957 40,000 lb/hr Baghouse R-7

002P218 -- Press Reject Conveyor 1957 40,000 lb/hr --

002P219 -- Green Scrap Storage Pile 1957 40,000 lb/hr --

002P220 002S202 Roll Crusher M-5C 1957 40,000 lb/hr Baghouse R-7

002P221 002S202 Roll Crusher M-5B 1957 40,000 lb/hr Baghouse R-7

GROUP F - COAL AND COKE UNLOADING

002P301

002P301A

002P301B

--

002S301

--

Coal, Coke, and Pitch Unloading

Feeder AA-1, Feeder V-1, Belt 1-1

Bucket Elevator S-1. Screws K-12, K-13, K-14

1957

140,000 lb/hr

140,000 lb/hr

140,000 lb/hr

--

Baghouse R-1

--

002P302 -- Coal and Coke Storage Silos 1-4 and 8-11(8) 1957 140,000 lb/hr --

002P303 -- Belt 1-3 1957 120,000 lb/hr --

002P304 002S101 Roll Crusher M-3 1957 80,000 lb/hr R232 Dust Coll.

002P305 002S101 K-3A, K-3B, S-3, Y-1, AM-1&2 Vibrating

Screen 1957 160,000 lb/hr R232 Dust Coll.

002P306 002S303 Screw K-27, Bin 18, Bin 19, Disc W01, Fine Grind

Mill D-1 1957 100,000 lb/hr Baghouse R-2

002P307 002S303 Air Classifier G-2 1957 50,000 lb/hr Baghouse R-2

002P308 002S303 Cyclone P3 1957 50,000 lb/hr Baghouse R-2

002P309 002S303 Cyclone P1 1957 50,000 lb/hr Baghouse R-2

002P310 002S101 Feeder AA-20, Roll Crusher M-6 1957 60,000 lb/hr R232 Dust Coll.

002P310A 002S101 Bin 50 1957 60,000 lb/hr R232 Dust Coll.
Title V Operating Permit R30-03500002-2010 Page 8 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

002P311 002S101 Bucket Elevator S-6, Vibrating Screen AM-4 1957 60,000 lb/hr R232 Dust Coll.

002P312 002S101 Screws K-5, K-20, Coke Fines Bins 53-68 1957 50,000 lb/hr R232 Dust Coll.

002P313 002S101 Screw Conveyor K-18, Coke Coarse Bins 20-31 1957 50,000 lb/hr R232 Dust Coll.

002P314 002S101 Screw Conveyor K-19, Anode Butts Bins 36-41 1957 50,000 lb/hr R232 Dust Coll.

003P315 -- Bin 17 1957 -- --

GROUP G - ANODE BLOCKS

003P101 003S105 51 Bin 1957 40,000 lb/hr Bin Vent 51BV

003P102 003S101 Belt Conveyor BC-5 1957 93,600 lb/hr --

003P103 003S101 Coke Tubs 1957 60,000 lb/hr Baghouse No. 1

003P104 003104 15 Ton Make-Up Bin 1957 40,000 lb/hr --

003P106 003S103A

003S103B Portable ECL Bins 1957 60,000 lb/hr ECL Baghouse

003P111 003S102 Anode Cleaner 1957 1,000 lb/hr Baghouse No. 2

003P113 003S101 Screening Station 1957 60,000 lb/hr Baghouse No. 1

003P114 003S101 Vibramill 1957 60,000 lb/hr Baghouse No. 1

003P115 -- Bucket Elevator 1957 2,000 lb/hr --

003P116 003S102 Bucket Elevator 1957 2,000 lb/hr --

003P117 003S102 Anode Bins, Cleaning Station 1957 2,000 lb/hr --

003P118 003S101 Belt Conveyor BC-6 1957 60,000 lb/hr Baghouse No. 1

003P119 003S101 Screen Hopper 1957 60,000 lb/hr Baghouse No. 1

003P120 003S101 Screw Conveyor SC-1 1957 60,000 lb/hr Baghouse No. 1

003P201

003P201A

003S203

003S201

No. 2 Bin Fresh Alumina

Air Slide 201 1976 30,000 lb/hr 10,000 lb/hr

Baghouse DC11-407

Baghouse DC11-570

003P202 003S202 No. 3 Bin, Air Slide 300, Air Lift 300,

Disengaging Bin 300 1976 10,000 lb/hr Baghouse DC 11-470

003P203 003S201 Reacted Booth System 1976 30,000 lb/hr Baghouse DC11-570

GROUP H - RODDING DEPARTMENT

003P301 003S309 Horizontal Press 1957 60,000 lb/hr Bertha DC

003P302 003S309 Cone Crusher 1957 60,000 lb/hr Bertha DC

003P303 003S309 Secondary Crusher 1957 60,000 lb/hr Bertha DC

003P304 003S302 Belt Conveyor #4 1957 60,000 lb/hr Baghouse No. 2

003P305 003S304 Belt Conveyor #24 1957 60,000 lb/hr Baghouse No. 2
Title V Operating Permit R30-03500002-2010 Page 9 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

003P306 003S302 Butt Removal 1957 60,000 lb/hr Baghouse No. 2

003P307 003S302 Butt Crusher 1957 60,000 lb/hr Baghouse No. 2

003P308 -- Magnetic Separator 1957 60,000 lb/hr --

003P309 003V302 Thimble Press 1957 6,000 lb/hr --

003P310 003S303 Thimble Cleaner, Belts 29, 29A, and 30 1957 6,000 lb/hr Baghouse No. 3

003P311 003S304 (3) Electric Arc Furnaces 1957 60,000 lb/hr Electric Arc DC

003P312 003S303 Rod Cleaning 1957 60 lb/hr Baghouse No. 3

003P313 003V306 Stub Dryer 1957 -- --

003P314 003S304 Hole Cleaner 1957 225 lb/hr Electric Arc DC

003P315 -- Hole Dryer 1957 -- --

003P316 003S304 Pouring and Assembly Station 1957 75,000 lb/hr Electric Arc DC

003P317 003V308 Chamfer 1957 -- --

003P318 003V305 Stub Saw 1957 -- --

003P319 003V305 Welding Station 1957 -- --

003P320 003V307 Thimble Press, Combination Press 1957 60,000 lb/hr --

003P321 003S302 Belt Conveyor #22 1957 60,000 lb/hr Baghouse No. 2

003P322 003S302 Belt Conveyor #23 1957 60,000 lb/hr Baghouse No. 2

003P323 003S305 Rough Cleaning Machine 1957 60,000 lb/hr Baghouse No. 5

003P324 003S309 Anode Fine Cleaning (Shot Blast) Machine 1957 60,000 lb/hr Bertha DC

003P325 003S305 Bath Belt Conveyor 1957 60,000 lb/hr Baghouse No. 5

003P326 003S305 Surge Hopper 1957 60,000 lb/hr Baghouse No. 5

003P327 003S305 Crushed Feed Conveyor 1957 60,000 lb/hr Baghouse No. 5

003P328 003S305 Bath Crusher 1957 60,000 lb/hr Baghouse No. 5

003P329 003S305 Bath Screen Feed Conveyor 1957 60,000 lb/hr Baghouse No. 5

003P330 003S305 Bath Screen 1957 60,000 lb/hr Baghouse No. 5

003P331 003S305 Surge Hopper 1957 60,000 lb/hr Baghouse No. 5

003P332 003S305 Bath Silo 1957 60,000 lb/hr Baghouse No. 5

003P333 003S310 No. 1 Storage Bin 1957 0.403 lb/hr Bin Vent 971BV
Title V Operating Permit R30-03500002-2010 Page 10 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

GROUP I - MISCELLANEOUS SOURCES

005P104A 005S108 Paste Mixer 1957 -- Dust Collector

005P105 005S101 Carpenter Shop Saws 1957 -- Cyclone

005P106 005S109 Paint Booth used for storage 1957 -- --

005P107 005S110 Paste Heaters 1957 -- --

005P108 005S111 Shell Rebuild 1957 -- --

005P109 005S102 Reduction Cell Super Structure Cleaning Booth 1957 -- Pot Lining Baghouse

005P110 005S114 Spent Pot Lining Disposal 1976 1600 lb/hr SPL Dust Collector

005P111 005S104A Module Cleaning Booth 1976 -- Baghouse

005P112 005S113 Rod Preheaters 1957 -- --

005P113 -- Crucible Heaters 2001 -- --

005P114 005S115 TAC System Unit #1 2001 46,000 lb/hr Baghouse R-442

005P115 005S115 TAC System Unit #2 2001 46,000 lb/hr Baghouse R-442

005P116 005S112 Crucible Cleaner 2009 2,000 lb/hr Baghouse 005C112

005P117 005S112 Siphon Cleaner 2009 150 lb/hr Baghouse 005C112

FUEL BURNING SOURCES

002P139 002S110 Hot Oil Heater No. 1 1997 1.25 mmBtu/hr --

002P140 002S111 Hot Oil Heater No. 2 1997 1.25 mmBtu/hr --

005P102 005S106 Boiler No. 2; Superior Boilers 223V 1957 43.5 mmBtu/hr --

005P103 005S107 Boiler No. 4; Cleaver Brooks D76-RH 1997 76.0 mmBtu/hr --

005P104 005S106 Boiler No. 5; English Boiler & Tube, Inc. 30-SD250 2003 37.5 mmBtu/hr --

PRIMARY ALUMINUM MACT SOURCES

002P101 002S101 Scrap & Rejects Storage Bin North 1957 60,000 lb/hr

Venturi Reactor VR371

Sonair Baghouse R300

002P102 002S101 Scrap & Rejects Storage Bin South 1957 60,000 lb/hr

002P103 002S101 Coke Fines Storage Bin North 1957 100,000 lb/hr

002P104 002S101 Coke Fines Storage Bin South 1957 100,000 lb/hr

002P105 002S101 Coke Coarse Storage Bin North 1957 100,000 lb/hr

002P106 002S101 Coke Coarse Storage Bin South 1957 100,000 lb/hr

002P107 002S101 Crushed Anode Butts Storage Bin North 1957 100,000 lb/hr

002P108 002S101 Crushed Anode Butts Storage Bin South 1957 100,000 lb/hr
Title V Operating Permit R30-03500002-2010 Page 11 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

002P109 -- Hard Pitch Storage Bin North 1957 -- --

002P110 -- Hard Pitch Storage Bin South 1957 -- --

002P111 002S101 Auto Scale AL-1 1957 100,000 lb/hr

Venturi Reactor VR371

Sonair Baghouse R300

002P112 002S101 Auto Scale AL-2 1957 100,000 lb/hr

002P113 002S101 Screw Conveyor K-101 1957 100,000 lb/hr

002P114 002S101 Batch Car 1957 100,000 lb/hr

002P115 002S109 South Mixers 1-8 1957 100,000 lb/hr Baghouses 002C104,

002C105 002P116 002S109 North Mixers 9-16 1957 100,000 lb/hr

002P117 002S109 Belt Conveyor I-6 1957 64,000 lb/hr Baghouses 002C104,

002C105 002P118 002S109 Belt Conveyor I-7 1957 64,000 lb/hr

002P119 002S109 Belt Conveyor V-4 1957 128,000 lb/hr

Baghouses 002C104,

002C105

002P120 002S109 Belt Conveyor I-8 1957 128,000 lb/hr

002P121 002S109 Belt Conveyor I-9 1957 128,000 lb/hr

002P122 002S109 Belt Conveyor I-10 1957 128,000 lb/hr

002P123 002S109 Cooling Screw AG-1 1957 128,000 lb/hr

Baghouses 002C104,

002C105

002P124 002S109 Cooling Screw AG-2 1957 128,000 lb/hr

002P125 002S109 Cooling Screw AG-3 1957 128,000 lb/hr

002P126 002S109 Cooling Screw AG-4 1957 128,000 lb/hr

002P127 002S109 Disc Feeder W11 1957

128,000 lb/hr Baghouses 002C104,

002C105 002P128 002S109 Disc Feeder W12 1957

002P129 002S109 Anode Press AJ-1 1957

128,000 lb/hr Baghouses 002C104,

002C105 002P130 002S109 Anode Press AJ-2 1957

002P131 002S109 Belt Conveyor I-11 1957 128,000 lb/hr

Baghouses 002C104,

002C105 002P132 002S109 Screw Conveyor K-103 1957 128,000 lb/hr

002P133 002S109 Green Scrap Area 1957 128,000 lb/hr

002P134 002S109 Fresh Coke Fines Storage Tank 1957 50,000 lb/hr Baghouse 002C104

002P135 002S109 Screw Conveyor K-321 1957 2,400 lb/hr Baghouse 002C104

002P141 002S101 Screw Conveyor K-100 1957 100,000 lb/hr Baghouse 002C106

002P142 002S101 Collecting Hopper 1957 100,000 lb/hr Baghouse 002C106

002P143 002S109 K-312 Screw Conveyor 1957 50,000 lb/hr Baghouse 002C104
Title V Operating Permit R30-03500002-2010 Page 12 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Emission

Point ID Emission Unit Description Year

Installed

Design

Capacity Control Device

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

003P109 003S204 Building No. 52 Ring Furnace 1957 Capacity is

based on green

anodes

capacity

Anode Bake Furnace

Scrubber System

(28 stacks)

003C205 (bypass) 003P110 003S204 Building No. 53 Ring Furnace 1957

004P101

004S301

Reduction Cells Potroom 1A 1957 14,500 lb/hr

Scrubber 004C302

004P102 Reduction Cells Potroom 1B 1957 14,500 lb/hr

004P103 Reduction Cells Potroom 2A 1957 14,500 lb/hr

004P104 Reduction Cells Potroom 2B 1957 14,500 lb/hr

004P201 Reduction Cells Potroom 3A 1957 14,500 lb/hr

Scrubber 004C301

004P202 Reduction Cells Potroom 3B 1957 14,500 lb/hr

004P203 Reduction Cells Potroom 4A 1957 14,500 lb/hr

004P204 Reduction Cells Potroom 4B 1957 14,500 lb/hr

004P113 -- Ore Bucket - Line 1A 1957 120,000 lb/hr Baghouse DC 1

004P114 -- Ore Bucket - Line 1B 1957 120,000 lb/hr Baghouse DC 2

004P115 -- Ore Bucket - Line 2A 1957 160,000 lb/hr Baghouse DC 3

004P116 -- Ore Bucket - Line 2B 1957 160,000 lb/hr Baghouse DC 4

004P213 -- Ore Bucket - Line 3A 1957 120,000 lb/hr Baghouse DC 5

004P214 -- Ore Bucket - Line 3B 1957 120,000 lb/hr Baghouse DC 6

004P215 -- Ore Bucket - Line 4A 1957 120,000 lb/hr Baghouse DC 7

004P216 -- Ore Bucket - Line 4B 1957 120,000 lb/hr Baghouse DC 8

STORAGE TANKS

Emission Unit ID Emission Unit Description Orientation Capacity Tank Contents

Tank IEU-1 Gas station in parking lot (south) Horizontal 10,000 gal Diesel

Tank IEU-2 Gas station in parking lot (north) Horizontal 4,000 gal Kerosene

Tank IEU-3 Maintenance parking lot (south) Horizontal 550 gal Gasoline

Tank IEU-4 Near south cooling tower (boiler house) Vertical 15,000 gal Diesel

Tank IEU-5 Outside of bath processing Horizontal 4,000 gal Diesel

Tank IEU-6 Maintenance parking lot (south) Horizontal 550 gal Diesel

Tank IEU-7 Outside potrooms west passage (south) 4B Horizontal 2,000 gal Diesel
Title V Operating Permit R30-03500002-2010 Page 13 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

1.2. Active R13, R14, and R19 Permits

The underlying authority for any conditions from R13, R14, and/or R19 permits contained in this operating permit is

cited using the original permit number (e.g. R13-1234). The current applicable version of such permit(s) is listed

below.

Permit Number Date of Issuance

R13-0348 December 23, 1977

R13-201R June 10, 1997

R13-2140A August 29, 2003

R13-2431A March 17, 2009
Title V Operating Permit R30-03500002-2010 Page 14 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

2.0. General Conditions

2.1. Definitions

2.1.1. All references to the "West Virginia Air Pollution Control Act" or the "Air Pollution Control Act" mean those

provisions contained in W.Va. Code §§ 22-5-1 to 22-5-18.

2.1.2. The "Clean Air Act" means those provisions contained in 42 U.S.C. §§ 7401 to 7671q, and regulations

promulgated thereunder.

2.1.3. "Secretary" means the Secretary of the Department of Environmental Protection or such other person to whom

the Secretary has delegated authority or duties pursuant to W.Va. Code §§ 22-1-6 or 22-1-8 (45CSR§30-2.12.).

The Director of the Division of Air Quality is the Secretary's designated representative for the purposes of this

permit.

2.1.4. Unless otherwise specified in a permit condition or underlying rule or regulation, all references to a “rolling

yearly total” shall mean the sum of the monthly data, values or parameters being measured, monitored, or

recorded, at any given time for the previous twelve (12) consecutive calendar months

2.2. Acronyms

CAAA Clean Air Act Amendments

CBI Confidential Business Information

CEM Continuous Emission Monitor

CES Certified Emission Statement

C.F.R. or CFR Code of Federal Regulations

CO Carbon Monoxide

C.S.R. or CSR Codes of State Rules

DAQ Division of Air Quality

DEP Department of Environmental

Protection

FOIA Freedom of Information Act

HAP Hazardous Air Pollutant

HON Hazardous Organic NESHAP

HP Horsepower

lbs/hr Pounds per Hour

LDAR Leak Detection and Repair

m Thousand

MACT Maximum Achievable Control

Technology

mm Million

mmBtu/hr Million British Thermal Units per

Hour

mmft3

/hr Million Cubic Feet Burned per

Hour

NA or N/A Not Applicable

NAAQS National Ambient Air Quality

Standards

NESHAPS National Emissions Standards

for Hazardous Air Pollutants

NOx Nitrogen Oxides

NSPS New Source Performance

Standards

PM Particulate Matter

PM10 Particulate Matter less than

10μm in diameter

pph Pounds per Hour

ppm Parts per Million

PSD Prevention of Significant

Deterioration

psi Pounds per Square Inch

SIC Standard Industrial

Classification

SIP State Implementation Plan

SO2 Sulfur Dioxide

TAP Toxic Air Pollutant

TPY Tons per Year

TRS Total Reduced Sulfur

TSP Total Suspended Particulate

USEPA United States Environmental

Protection Agency

UTM Universal Transverse Mercator

VEE Visual Emissions Evaluation

VOC Volatile Organic Compounds
Title V Operating Permit R30-03500002-2010 Page 15 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

2.3. Permit Expiration and Renewal

2.3.1. Permit duration. This permit is issued for a fixed term of five (5) years and shall expire on the date specified

on the cover of this permit, except as provided in 45CSR§30-6.3.b. and 45CSR§30-6.3.c.

[45CSR§30-5.1.b.]

2.3.2. A permit renewal application is timely if it is submitted at least six (6) months prior to the date of permit

expiration.

[45CSR§30-4.1.a.3.]

2.3.3. Permit expiration terminates the source's right to operate unless a timely and complete renewal application has

been submitted consistent with 45CSR§30-6.2. and 45CSR§30-4.1.a.3.

[45CSR§30-6.3.b.]

2.3.4. If the Secretary fails to take final action to deny or approve a timely and complete permit application before the

end of the term of the previous permit, the permit shall not expire until the renewal permit has been issued or

denied, and any permit shield granted for the permit shall continue in effect during that time.

[45CSR§30-6.3.c.]

2.4. Permit Actions

2.4.1. This permit may be modified, revoked, reopened and reissued, or terminated for cause. The filing of a request

by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of

planned changes or anticipated noncompliance does not stay any permit condition.

[45CSR§30-5.1.f.3.]

2.5. Reopening for Cause

2.5.1. This permit shall be reopened and revised under any of the following circumstances:

a. Additional applicable requirements under the Clean Air Act or the Secretary's legislative rules become

applicable to a major source with a remaining permit term of three (3) or more years. Such a reopening

shall be completed not later than eighteen (18) months after promulgation of the applicable requirement.

No such reopening is required if the effective date of the requirement is later than the date on which the

permit is due to expire, unless the original permit or any of its terms and conditions has been extended

pursuant to 45CSR§§30-6.6.a.1.A. or B.

b. Additional requirements (including excess emissions requirements) become applicable to an affected

source under Title IV of the Clean Air Act (Acid Deposition Control) or other legislative rules of the

Secretary. Upon approval by U.S. EPA, excess emissions offset plans shall be incorporated into the permit.

c. The Secretary or U.S. EPA determines that 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.

d. The Secretary or U.S. EPA determines that the permit must be revised or revoked and reissued to assure

compliance with the applicable requirements.

[45CSR§30-6.6.a.]
Title V Operating Permit R30-03500002-2010 Page 16 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

2.6. Administrative Permit Amendments

2.6.1. The permittee may request an administrative permit amendment as defined in and according to the procedures

specified in 45CSR§30-6.4.

[45CSR§30-6.4.]

2.7. Minor Permit Modifications

2.7.1. The permittee may request a minor permit modification as defined in and according to the procedures specified

in 45CSR§30-6.5.a.

[45CSR§30-6.5.a.]

2.8. Significant Permit Modification

2.8.1. The permittee may request a significant permit modification, in accordance with 45CSR§30-6.5.b., for permit

modifications that do not qualify for minor permit modifications or as administrative amendments.

[45CSR§30-6.5.b.]

2.9. Emissions Trading

2.9.1. 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 provided for in the permit and that are in

accordance with all applicable requirements.

[45CSR§30-5.1.h.]

2.10. Off-Permit Changes

2.10.1. Except as provided below, a facility may make any change in its operations or emissions that is not addressed

nor prohibited in its permit and which is not considered to be construction nor modification under any rule

promulgated by the Secretary without obtaining an amendment or modification of its permit. Such changes

shall be subject to the following requirements and restrictions:

a. The change must meet all applicable requirements and may not violate any existing permit term or

condition.

b. The permittee must provide a written notice of the change to the Secretary and to U.S. EPA within two (2)

business days following the date of the change. Such written notice shall describe each such change,

including the date, any change in emissions, pollutants emitted, and any applicable requirement that would

apply as a result of the change.

c. The change shall not qualify for the permit shield.

d. The permittee shall keep records describing all changes made at the source that result in emissions of

regulated air pollutants, but not otherwise regulated under the permit, and the emissions resulting from

those changes.

e. No permittee may make any change subject to any requirement under Title IV of the Clean Air Act (Acid

Deposition Control) pursuant to the provisions of 45CSR§30-5.9.
Title V Operating Permit R30-03500002-2010 Page 17 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

f. No permittee may make any changes which would require preconstruction review under any provision of

Title I of the Clean Air Act (including 45CSR14 and 45CSR19) pursuant to the provisions of 45CSR§30-

5.9.

[45CSR§30-5.9]

2.11. Operational Flexibility

2.11.1. The permittee may make changes within the facility as provided by § 502(b)(10) of the Clean Air Act. Such

operational flexibility shall be provided in the permit in conformance with the permit application and applicable

requirements. No such changes shall be a modification under any rule or any provision of Title I of the Clean

Air Act (including 45CSR14 and 45CSR19) promulgated by the Secretary in accordance with Title I of the

Clean Air Act and the change shall not result in a level of emissions exceeding the emissions allowable under

the permit.

[45CSR§30-5.8]

2.11.2. Before making a change under 45CSR§30-5.8., the permittee shall provide advance written notice to the

Secretary and to U.S. EPA, describing the change to be made, the date on which the change will occur, any

changes in emissions, and any permit terms and conditions that are affected. The permittee shall thereafter

maintain a copy of the notice with the permit, and the Secretary shall place a copy with the permit in the public

file. The written notice shall be provided to the Secretary and U.S. EPA at least seven (7) days prior to the date

that the change is to be made, except that this period may be shortened or eliminated as necessary for a change

that must be implemented more quickly to address unanticipated conditions posing a significant health, safety,

or environmental hazard. If less than seven (7) days notice is provided because of a need to respond more

quickly to such unanticipated conditions, the permittee shall provide notice to the Secretary and U.S. EPA as

soon as possible after learning of the need to make the change.

[45CSR§30-5.8.a.]

2.11.3. The permit shield shall not apply to changes made under 45CSR§30-5.8., except those provided for in

45CSR§30-5.8.d. However, the protection of the permit shield will continue to apply to operations and

emissions that are not affected by the change, provided that the permittee complies with the terms and

conditions of the permit applicable to such operations and emissions. The permit shield may be reinstated for

emissions and operations affected by the change:

a. If subsequent changes cause the facility's operations and emissions to revert to those authorized in the

permit and the permittee resumes compliance with the terms and conditions of the permit, or

b. If the permittee obtains final approval of a significant modification to the permit to incorporate the change

in the permit.

[45CSR§30-5.8.c.]

2.11.4. "Section 502(b)(10) changes" are changes that contravene an express permit term. Such changes do not include

changes that would violate applicable requirements or contravene enforceable permit terms and conditions that

are monitoring (including test methods), recordkeeping, reporting, or compliance certification requirements.

[45CSR§30-2.39]

2.12. Reasonably Anticipated Operating Scenarios

2.12.1. The following are terms and conditions for reasonably anticipated operating scenarios identified in this permit.
Title V Operating Permit R30-03500002-2010 Page 18 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

a. Contemporaneously with making a change from one operating scenario to another, the permittee shall

record in a log at the permitted facility a record of the scenario under which it is operating and to document

the change in reports submitted pursuant to the terms of this permit and 45CSR30.

b. The permit shield shall extend to all terms and conditions under each such operating scenario; and

c. The terms and conditions of each such alternative scenario shall meet all applicable requirements and the

requirements of 45CSR30.

[45CSR§30-5.1.i.]

2.13. Duty to Comply

2.13.1. The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation

of the West Virginia Code and the Clean Air Act and is grounds for enforcement action by the Secretary or

USEPA; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal

application.

[45CSR§30-5.1.f.1.]

2.14. Inspection and Entry

2.14.1. The permittee shall allow any authorized representative of the Secretary, upon the presentation of credentials

and other documents as may be required by law, to perform the following:

a. At all reasonable times (including all times in which the facility is in operation) enter upon the permittee's

premises where a source is located or emissions related activity is conducted, or where records must be

kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this

permit;

c. Inspect at reasonable times (including all times in which the facility is in operation) any facilities,

equipment (including monitoring and air pollution control equipment), practices, or operations regulated

or required under the permit;

d. Sample or monitor at reasonable times substances or parameters to determine compliance with the permit

or applicable requirements or ascertain the amounts and types of air pollutants discharged.

[45CSR§30-5.3.b.]

2.15. Schedule of Compliance

2.15.1. For sources subject to a compliance schedule, certified progress reports shall be submitted consistent with the

applicable schedule of compliance set forth in this permit and 45CSR§30-4.3.h., but at least every six (6)

months, and no greater than once a month, and shall include the following:

a. Dates for achieving the activities, milestones, or compliance required in the schedule of compliance, and

dates when such activities, milestones or compliance were achieved; and
Title V Operating Permit R30-03500002-2010 Page 19 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

b. An explanation of why any dates in the schedule of compliance were not or will not be met, and any

preventative or corrective measure adopted.

[45CSR§30-5.3.d.]

2.16. Need to Halt or Reduce Activity not a Defense

2.16.1. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or

reduce the permitted activity in order to maintain compliance with the conditions of this permit. However,

nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as

a mitigating factor in determining penalties for noncompliance if the health, safety, or environmental impacts

of halting or reducing operations would be more serious than the impacts of continued operations.

[45CSR§30-5.1.f.2.]

2.17. Emergency

2.17.1. 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 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.

[45CSR§30-5.7.a.]

2.17.2. Effect of any emergency. An emergency constitutes an affirmative defense to an action brought for

noncompliance with such technology-based emission limitations if the conditions of 45CSR§30-5.7.c. are met.

[45CSR§30-5.7.b.]

2.17.3. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous

operating logs, or other relevant evidence that:

a. An emergency occurred and that the permittee can identify the cause(s) of the emergency;

b. The permitted facility was at the time being properly operated;

c. During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions

that exceeded the emission standards, or other requirements in the permit; and

d. Subject to the requirements of 45CSR§30-5.1.c.3.C.1, the permittee submitted notice of the emergency to

the Secretary within one (1) working day of the time when emission limitations were exceeded due to the

emergency and made a request for variance, and as applicable rules provide. This notice, report, and

variance request fulfills the requirement of 45CSR§30-5.1.c.3.B. This notice must contain a detailed

description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

[45CSR§30-5.7.c.]

2.17.4. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the

burden of proof.

[45CSR§30-5.7.d.]
Title V Operating Permit R30-03500002-2010 Page 20 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

2.17.5. This provision is in addition to any emergency or upset provision contained in any applicable requirement.

[45CSR§30-5.7.e.]

2.18. Federally-Enforceable Requirements

2.18.1. All terms and conditions in this permit, including any provisions designed to limit a source's potential to emit

and excepting those provisions that are specifically designated in the permit as "State-enforceable only", are

enforceable by the Secretary, USEPA, and citizens under the Clean Air Act.

[45CSR§30-5.2.a.]

2.18.2. Those provisions specifically designated in the permit as "State-enforceable only" shall become "Federallyenforceable" requirements upon SIP approval by the USEPA.

2.19. Duty to Provide Information

2.19.1. The permittee shall furnish to the Secretary within a reasonable time any information the Secretary 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 Secretary

copies of records required to be kept by the permittee. For information claimed to be confidential, the permittee

shall furnish such records to the Secretary along with a claim of confidentiality in accordance with 45CSR31.

If confidential information is to be sent to USEPA, the permittee shall directly provide such information to

USEPA along with a claim of confidentiality in accordance with 40 C.F.R. Part 2.

[45CSR§30-5.1.f.5.]

2.20. Duty to Supplement and Correct Information

2.20.1. Upon becoming aware of a failure to submit any relevant facts or a submittal of incorrect information in any

permit application, the permittee shall promptly submit to the Secretary such supplemental facts or corrected

information.

[45CSR§30-4.2.]

2.21. Permit Shield

2.21.1. Compliance with the conditions of this permit shall be deemed compliance with any applicable requirements

as of the date of permit issuance provided that such applicable requirements are included and are specifically

identified in this permit or the Secretary has determined that other requirements specifically identified are not

applicable to the source and this permit includes such a determination or a concise summary thereof.

[45CSR§30-5.6.a.]

2.21.2. Nothing in this permit shall alter or affect the following:

a. 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; or

b. The applicable requirements of the Code of West Virginia and Title IV of the Clean Air Act (Acid

Deposition Control), consistent with § 408 (a) of the Clean Air Act.
Title V Operating Permit R30-03500002-2010 Page 21 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

c. The authority of the Administrator of U.S. EPA to require information under § 114 of the Clean Air Act

or to issue emergency orders under § 303 of the Clean Air Act.

[45CSR§30-5.6.c.]

2.22. Credible Evidence

2.22.1. Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or a violation

of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing

in this permit shall be construed to waive any defenses otherwise available to the permittee including but not

limited to any challenge to the credible evidence rule in the context of any future proceeding.

[45CSR§30-5.3.e.3.B. and 45CSR38]

2.23. Severability

2.23.1. The provisions of this permit are severable. If any provision of this permit, or the application of any provision

of this permit to any circumstance is held invalid by a court of competent jurisdiction, the remaining permit

terms and conditions or their application to other circumstances shall remain in full force and effect.

[45CSR§30-5.1.e.]

2.24. Property Rights

2.24.1. This permit does not convey any property rights of any sort or any exclusive privilege.

[45CSR§30-5.1.f.4]

2.25. Acid Deposition Control

2.25.1. Emissions shall not exceed any allowances that the source lawfully holds under Title IV of the Clean Air Act

(Acid Deposition Control) or rules of the Secretary promulgated thereunder.

a. No permit revision shall be required for increases in emissions that are authorized by allowances acquired

pursuant to the acid deposition control program, provided that such increases do not require a permit

revision under any other applicable requirement.

b. No limit shall be placed on the number of allowances held by the source. The source may not, however,

use allowances as a defense to noncompliance with any other applicable requirement. 

c. Any such allowance shall be accounted for according to the procedures established in rules promulgated

under Title IV of the Clean Air Act.

[45CSR§30-5.1.d.]

2.25.2. Where applicable requirements of the Clean Air Act are more stringent than any applicable requirement of

regulations promulgated under Title IV of the Clean Air Act (Acid Deposition Control), both provisions shall

be incorporated into the permit and shall be enforceable by the Secretary and U. S. EPA.

[45CSR§30-5.1.a.2.]
Title V Operating Permit R30-03500002-2010 Page 22 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

3.0. Facility-Wide Requirements

3.1. Limitations and Standards

3.1.1. Open burning. The open burning of refuse by any person is prohibited except as noted in 45CSR§6-3.1.

[45CSR§6-3.1.]

3.1.2. Open burning exemptions. The exemptions listed in 45CSR§6-3.1 are subject to the following stipulation:

Upon notification by the Secretary, no person shall cause or allow any form of open burning during existing

or predicted periods of atmospheric stagnation. Notification shall be made by such means as the Secretary may

deem necessary and feasible.

[45CSR§6-3.2.]

3.1.3. Asbestos. The permittee is responsible for thoroughly inspecting the facility, or part of the facility, prior to

commencement of demolition or renovation for the presence of asbestos and complying with 40 C.F.R. §

61.145, 40 C.F.R. § 61.148, and 40 C.F.R. § 61.150. The permittee must notify the Secretary at least ten (10)

working days prior to the commencement of any asbestos removal on the forms prescribed by the Secretary if

the permittee is subject to the notification requirements of 40 C.F.R. § 61.145(b)(3)(i). The USEPA, the

Division of Waste Management and the Bureau for Public Health - Environmental Health require a copy of this

notice to be sent to them.

[40 C.F.R. 61 and 45CSR34]

3.1.4. Odor. No person shall cause, suffer, allow or permit the discharge of air pollutants which cause or contribute

to an objectionable odor at any location occupied by the public.

[45CSR§4-3.1 State-Enforceable only.]

3.1.5. Standby plan for reducing emissions. When requested by the Secretary, the permittee shall prepare standby

plans for reducing the emissions of air pollutants in accordance with the objectives set forth in Tables I, II, and

III of 45CSR11.

[45CSR§11-5.2]

3.1.6. Emission inventory. The permittee is responsible for submitting, on an annual basis, an emission inventory

in accordance with the submittal requirements of the Division of Air Quality.

[W.Va. Code § 22-5-4(a)(14)]

3.1.7. Ozone-depleting substances. For those facilities performing maintenance, service, repair or disposal of

appliances, the permittee shall comply with the standards for recycling and emissions reduction pursuant to 40

C.F.R. Part 82, Subpart F, except as provided for Motor Vehicle Air Conditioners (MVACs) in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the prohibitions

and required practices pursuant to 40 C.F.R. §§ 82.154 and 82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the

standards for recycling and recovery equipment pursuant to 40 C.F.R. § 82.158.

c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved

technician certification program pursuant to 40 C.F.R. § 82.161.

[40 C.F.R. 82, Subpart F]
Title V Operating Permit R30-03500002-2010 Page 23 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

3.1.8. Risk Management Plan. Should this stationary source, as defined in 40 C.F.R. § 68.3, become subject to Part

68, then the owner or operator shall submit a risk management plan (RMP) by the date specified in 40 C.F.R.

§ 68.10 and shall certify compliance with the requirements of Part 68 as part of the annual compliance

certification as required by 40 C.F.R. Part 70 or 71.

[40 C.F.R. 68]

3.1.9. The owner or operator of a plant shall maintain particulate matter control of the plant premises, and plant

owned, leased or controlled access roads, by paving, application of asphalt, chemical dust suppressants or other

suitable dust control measures. Good operating practices shall be implemented and when necessary particulate

matter suppressants shall be applied in relation to stockpiling and general material handling to minimize

particulate matter generation and atmospheric entrainment.

[45CSR§7-5.2.]

3.1.10 Due to unavoidable malfunction of equipment, emissions exceeding those provided for in 45CSR7 may be

permitted by the Director for periods not to exceed ten (10) days upon specific application to the Director. Such

application shall be made within twenty-four (24) hours of the malfunction. In cases of major equipment

failure, additional time periods may be granted by the Director provided a corrective program has been

submitted by the owner or operator and approved by the Director.

[45CSR§7-9.1.]

3.1.11 Any stack serving any process source operation or air pollution control equipment on any process source

operation shall contain flow straightening devices or a vertical run of sufficient length to establish flow patterns

consistent with acceptable stack sampling procedures.

[45CSR§7-4.12.]

3.2. Monitoring Requirements

3.2.1. Visible emission checks of each emission point subject to an opacity limit shall be conducted once per week

during periods of normal facility operation using 40 C.F.R. 60 Appendix A, Method 22. If during these checks,

or at any other time, visible emissions are observed at any emission point, compliance shall be determined by

conducting tests in accordance 45CSR7A within 48 hours. If the 45CSR7A test results show the opacity to be

equal to or greater than the limit, then an evaluation to determine the cause of the exceedance shall be conducted

within three (3) days, unless the cause of the exceedance is corrected within 24 hours. If no visible emissions

are observed after two weeks, visible emission checks shall be conducted monthly. If any visible emissions are

observed during the monthly emission checks, visible emission checks shall return to being performed weekly.

If no visible emissions are observed after four months, visible emission checks shall be conducted each calendar

quarter. If any visible emissions are observed during the quarterly emission checks, visible emission checks

shall return to being performed each calendar month. Records shall be maintained on site and shall include all

data required by 40 C.F.R. 60 Appendix A, Method 22 or 45CSR7A test, whichever is appropriate. These

records shall include, at a minimum, the date and time of each visible emission check, the visible emissions

survey results and, if appropriate, all corrective actions taken.

For sources that are controlled by fabric filtration, the Method 22 or 45CSR7A test readings shall be taken at

the exhaust point for the associated control device. For sources controlled by other means but without a defined

stack emission point, the Method 22 or 45CSR7A test readings shall be taken at the source. For sources located

within an enclosed building, the Method 22 or 45CSR7A test readings shall be taken at each visible side and

the roof of the building.

[45CSR§30-5.1.c.]
Title V Operating Permit R30-03500002-2010 Page 24 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

3.3. Testing Requirements

3.3.1. Stack testing. As per provisions set forth in this permit or as otherwise required by the Secretary, in

accordance with the West Virginia Code, underlying regulations, permits and orders, the permittee shall conduct

test(s) to determine compliance with the emission limitations set forth in this permit and/or established or set

forth in underlying documents. The Secretary, or his duly authorized representative, may at his option witness

or conduct such test(s). Should the Secretary exercise his option to conduct such test(s), the operator shall

provide all necessary sampling connections and sampling ports to be located in such manner as the Secretary

may require, power for test equipment and the required safety equipment, such as scaffolding, railings and

ladders, to comply with generally accepted good safety practices. Such tests shall be conducted in accordance

with the methods and procedures set forth in this permit or as otherwise approved or specified by the Secretary

in accordance with the following:

a. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing

to the test methods specified in the permit for demonstrating compliance with 40 C.F.R. Parts 60, 61, and

63, if applicable, in accordance with the Secretary’s delegated authority and any established equivalency

determination methods which are applicable.

b. The Secretary may on a source-specific basis approve or specify additional testing or alternative testing

to the test methods specified in the permit for demonstrating compliance with applicable requirements

which do not involve federal delegation. In specifying or approving such alternative testing to the test

methods, the Secretary, to the extent possible, shall utilize the same equivalency criteria as would be used

in approving such changes under Section 3.3.1.a. of this permit.

c. All periodic tests to determine mass emission limits from or air pollutant concentrations in discharge stacks

and such other tests as specified in this permit shall be conducted in accordance with an approved test

protocol. Unless previously approved, such protocols shall be submitted to the Secretary in writing at least

thirty (30) days prior to any testing and shall contain the information set forth by the Secretary. In addition,

the permittee shall notify the Secretary at least fifteen (15) days prior to any testing so the Secretary may

have the opportunity to observe such tests. This notification shall include the actual date and time during

which the test will be conducted and, if appropriate, verification that the tests will fully conform to a

referenced protocol previously approved by the Secretary.

[WV Code § 22-5-4(a)(15), 45CSR§§7-8.1 and 8.2., and 45CSR§13-6.1.]

3.4. Recordkeeping Requirements

3.4.1. Monitoring information. The permittee shall keep records of monitoring information that include the

following:

a. The date, place as defined in this permit and time of sampling or measurements;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The results of the analyses; and

f. The operating conditions existing at the time of sampling or measurement.

[45CSR§30-5.1.c.2.A. and 45CSR13 - R13-2431, Condition 4.3.1.]
Title V Operating Permit R30-03500002-2010 Page 25 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

3.4.2. Retention of records. 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 monitoring sample, measurement, report,

application, or record creation date. Support information includes all calibration and maintenance records and

all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required

by the permit. Where appropriate, records may be maintained in computerized form in lieu of the above

records.

[45CSR§30-5.1.c.2.B.]

3.4.3. Odors. For the purposes of 45CSR4, the permittee shall maintain a record of all odor complaints received,

any investigation performed in response to such a complaint, and any responsive action(s) taken.

[45CSR§30-5.1.c. State-Enforceable only.]

3.5. Reporting Requirements

3.5.1. Responsible official. Any application form, report, or compliance certification required by this permit to be

submitted to the DAQ and/or USEPA shall contain a certification by the responsible official that states that,

based on information and belief formed after reasonable inquiry, the statements and information in the

document are true, accurate and complete.

[45CSR§30-4.4. and 5.1.c.3.D.]

3.5.2. A permittee may request confidential treatment for the submission of reporting required under 45CSR§30-

5.1.c.3. pursuant to the limitations and procedures of W.Va. Code § 22-5-10 and 45CSR31.

[45CSR§30-5.1.c.3.E.]

3.5.3. Except for the electronic submittal of the annual certification to the USEPA as required in 3.5.5 below, all

notices, requests, demands, submissions and other communications required or permitted to be made to the

Secretary of DEP and/or USEPA shall be made in writing and shall be deemed to have been duly given when

delivered by hand, mailed first class, or by private carrier with postage prepaid to the address(es) set forth below

or to such other person or address as the Secretary of the Department of Environmental Protection may

designate:

If to the DAQ: If to the US EPA:

Director

WVDEP

Division of Air Quality

601 57th Street SE

Charleston, WV 25304

Phone: 304/926-0475

FAX: 304/926-0478

Associate Director

Office of Enforcement and Permits Review

(3AP12)

U. S. Environmental Protection Agency

Region III

1650 Arch Street

Philadelphia, PA 19103-2029

3.5.4. Certified emissions statement. The permittee shall submit a certified emissions statement and pay fees on an

annual basis in accordance with the submittal requirements of the Division of Air Quality. 

[45CSR§30-8.]

3.5.5. Compliance certification. The permittee shall certify compliance with the conditions of this permit on the

forms provided by the DAQ. In addition to the annual compliance certification, the permittee may be required
Title V Operating Permit R30-03500002-2010 Page 26 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

to submit certifications more frequently under an applicable requirement of this permit. The annual certification

shall be submitted to the DAQ and USEPA on or before March 15 of each year, and shall certify compliance

for the period ending December 31. The annual certification to the USEPA shall be submitted in electronic

format only. It shall be submitted by e-mail to the following address: R3_APD_Permits@epa.gov. The

permittee shall maintain a copy of the certification on site for five (5) years from submittal of the certification.

[45CSR§30-5.3.e.]

3.5.6. Semi-annual monitoring reports. The permittee shall submit reports of any required monitoring on or before

September 15 for the reporting period January 1 to June 30 and on or before March 15 for the reporting period

July 1 to December 31. All instances of deviation from permit requirements must be clearly identified in such

reports. All required reports must be certified by a responsible official consistent with 45CSR§30-4.4.

[45CSR§30-5.1.c.3.A.]

3.5.7. Emergencies. For reporting emergency situations, refer to Section 2.17 of this permit.

3.5.8. Deviations.

a. In addition to monitoring reports required by this permit, the permittee shall promptly submit supplemental

reports and notices in accordance with the following:

1. Any deviation resulting from an emergency or upset condition, as defined in 45CSR§30-5.7., shall be

reported by telephone or telefax within one (1) working day of the date on which the permittee

becomes aware of the deviation, if the permittee desires to assert the affirmative defense in accordance

with 45CSR§30-5.7. A written report of such deviation, which shall include the probable cause of

such deviations, and any corrective actions or preventative measures taken, shall be submitted and

certified by a responsible official within ten (10) days of the deviation.

2. Any deviation that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to the Secretary immediately by telephone or telefax. A written report

of such deviation, which shall include the probable cause of such deviation, and any corrective actions

or preventative measures taken, shall be submitted by the responsible official within ten (10) days of

the deviation.

3. Deviations for which more frequent reporting is required under this permit shall be reported on the

more frequent basis.

4. All reports of deviations shall identify the probable cause of the deviation and any corrective actions

or preventative measures taken.

[45CSR§30-5.1.c.3.C.]

b. The permittee shall, in the reporting of deviations from permit requirements, including those attributable

to upset conditions as defined in this permit, report the probable cause of such deviations and any

corrective actions or preventive measures taken in accordance with any rules of the Secretary.

[45CSR§30-5.1.c.3.B.]

3.5.9. New applicable requirements. If any applicable requirement is promulgated during the term of this permit,

the permittee will meet such requirements on a timely basis, or in accordance with a more detailed schedule if

required by the applicable requirement.

[45CSR§30-4.3.h.1.B.]
Title V Operating Permit R30-03500002-2010 Page 27 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

3.6. Compliance Plan

3.6.1. None.

3.7. Permit Shield

3.7.1. The permittee is hereby granted a permit shield in accordance with 45CSR§30-5.6. The permit shield applies

provided the permittee operates in accordance with the information contained within this permit.

3.7.2. The following requirements specifically identified are not applicable to the source based on the determinations

set forth below. The permit shield shall apply to the following requirements provided the conditions of the

determinations are met.

a. 45CSR5 - The facility is exempt from this rule in accordance with Section 2.4.a., a facility that is designed

to process less than two hundred (200) tons of coal per day; and Section 2.4.b., a facility subject to the

requirements of 45CSR2, 45CSR3, 45CSR7.

b. 40 C.F.R. Part 60 subparts K, Ka, Kb - The facility does not have any tanks that store volatile organic

liquids with a capacity greater than 65,000 gallons (Subpart K), 40,000 gallons (Subpart Ka), or 19,813

gallons (Subpart Kb).

c. 40 C.F.R. Part 60 Subpart Y - The provisions of this subpart are not applicable because the facility does

not process more than 181 Mg (200 tons) of coal per day.

d. 40 C.F.R. Part 64 - Compliance Assurance Monitoring - In accordance with 40 C.F.R.§ 64.2(a)(3), the

following emission units have potential pre-control device emissions of the applicable regulated air

pollutant required to be classified as a major source:

Emission Unit ID Description Pollutant Reason for exemption

002P301B Bucket Elevator S-1. Screws K12, K-13, K-14 PM No control device [40 C.F.R.

§64.2(a)(2)]

003P019 Building No. 52 Ring Furnace SO2 No SO2

 control device

[40 C.F.R. §64.2(a)(2)] 003P110 Building No. 53 Ring Furnace SO2

004P101-004P104 Reduction Cells Potroom 1A, 1B,

2A, and 2B CO No CO control device

[40 C.F.R. §64.2(a)(2)]

004P201-004P204 Reduction Cells Potroom 3A, 3B,

4A, and 4B CO

004P101-004P104 Reduction Cells Potroom 1A, 1B,

2A, and 2B

Total

Fluorides Subject to 40 C.F.R. Part 63, Subpart

LL. Exempt in accordance with 40

C.F.R. § 64.2(b)(1)(i). 004P201-004P204 Reduction Cells Potroom 3A, 3B,

4A, and 4B

Total

Fluorides
Title V Operating Permit R30-03500002-2010 Page 28 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

4.0. Manufacturing Process Group Requirements: Group A [Barge Unloading], Group B [Material Transfer

to/from Potroom Silos], Group C [Bath Processing], Group D [Anode Mix, Press & Prep], Group E

[Cathode Paste], Group F [Coal & Coke Unloading], and Group G [Anode Blocks]

4.1. Limitations and Standards

4.1.1. No person shall cause, suffer, allow, or permit PM to be vented into the open air from any type source operation

or duplicate source operation, or from all air pollution control equipment installed on any type source operation

or duplicate source operation in excess of the quantities specified in this permit.

Emission Unit ID Equipment Description Max. Allowable PM

Emission Limit (lb/hr)

Group A - Barge Unloading

001P101, 001P101A Vacuum Truck Unloading/AIF3

 - Cryolite Railcar Unloading

and Conveyor 46.0

001P111 Conveyor 2 43.6

Group B - Material Transfer to/from Potroom Silos

001P201 Air Slides 372, 470, 473, 404, 472, 405, & 474; Air Lifts 374

& 471; Disengaging Bins 374 & 471 28.0

001P202 Air Slides 302, 400, & 403; Air Lifts 304 & 401; Disengaging

Bins 304 & 401 28.0

001P203 Air Slides 021& 025, Air Lifts 022 & 250; & Disengaging Bins

022 & 250 32.2

001P204 Parallel Vibrating Screens 004 & 014 and Tote, Air Slide 102 32.2

001P206 Air Slide 172, Air Lift 174, Disengaging Bin 174 32.2

004P217 Fill Station 16.0

004P218 Bath Cart 16.0

004P219 Apollo Fill Station 28.0

004P301 Air Slides 270, 271, 277 28.0

004P302 Air Slides 200, 207 28.0

004P303 Air Slides 370, 371 28.0

004P304 Air Slides 300, 301 28.0

004P305 Air Slides 264, 303 28.0

Group C - Bath Processing

001P305 Cascade Mill 156-200 19.96

001P306 Magnetic Separator 156-214 19.96

001P307 and 001P308 Skip Buckets 16.0 each
Title V Operating Permit R30-03500002-2010 Page 29 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission Unit ID Equipment Description Max. Allowable PM

Emission Limit (lb/hr)

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

001P309 Vibrating Screen 156.-203 19.96

001P311 Bagging Machine 156-501 19.96

001P315 Skip Hoist 16.0

001P312 Cyclone 156-206, Air Lifts 156-304 & 156-309, Disengaging

Bins 156-305 & 156-310

19.96

Group E - Cathode Paste

002P201 Vibrating Screening/Sizing 28.0

002P202 Conveyor K-10 28.0

002P203 Roll Crusher M-7 28.0

002P205 Fine Grind Mill D-2 28.0

002P206 Conveyor K-11 28.0

002P207 Air Classifier G-2 28.0

002P208 Cyclone P-2 28.0

002P214 Weigh Larry 28.0

002P215 Batch Mixer AF-17 28.0

002P216 Batch Mixer AF-18 28.0

002P218 Press Reject Conveyor 28.0

002P220 Roll Crusher M-5C 28.0

002P221 Roll Crusher M-5B 28.0

Group F - Coal & Coke Unloading

002P301 Coal, Coke and Pitch Unloading

Feeder AA-1, Feeder V-1, Belt I-1

Bucket Elevator S-1, Screws K-12, K-13, K-14

34.6

002P304 Roll Crusher M-3 32.2

002P305 K-3A, K-3B, S-3, Y-1, AM-1&2 Vibrating Screen 35.4

002P306 Screw K-27, Bins 18 & 19, Disc W-1, Fine Grind Mill D-1 33.0

002P307 Air Classifier G-2 31.0

002P308 Cyclone P3 31.0

002P309 Cyclone P1 31.0

002P310 Feeder AA-20, Roll Crusher M-6 31.4

002P311 Bucket Elevator S-6, Vibrating Screen AM-4 31.4
Title V Operating Permit R30-03500002-2010 Page 30 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission Unit ID Equipment Description Max. Allowable PM

Emission Limit (lb/hr)

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Group G - Anode Blocks

003P102 Belt Conveyor BC-5 32.74

003P106 Portable ECL Bins 31.4

003P111 Anode Cleaner 1.2

003P113 Screening Station 31.4

003P114 Vibramill 31.4

003P115 Bucket Elevator 2.4

003P116 Bucket Elevator 2.4

003P203 Reacted Booth System 13.6

[45CSR§7-4.1.]

4.1.2. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any process source operation which is greater than twenty (20) percent opacity, except as noted in subsections

3.2, 3.3, 3.4, 3.5, 3.6, and 3.7. of 45CSR7.

[45CSR§7-3.1.]

4.1.3. No person shall cause, suffer, allow or permit any manufacturing process or storage structure generating fugitive

particulate matter to operate that is not equipped with a system, which may include, but not be limited to,

process equipment design, control equipment design or operation and maintenance procedures, to minimize the

emissions of fugitive particulate matter. To minimize means such system shall be installed, maintained and

operated to ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1.]

4.1.4. The barge unloader shall not operate more than 50 hours per week and the feeder from the large silo shall not

be operated more than two shifts per day. The emissions of particulate matter shall not exceed the amounts

listed in the following table:

Emission

Point ID

Emission Unit ID Gas Volume

(ACFM)

Max Potential PM

Emissions (lbs/hr)

Max PM Emissions

w/Controls (lbs/hr)

001S110

001P102

500 20 0.02

001S111 500 20 0.02

001S101 T.P. to 001P105 5000 214 0.21

001S102 T.P. from 001P106 to

001P107 & 001P108

11200 480 0.48

001S103 11200 480 0.48

001S106

001P110

1500 64 0.06

001S108 1500 64 0.06

Compliance with these limits shall demonstrate compliance with the less stringent limit of 45CSR§7-4.1.

[45CSR13 - R13-0348 and 45CSR§7-4.1.]
Title V Operating Permit R30-03500002-2010 Page 31 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

4.2. Monitoring Requirements

4.2.1. The permittee shall monitor the PM emissions by conducting visible emissions checks and keeping records of

the results of the monitoring checks in accordance with Section 3.2.1.

[45CSR§30-5.1.c.]

4.3. Testing Requirements

4.3.1. None.

4.4. Recordkeeping Requirements

4.4.1. The permittee shall monitor all fugitive PM emission sources as required by Subsection 4.1.3. to ensure that

a system to minimize fugitive emissions has been installed or implemented. Records shall be maintained on

site stating the types of fugitive PM capture and/or suppression systems used, the times these systems were

inoperable, and the corrective actions taken to repair these systems.

[45CSR§30-5.1.c.]

4.5. Reporting Requirements

4.5.1. None.

4.6. Compliance Plan

4.6.1. None.
Title V Operating Permit R30-03500002-2010 Page 32 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

5.0. Manufacturing Process Group H Requirements [Rodding Department]

5.1. Limitations and Standards

5.1.1. No person shall cause, suffer, allow, or permit PM to be vented into the open air from any type source operation

or duplicate source operation, or from all air pollution control equipment installed on any type source operation

or duplicate source operation in excess of the quantities specified in this permit.

Emission Unit ID Equipment Max. Allowable PM

Emission Limit (lb/hr)

Group H - Rodding Department

003P301 Horizontal Press 31.4

003P302 Cone Crusher 31.4

003P303 Secondary Crusher 31.4

003P304 Belt Conveyor No. 4 31.4

003P305 Belt Conveyor No. 24 31.4

003P306 Butt Removal 31.4

003P307 Butt Crusher 31.4

003P308 Magnetic Separator 31.4

003P309 Thimble Press 6.0

003P310 Thimble Cleaner 6.0

003P311 Electric Arc Furnaces (3) 31.4

003P312 Rod Cleaning 0.07

003P313 Stub Dryer 0.07

003P314 Hole Cleaner 0.27

003P315 Hole Dryer 0.27

003P316 Assembly and Pouring Station 75.0

003P317 Chamfer 0.001

003P318 Stub Saw 0.0001

003P319 Welding Station 0.0001

003P320 Thimble Press, Combination Press 31.4

003P321 Belt Conveyor No. 22 31.4

003P322 Belt Conveyor No. 23 31.4

003P324 Anode Fine Cleaning (Shot Blast) Machine 31.4

003P323 Anode Rough Cleaning Machine 31.4
Title V Operating Permit R30-03500002-2010 Page 33 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission Unit ID Equipment Max. Allowable PM

Emission Limit (lb/hr)

Group H - Rodding Department

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

003P325 Bath Belt Conveyor 31.4

003P326 Surge Hopper 31.4

003P327 Crushed Feed Conveyor 31.4

003P328 Bath Crusher 31.4

003P329 Bath Screen Feed Conveyor 31.4

003P330 Bath Screen 31.4

003P331 Surge Hopper 31.4

[45CSR§7-4.1.]

5.1.2. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any process source operation which is greater than twenty (20) percent opacity, except as noted in subsections

3.2, 3.3, 3.4, 3.5, 3.6, and 3.7. of 45CSR7.

[45CSR§7-3.1. and 45CSR13 - R13-0201]

5.1.3. No person shall cause, suffer, allow or permit any manufacturing process or storage structure generating fugitive

particulate matter to operate that is not equipped with a system, which may include, but not be limited to,

process equipment design, control equipment design or operation and maintenance procedures, to minimize the

emissions of fugitive particulate matter. To minimize means such system shall be installed, maintained and

operated to ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1.]

5.1.4. No person shall cause, suffer, allow or permit the emission into the open air from any source operation an instack sulfur dioxide concentration exceeding 2,000 parts per million by volume from existing source operations,

except as provided in 45CSR§§10-4.1.a through 4.1.e.

[45CSR§10-4.1. (003P311)]

5.1.5. The operating rate for the rough cleaning and fine cleaning machines shall be limited to 30 tons per hour.

[45CSR13 - R13-0201, Specific Requirements A.1. (003P323 & 003P324)]

5.1.6. The operating rate for the three conveyor belts, the pneumatic conveying system, the crusher, and the screen

associated with the modification to the Bath Processing Facility shall be limited to 30 tons per hour.

[45CSR13 - R13-0201, Specific Requirements A.2. (003P325, 003P327, 003P328, 003P329, & 003P330)]

5.1.7. A dust collector shall be installed, and shall be properly maintained according to the manufacturer's

specifications such as to maximize its removal efficiency, and shall be in operation whenever any part of the

bath processing circuit is operating.

[45CSR13 - R13-0201, Specific Requirements A.3. (Baghouse No. 5)]
Title V Operating Permit R30-03500002-2010 Page 34 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

5.2. Monitoring Requirements

5.2.1. The permittee shall monitor the PM emissions by conducting visible emissions checks and keeping records of

the results of the monitoring checks in accordance with Section 3.2.1.

[45CSR§30-5.1.c.]

5.2.2. The permittee shall demonstrate compliance with Section 5.1.4. by testing and /or monitoring as set forth in an

approved monitoring plan (see Appendix A) for each emission unit.

[45CSR§10-8.2.c. (003P311)]

5.3. Testing Requirements

5.3.1. None.

5.4. Recordkeeping Requirements

5.4.1. The permittee shall maintain on-site a record of all required monitoring data as established in a monitoring plan

(see Appendix A) pursuant to 45CSR§10-8.2.c. Such records shall be made available to the Director or his duly

authorized representative upon request. Such records shall be retained on-site for a minimum of five years.

[45CSR§10-8.3.a. (003P311)]

5.4.2. The permittee shall keep a record of all maintenance performed on the dust collector. These records shall be

properly maintained on site for a period not less than five (5) years and be made available to the Director, or

his or her designated representative, upon request.

[45CSR13 - R13-0201, Other Requirements B.2. (003C305)]

5.4.3. The permittee shall monitor all fugitive PM emission sources as required by Section 5.1.3. to ensure that a

system to minimize fugitive emissions has been installed or implemented. Records shall be maintained on site

stating the types of fugitive PM capture and/or suppression systems used, the times these systems were

inoperable, and the corrective actions taken to repair these systems.

[45CSR§30-5.1.c.]

5.5. Reporting Requirements

5.5.1. The permittee shall submit a periodic exception report to the Director, in a manner specified by the Director.

Such an exception report shall provide details of all excursions outside the range of measured emissions or

monitored parameters established in an approved monitoring plan (see Appendix A) and shall include, but not

be limited to, the time of the excursion, the magnitude of the excursion, the duration of the excursion, the cause

of the excursion and the corrective action taken.

[45CSR§10-8.3.b. (003P311)]

5.6. Compliance Plan

5.6.1. None.
Title V Operating Permit R30-03500002-2010 Page 35 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

6.0. Storage Structure Requirements: Group A [Barge Unloading], Group B [Material Transfer to/from Potroom

Silos], Group C [Bath Processing], Group E [Cathode Paste], Group F [Coal & Coke Unloading], Group G

[Anode Blocks], and Group H [Rodding Department]

6.1. Limitations and Standards

6.1.1. No person shall cause, suffer, allow, or permit emissions of smoke and/or particulate matter into the open air

from any storage structure associated with any manufacturing process.

Emission Unit ID Equipment Description

Group A - Barge Unloading

001P107 Alumina Silo No. 1 West 741

001P108 Alumina Silo No. 2 East 742

001P112 Four Tote Bins

001P113 Carbon Ore Bin 11-9206

001P114 Fresh Alumina Bin 11-9201

Group B - Material Transfer to/from Potroom Silos

001P205 Alumina Bin 125

001P207 Alumina Bin 195

004P105 through 004P112 Potroom Silos 1A, 1C, 1D, 1B, 2A, 2C, 2D, 2B

004P205 through 004P212 Potroom Silos 3A, 3C, 3D, 3B, 4A, 4C, 4D, 4B

Group C - Bath Processing

001P301 through 001P304 Pure Bath Bins, Contaminated Bath Bin, Feed Storage Bin 156-103

001P310 Fines Storage Bin

001P313 and 001P314 Bath Storage 156-317 and Bath Storage 156-315

Group E - Cathode Paste

002P204 Mill Feed Bin

002P209 through 002P212 Coal Fines Storage Bins, Coal Intermediate Storage Bin, Coal Storage Bin

002P219 Green Scrap Storage Pile

Group F - Coal & Coke Unloading

002P302 Coal and Coke Storage Silos 1-4 and 8-11

002P312 through 002P315 Coke Fines Bins 53-68, Coke Coarse Bins 20-31, Anode Butts Bins 36-41, Bin 17

Group G - Anode Blocks

003P101 51 Bin

003P104 15 Ton Make-Up Bin
Title V Operating Permit R30-03500002-2010 Page 36 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

003P117 Anode Bin

003P201 No. 2 Bin Fresh Alumina,

003P202 Disengaging Bin 300

Group H - Rodding Department

003P332 Bath Silo

[45CSR§7-3.7.]

6.1.2. No person shall cause, suffer, allow or permit any manufacturing process or storage structure generating fugitive

particulate matter to operate that is not equipped with a system, which may include, but not be limited to,

process equipment design, control equipment design or operation and maintenance procedures, to minimize the

emissions of fugitive particulate matter. To minimize means such system shall be installed, maintained and

operated to ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1.]

6.2. Monitoring and Recordkeeping Requirements

6.2.1. The permittee shall monitor the smoke and PM emissions by conducting visible emissions checks and keeping

records of the results of the monitoring checks in accordance with Section 3.2.1.

[45CSR§30-5.1.c.]

6.3. Testing Requirements

6.3.1. None.

6.4. Recordkeeping Requirements

6.4.1. The permittee shall monitor all fugitive PM emission sources as required by Subsection 6.1.2. to ensure that

a system to minimize fugitive emissions has been installed or implemented. Records shall be maintained on

site stating the types of fugitive PM capture and/or suppression systems used, the times these systems were

inoperable, and the corrective actions taken to repair these systems.

[45CSR§30-5.1.c.]

6.5. Reporting Requirements

6.5.1. None.

6.6. Compliance Plan

6.6.1. None.
Title V Operating Permit R30-03500002-2010 Page 37 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

7.0. Manufacturing Process Group I Requirements [TAC Units and Miscellaneous Units]

7.1. Limitations and Standards

7.1.1. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any process source operation which is greater than twenty (20) percent opacity, except as noted in subsections

3.2, 3.3, 3.4, 3.5, 3.6, and 3.7 of 45CSR7.

[45CSR§7-3.1.]

7.1.2. The provisions of Section 7.1.1. of this permit shall not apply to smoke and/or particulate matter emitted from

any process source operation which is less than forty (40) percent opacity for any period or periods aggregating

no more than five (5) minutes in any sixty (60) minute period.

[45CSR§7-3.2.]

7.1.3. No person shall cause, suffer, allow, or permit particulate matter to be vented into the open air from any type

source operation or duplicate source operation, or from all air pollution control equipment installed on any type

source operation or duplicate source operation in excess of the quantity specified in this permit:

Emission

Unit ID

Equipment Description Max. Allowable PM Emission Limit

(lb/hr)

005P104A Paste Mixer 2.4

005P106 Paint Booth 0.012

005P108 Shell Rebuild 5.0

005P109 Reduction Cell Super Structure Cleaning Booth 7.5

005P110 Spent Pot Lining Disposal 1.92

[45CSR§7-4.1.]

7.1.4. No person shall circumvent the provisions of this rule by adding additional gas to any exhaust or group of

exhausts for the purpose of reducing the stack gas concentration.

[45CSR§7-4.3.]

7.1.5. No person shall cause, suffer, allow, or permit any manufacturing process generating fugitive particulate matter

to operate that is not equipped with a system to minimize the emissions of fugitive particulate matter. To

minimize means that a particulate capture or suppression system shall be installed to ensure the lowest fugitive

particulate emissions reasonably achievable.

[45CSR§7-5.1.]

7.1.6. Emissions from the TAC Systems Unit #1 and Unit #2, from emission point 005S115, shall not exceed the

following types and amounts of pollutants:

Pollutant Hourly Emission Rate (lb/hr) Annual Emission Rate (lb/yr)

PM 0.231 2024

PM10 0.231 2024

Hydrogen Fluoride 0.206 1805
Title V Operating Permit R30-03500002-2010 Page 38 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Pollutant Hourly Emission Rate (lb/hr) Annual Emission Rate (lb/yr)

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Particulate Fluoride 0.046 403

[45CSR13 - R13-2431 - Condition 4.1.1.]

7.1.7. The maximum rate of molten aluminum being treated by both TAC units combined shall be 46,000 pounds per

hour and 403,000,000 pounds per year. Compliance with the hourly process limit shall be determined by

dividing the daily amount of molten aluminum processed by the number of hours of operation for that given

day. Compliance with the yearly process limit shall be determined using a rolling yearly total. A rolling yearly

total shall mean the total amount of aluminum processed in pounds at any given time for the previous twelve

consecutive months.

[45CSR13 - R13-2431 - Condition 4.1.2. (005P114 & 005P115)]

7.1.8. The emissions generated from TAC Systems Unit #1 and Unit #2, which includes the stationary aluminum

fluoride storage bin for each unit, shall be vented to the Wheelabrator Canada Air Pollution Control, Model

WCC-36, size 45 bag house (Control Device ID No. R-442), which shall be installed, maintained, and operated

to maintain compliance with the emissions limits set forth in Section 7.1.6. of this permit.

[45CSR13 - R13-2431 - Conditions 4.1.3. and 4.1.4. (Baghouse R-442)]

7.1.9. Emissions from the crucible cleaner (unit 005P116) and the siphon cleaner (unit 005P117) shall not exceed the

following:

PM PM10

1

lb/hr tpy lb/hr tpy

Crucible Cleaner 0.5 2.19 0.5 2.19

Siphon Cleaner 0.04 0.17 0.04 0.17

Total 0.54 2.36 0.54 2.36

[45CSR13 - R13-2431 - Condition 4.1.5.]

7.1.10. Emissions from the crucible cleaner (unit 005P116) and the siphon cleaner (unit 005P117) shall be controlled

by baghouse 005C112. Said baghouse shall be installed, operated and maintained so as to achieve a minimum

control efficiency of 99.9%.

[45CSR13 - R13-2431 - Condition 4.1.6.]

7.1.11. Pressure drop across baghouse 005C112 shall be maintained at a range between 2 inches of water and 6 inches

of water.

[45CSR13 - R13-2431 - Condition 4.1.7.]

7.1.12. Operation and Maintenance of Air Pollution Control Equipment. The permittee shall, to the extent

practicable, install, maintain, and operate pollution control equipment, baghouse 005C112, and associated

monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing

emissions, or comply with any more stringent limits set forth in this permit or as set forth by any State rule,

Federal regulation, or alternative control plan approved by the Secretary.

[45CSR§13-5.11. and 45CSR13 - R13-2431, Condition 4.1.8.]
Title V Operating Permit R30-03500002-2010 Page 39 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

7.2. Monitoring Requirements

7.2.1. The permittee shall monitor the smoke and PM emissions by conducting visible emissions checks and keeping

records of the results of the monitoring checks in accordance with Section 3.2.1. of this permit

[45CSR§30-5.1.c.]

7.3. Testing Requirements

7.3.1. None.

7.4. Recordkeeping Requirements

7.4.1. For the purpose of determining compliance with the PM limit for the paint booth, the permittee shall maintain

records on the amount of paint consumed on a monthly basis.

[45CSR§30-5.1.c.]

7.4.2. For the purposes of determining compliance with the maximum processing rate limit as set forth in Section

7.1.7. of this permit, the applicant shall maintain certified daily and monthly records of the amount of molten

aluminum treated by TAC system. Such records shall be retained by the permittee for at least five (5) years.

Certified records shall be made available to the Director or his/her duly authorized representative upon request.

[45CSR13 - R13-2431, Condition 4.3.4.]

7.4.3. For the purposes of determining compliance with the requirement set forth in condition 7.1.8. of this permit,

the permittee shall maintain certified daily records of the pressure drop across baghouse R-442. Said records

shall be retained by the permittee on site for at least five years. Certified records shall be made available to the

Director or his/her duly authorized representative upon request.

[45CSR13 - R13-2431, Condition 4.3.5.]

7.4.4. In order to determine compliance with condition 7.1.11. of this permit, the permittee shall maintain certified

daily records of the pressure drop across baghouse 005C112. Said records shall be retained by the permittee

on site for at least five years. Certified records shall be made available to the Director or his/her duly

authorized representative upon request.

[45CSR13 - R13-2431, Condition 4.3.6.]

7.4.5. Record of Maintenance of Air Pollution Control Equipment. For pollution control equipment, baghouse

005C112, the permittee shall maintain accurate records of all required pollution control equipment inspection

and/or preventative maintenance procedures.

[45CSR13 - R13-2431, Condition 4.3.2.]

7.4.6. Record of Malfunctions of Air Pollution Control Equipment. For pollution control equipment, baghouse

005C112, the permittee shall maintain records of the occurrence and duration of any malfunction or operational

shutdown of the air pollution control equipment during which excess emissions occur. For each such case, the

following information shall be recorded:

a. The equipment involved.

b. Steps taken to minimize emissions during the event.

c. The duration of the event.
Title V Operating Permit R30-03500002-2010 Page 40 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

d. The estimated increase in emissions during the event.

For each such case associated with an equipment malfunction, the additional information shall also be recorded:

e. The cause of the malfunction.

f. Steps taken to correct the malfunction.

g. Any changes or modifications to equipment or procedures that would help prevent future recurrences of

the malfunction.

[45CSR13 - R13-2431, Condition 4.3.3.]

7.5. Reporting Requirements

7.5.1. None.

7.6. Compliance Plan

7.6.1. None.
Title V Operating Permit R30-03500002-2010 Page 41 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

8.0. Fuel Burning Unit Requirements [002P139, 002P140, 005P102, 005P103, 005P104)]

8.1. Limitations and Standards

8.1.1. No person shall cause, suffer, allow or permit emission of smoke and/or particulate matter into the open air from

any fuel burning unit which is darker in shade or appearance than ten (10) percent opacity based on a six minute

block average. Compliance with this limit shall demonstrate compliance with the less stringent limit of 40

C.F.R. § 60.43c(c) and 45CSR16.

[45CSR§2-3.1., 45CSR13 - R13-2140, Condition B.1.]

8.1.2 No person shall cause, suffer, allow or permit the discharge of particulate matter into the open air from all fuel

burning units located at one plant, measured in terms of pounds per hour in excess of the product of 0.09 and

the total design heat input in million B.T.U.’s per hour. For Boiler No. 2 (005P102): 3.92 lbs/hr.

[45CSR§2-4.1.b. (002P139 & 002P140 Exempt)]

8.1.3. The addition of sulfur oxides to a combustion unit exit gas stream for the purpose of improving emissions

control equipment efficiency shall be reviewed by the Director. No person shall cause, suffer, allow or permit

the addition of sulfur oxides as described above unless written approval for such addition is provided by the

Director.

[45CSR§2-4.4. (002P139 & 002P140 Exempt)]

8.1.4. The visible emission standards set forth in Section 8.1.1. shall apply at all times except in periods of start-ups,

shutdowns and malfunctions. Where the Director believes that start-ups and shutdowns are excessive in

duration and/or frequency, the Director may require an owner or operator to provide a written report

demonstrating that such frequent start-ups and shutdowns are necessary.

[45CSR§2-9.1. (002P139 & 002P140 Exempt)]

8.1.5. At all times, including periods of start-ups, shutdowns and malfunctions, owners and operators shall, to the

extent practicable, maintain and operate any fuel burning unit(s) including associated air pollution control

equipment in a manner consistent with good air pollution control practice for minimizing emissions.

Determination of whether acceptable operating and maintenance procedures are being used will be based on

information available to the Director which may include, but is not limited to, monitoring results, visible

emission observations, review of operating and maintenance procedures and inspection of the source.

[45CSR§2-9.2. and 45CSR13 - R13-2140, Condition B.1. (002P139 & 002P140 Exempt)]

8.1.6. No person shall cause, suffer, allow or permit the discharge of sulfur dioxide into the open air from all stacks

located at one plant, measured in terms of pounds per hour, in excess of the amount determined as follows: the

product of 3.1 and the total design heat inputs for such units discharging through those stacks in million BTU's

per hour. For Boiler No. 2 (005P102): 134.85 lbs/hr.

[45CSR§10-3.1.e. and 45CSR13 - R13-2140, Condition B.2. (002P139 & 002P140 Exempt)]

8.1.7. No person shall circumvent the provisions of this rule by constructing fuel burning unit(s) larger than would

be necessary to provide heat and/or power for an existing manufacturing plant, with a reasonable margin for

plant expansion, in order to use that design heat input to raise the allowable sulfur content in fuel.

[45CSR§10-3.6. and 45CSR13 - R13-2140, Condition B.2.]

8.1.8. No person shall construct, modify or relocate any source of sulfur dioxide without first obtaining a permit in

accordance with the provisions of W. Va. Code §22-5-1 et seq., and Series 13, 14, 19 and 30 of Title 45.

[45CSR§10-7.1. and 45CSR13 - R13-2140, Condition B.2.]
Title V Operating Permit R30-03500002-2010 Page 42 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

8.1.9. Due to unavoidable malfunction of equipment or inadvertent fuel shortages, emissions exceeding those provided

for in this rule may be permitted by the Director for periods not to exceed ten (10) days upon specific

application to the Director. Such application shall be made within twenty-four (24) hours of the equipment

malfunction or fuel shortage. In cases of major equipment failure or extended shortages of conforming fuels,

additional time periods may be granted by the Director provided a corrective program has been submitted by

the owner or operator and approved by the Director.

[45CSR§10-9.1. and 45CSR13 - R13-2140, Condition B.2.]

8.1.10. The maximum heat input and maximum fuel consumption rates for Boilers No. 4 and No. 5 shall not exceed:

Equip. ID Source

Maximum Heat

Input (106 Btu/hr)

Natural Gas Usage

 (ft3/hr) (ft3/yr)

#2 Oil Usage

Sulfur Content (gal/hr) (gal/yr)

005P103 Boiler No. 4 76.0 66,785 480,000,000 0.05% 550 3,800,000

005P104 Boiler No. 5 37.5 32,917 288,356,415 0.05% 258 2,260,080

[45CSR13 - R13-2140, Condition A.1.]

8.1.11. Only natural gas or No. 2 fuel oil shall be burned in Boilers No. 4 (005P103) and No. 5 (005P104).

[45CSR13 - R13-2140, Condition A.2.]

8.1.12. The maximum sulfur content for the No. 2 fuel oil to be burned in Boilers No. 4 (005P103) and No. 5

(005P104) shall not exceed 0.05% by weight. Compliance with this limit shall demonstrate compliance with

the less stringent limit of 45CSR§10-10.2, 40 C.F.R. § 60.42c(d) and 45CSR§16.

[45CSR13 - R13-2140, Condition A.3.]

8.1.13. Emissions from Boiler No. 4 (005P103) shall not exceed the limits set forth in the table below:

Pollutant Pounds per Hour (lb/hr) 

(combusting natural gas)

Pounds per Hour (lb/hr) 

(combusting fuel oil)

Tons per Year (TPY)

(any combination of fuel)

Carbon Monoxide 6.26 2.75 22.49

Nitrogen Oxides 3.73 11.00 38.00

Particulate Matter 0.57 0.72 2.47

Sulfur Dioxide 0.04 3.91 13.49

Volatile Organic Compounds (VOCs) 0.41 0.12 1.47

Hazardous Air Pollutant (HAPs) 0.13 0.08 0.55

Compliance with the PM and SO2 emission limits shall demonstrate compliance with the less stringent limits

of 45CSR§2-4.1.b. and 45CSR§10-3.1.e.

[45CSR13 - R13-2140, Condition A.4., 45CSR§2-4.1.b., and 45CSR§10-3.1.e.]

8.1.14. Emissions from Boiler No. 5 (005P104) shall not exceed the limits set forth in the table below:
Title V Operating Permit R30-03500002-2010 Page 43 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Pollutant Pounds per Hour (lb/hr)

(combusting natural gas)

Pounds per Hour (lb/hr)

(combusting fuel oil)

Tons per Year (TPY)

(any combination of fuel)

Carbon Monoxide 3.08 1.29 13.51

Nitrogen Oxides 1.84 5.16 22.60

Particulate Matter 0.28 1.08 4.73

Sulfur Dioxide 0.02 1.83 8.02

Volatile Organic Compounds (VOCs) 0.20 0.06 0.88

Hazardous Air Pollutant (HAPs) 0.06 0.04 0.27

Compliance with the PM and SO2 emission limits shall demonstrate compliance with the less stringent limits

of 45CSR§2-4.1.b. and 45CSR§10-3.1.e.

[45CSR13 - R13-2140, Condition A.5., 45CSR§2-4.1.b., and 45CSR§10-3.1.e.]

8.1.15. Boilers No. 4 (Equip ID No. 005P103) and No. 5 (Equip. ID No. 005P104) shall comply with all applicable

provisions of 40 C.F.R. 60, Subpart Dc - “Standards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units,” provided that the boilers shall comply with any more stringent

requirements as may be set forth under the requirements of this permit.

[40 C.F.R. § 60.40c and 45CSR16]

8.1.16. If US EPA has not already promulgated a standard pursuant to 40 C.F.R. 63 for industrial, commercial,

institutional boilers and process heaters, the facility shall submit a Part 1 112(j) “equivalent emission limitation

by permit” application for case-by-case MACT determination, containing the information required in 40 C.F.R.

§ 63.53 (a), within thirty (30) days of the date for a final rule specified in the final order of the United States

District Court for the District of Columbia, which is currently December 16, 2010. The Part 1 112(j)

application shall identify each affected unit, and address HAP emissions from each of the boilers and process

heaters. If the facility determines there are no affected units (boilers or process heaters), a statement of nonapplicability must be submitted in lieu of a Part 1 application. A Part 2 112(j) “equivalent emission limitation

by permit” application for case-by-case MACT determination containing information required in 40 C.F.R. §

63.53 (b) is due within 60 days of the Part 1 112(j) application submittal. All 112 (j) “equivalent emission

limitation by permit” applications must be submitted to both WVDEP-Division of Air Quality, and Chief of

Permits and Technical Branch, US EPA Region III, Mail Code 3AP11, 1650 Arch Street, Philadelphia, PA,

19103-2029.

[45CSR34, 40 C.F.R. § 63.52]

8.2. Monitoring Requirements

8.2.1. Compliance with the visible emission requirements of Section 8.1.1. shall be determined in accordance with

40 CFR Part 60, Appendix A, Method 9 on a quarterly basis. If the result of any visible emissions test is equal

to or exceeds 10% opacity, then an evaluation to determine the cause of the exceedance shall be conducted

within three (3) days, unless the cause of the exceedance is corrected within 24 hours.

[45CSR§2-3.2., 45CSR13 - R13-2140, Condition B.1., and 45CSR§30-5.1.c.]

8.2.2. Compliance with the allowable sulfur dioxide emission limitations from fuel burning units shall be based on

a continuous twenty-four (24) hour averaging time. The permittee shall not allow emissions to exceed the

weight emissions standards for sulfur dioxide as set forth in this rule, except during one (1) continuous twenty-
Title V Operating Permit R30-03500002-2010 Page 44 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

four (24) hour period in each calendar month and during this one (1) continuous twenty-four hour period said

owner and/or operator shall not allow emissions to exceed such weight emission standards by more than ten

percent (10%) without causing a violation of this rule. A continuous twenty-four (24) hour period is defined

as one (1) calendar day.

[45CSR§10-3.8.]

8.2.3. The liquid pitch hot oil heaters shall be operated and maintained in accordance with the manufacturer’s

recommendations and specifications and in a manner consistent with good operating practices and shall only

burn natural gas.

[45CSR§30-5.1.c. (002P139 & 002P140)]

8.2.4. For distillate oil-fired affected facilities with heat input capacities between 2.9 and 29 MW (10 and 100 million

Btu/hr), where the owner or operator seeks to demonstrate compliance with the SO2

 standards based on fuel

supplier certification, the performance test shall consist of the certification from the fuel supplier, as described

under Section 8.5.2.(d) of this permit, as applicable.

[40 C.F.R. §§60.42c(h)(1) and 60.44c(h), 45CSR16 and 45CSR13 - R13-2140, Condition B.3.]

The CEMS and fuel sampling monitoring requirements of 40 C.F.R. § 60.46c (a) and (d) shall not apply to

affected facilities subject to 40 C.F.R. § 60.42c(h) (1), (2), or (3) where the owner or operator of the affected

facility seeks to demonstrate compliance with the SO2

 standards based on fuel supplier certification, as

described under 40 C.F.R. § 60.48c(f) (1), (2), or (3), as applicable.

[40 C.F.R. §60.46c(e), 45CSR16 and 45CSR13 - R13-2140, Condition B.3.]

8.3. Testing Requirements

8.3.1. For Boilers No. 4 and No. 5: At such reasonable times as the Director may designate, the owner or operator

of any fuel burning unit(s) may be required to conduct or have conducted tests to determine the compliance of

such unit(s) with the emission limitations of section 8.1.2. Such tests shall be conducted in accordance with

the appropriate method set forth in the Appendix to Rule 2 or other equivalent EPA approved method approved

by the Director. The Director, or his duly authorized representative, may at his option witness or conduct such

tests. Should the Director exercise his option to conduct such tests, the operator will provide all necessary

sampling connections and sampling ports located in such manner as the Director may require, power for test

equipment, and the required safety equipment such as scaffolding, railings and ladders to comply with generally

accepted good safety practices.

[45CSR§2-8.1.b. and 45CSR13 - R13-2140, Condition B.1.]

Sufficient information on temperatures, velocities, pressures, weights and dimensional values shall be reported

to the Director, with such necessary commentary as he may require to allow an accurate evaluation of the

reported test results and the conditions under which they were obtained.

[45CSR§2-8.1.b.1. and 45CSR13 - R13-2140, Condition B.1.]

The Director, or his duly authorized representative, may conduct such other tests as he may deem necessary to

evaluate air pollution emissions other than those noted in Section 8.1.2.

[45CSR§2-8.1.c. and 45CSR13 - R13-2140, Condition B.1.]

8.3.2. Compliance and performance test methods and procedures for particulate matter.

The permittee shall conduct an initial performance test as required under 40 C.F.R. § 60.8, and shall conduct

subsequent performance tests as requested by the Administrator, to determine compliance with the standards
Title V Operating Permit R30-03500002-2010 Page 45 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

using the following procedures and reference methods: Method 9 (6-minute average of 24 observations) shall

be used for determining the opacity of stack emissions.

[40 C.F.R. § 60.45c and 45CSR16]

8.4. Recordkeeping Requirements

8.4.1. The permittee shall maintain on-site all records of monitored data. Such records shall be made available to the

Director or his duly authorized representative upon request. Such records shall be retained on-site for a

minimum of five years.

[45CSR§2-8.3.a.]

The permittee shall submit a periodic exception report to the Director, in a manner and at a frequency to be

established by the Director. Such exception report shall provide details of all excursions outside the range of

measured emissions or monitored parameters, and shall include, but not be limited to, the time of the excursion,

the magnitude of the excursion, the duration of the excursion, the cause of the excursion and the corrective

action taken.

[45CSR§2-8.3.b.]

8.4.2. The permittee shall maintain records of the operating schedule, and the quality and quantity of fuel burned in

each fuel burning unit as specified: For fuel burning units which burn only pipeline quality natural gas, such

records shall include, but not be limited to, the date and time of start-up and shutdown, and the quantity of fuel

consumed on a monthly basis. For fuel burning units which burn only distillate oil, such records shall include,

but not be limited to, the date and time of start-up and shutdown, the quantity of fuel consumed on a monthly

basis and a BTU analysis for each shipment. For fuel burning unit(s) which burn a combination of fuels, the

owner or operator shall comply with the applicable recordkeeping requirements for each fuel burned.

[45CSR§2A-7.1.a. and 45CSR§2-8.3.c.]

8.4.3. For the purpose of determining compliance with the maximum heat input and fuel consumption limitations

established for the boilers as set forth in Sections 8.1.10. and 8.1.11., and the maximum emission rate limits

established for the boilers as set forth in Sections 8.1.13. and 8.1.14., the permittee shall maintain daily,

monthly, and annual records of the type and amount of fuel usage, hours of operations, and maintenance work

performed on individual boilers. Certified copies of these records shall be made available to the Director or

his/her duly authorized representative upon request.

[45CSR13 - R13-2140, Condition B.6.]

8.5. Reporting Requirements

8.5.1. The owner or operator of a fuel burning unit(s) subject to this rule shall report to the Director any malfunction

of such unit or its air pollution control equipment which results in any excess particulate matter emission rate

or excess opacity as provided in one of the following subdivisions:

a. Excess opacity periods meeting the following conditions may be reported on a quarterly basis unless

otherwise required by the Director:

1. The excess opacity period does not exceed thirty (30) minutes within any 24-hour period; and

2. Excess opacity does not exceed 40%.
Title V Operating Permit R30-03500002-2010 Page 46 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

b. The owner or operator shall report to the Director any malfunction resulting in excess particulate matter

or excess opacity, not meeting the criteria set forth in Section 8.5.1.a., by telephone, telefax, or e-mail by

the end of the next business day after becoming aware of such condition. The owner or operator shall file

a certified written report concerning the malfunction with the Director within thirty (30) days providing

the following information:

1. A detailed explanation of the factors involved or causes of the malfunction;

2. The date and time of duration (with starting and ending times) of the period of excess emissions;

3. An estimate of the mass of excess emissions discharged during the malfunction period;

4. The maximum opacity measured or observed during the malfunction;

5. Immediate remedial actions taken at the time of the malfunction to correct or mitigate the effects of

the malfunction; and

6. A detailed explanation of the corrective measures or program that will be implemented to prevent a

recurrence of the malfunction and a schedule for such implementation.

[45CSR§2-9.3.]

8.5.2. Reporting and record keeping requirements.

a. The owner or operator of each affected facility shall submit notification of the date of any reconstruction as

provided by 40 C.F.R. § 60.7 of this part.

b. The owner or operator of each affected facility subject to the SO2 emission limits of 40 C.F.R. §60.42c shall

submit to the Administrator the performance test data from the initial and any subsequent performance tests.

c. The owner or operator of each affected facility subject to the fuel oil sulfur limits under 40 C.F.R. §60.42c shall

keep records and submit quarterly reports to the Administrator. Each quarterly report shall be postmarked by

the 30th day following the end of the reporting period and include:

1. Calendar dates covered in the reporting period.

2. Each 30-day average sulfur content (weight percent), calculated during the reporting period, ending with

the last 30-day period in the quarter; reasons for any noncompliance with the emission standards; and a

description of corrective actions taken.

3. If fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification as

described under paragraph d. of this section, as applicable. In addition to records of fuel supplier

certifications, the quarterly report shall include a certified statement signed by the owner or operator of the

affected facility that the records of fuel supplier certifications submitted represent all of the fuel combusted

during the quarter.

d. Fuel supplier certification for distillate oil shall include the following information: the name of the oil supplier

and a statement from the oil supplier that the oil complies with the specifications under the definition of

distillate oil in 40 C.F.R. §60.41c.
Title V Operating Permit R30-03500002-2010 Page 47 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

e. The owner or operator of each affected facility shall record and maintain records of the amounts of each fuel

combusted during each day.

f. All records required under this section shall be maintained by the owner or operator of the affected facility for

a period of two years following the date of such record.

[40 C.F.R. § 60.48c and 45CSR16]

8.6. Compliance Plan

8.5.1. None.
Title V Operating Permit R30-03500002-2010 Page 48 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

9.0. Primary Aluminum MACT (40 CFR Part 63 Subpart LL) Sources Requirements

9.1. Limitations and Standards

9.1.1. No person shall cause, suffer, allow, or permit PM to be vented into the open air from any type source operation

or duplicate source operation, or from all air pollution control equipment installed on any type source operation

or duplicate source operation in excess of the quantities specified in this permit.

Emission

Unit ID

Equipment Maximum Allowable PM Emission Limit

(lb/hr)

002P111 Auto Scale AL-1 33

002P112 Auto Scale AL-2 33

002P113 Screw Conveyor K-101 33

002P114 Batch car 33

002P115 South Mixers 1-8 33

002P116 North Mixers 9-16 33

002P117 Belt Conveyor I-6 31.56

002P118 Belt Conveyor I-7 31.56

002P119 Belt Conveyor V-4 34.12

002P120 Belt Conveyor I-8 34.12

002P121 Belt Conveyor I-9 34.12

002P122 Belt Conveyor I-10 34.12

002P123 Cooling Screw AG-1 34.12

002P124 Cooling Screw AG-2 34.12

002P125 Cooling Screw AG-3 34.12

002P126 Cooling Screw AG-4 34.12

002P127 Disc Feeder W11

34.12

002P128 Disc Feeder W12

002P129 Anode Press AJ-1

34.12

002P130 Anode Press AJ-2

002P131 Belt Conveyor I-11 34.12

002P132 Screw Conveyor K-103 34.12

002P135 Screw Conveyor K-321 2.88

002P141 Screw Conveyor K-100 33

002P142 Collecting Hopper 33
Title V Operating Permit R30-03500002-2010 Page 49 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

Emission

Unit ID

Equipment Maximum Allowable PM Emission Limit

(lb/hr)

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

003P109 Building No. 52 Ring Furnace 20.8

003P110 Building No. 53 Ring Furnace 20.8

004P113 Ore Bucket-Line 1A 33.8

004P114 Ore Bucket-Line 1B 33.8

004P115 Ore Bucket-Line 2A 35.4

004P116 Ore Bucket-Line 2B 35.4

004P213 Ore Bucket-Line 3A 33.8

004P214 Ore Bucket-Line 3B 33.8

004P215 Ore Bucket-Line 4A 33.8

004P216 Ore Bucket-Line 4B 33.8

[45CSR§7-4.1]

9.1.2. No person shall cause, suffer, allow, or permit emissions of smoke and/or particulate matter into the open air

from any storage structure associated with any manufacturing process.

[45CSR§7-3.7. (002P101 through 002P110, 002P114)]

9.1.3. No person shall cause, suffer, allow or permit the emission into the open air from any source operation an instack sulfur dioxide concentration exceeding 2,000 parts per million by volume from existing source operations,

except as provided in 45CSR§§10-4.1.a through 4.1.e.

[45CSR§10-4.1. (003P109, 003P110, 004P101 through 004P104, 004P201 through 004P204)]

9.1.4. No person shall cause, suffer, allow or permit any manufacturing process or storage structure generating fugitive

particulate matter to operate that is not equipped with a system, which may include, but not be limited to,

process equipment design, control equipment design or operation and maintenance procedures, to minimize the

emissions of fugitive particulate matter. To minimize means such system shall be installed, maintained and

operated to ensure the lowest fugitive particulate matter emissions reasonably achievable.

[45CSR§7-5.1.]

9.1.5. a. Primary aluminum reduction potlines which are equipped with a fluidized bed reactor or other similar gas

cleaning device which utilizes particulate matter as a media or as a component of a media for collecting

or reducing the emissions of gaseous fluorides, shall be exempted from the requirements of 45CSR§§7-4.1

and 4.4 provided that at least ninety-nine percent (99%) of the gaseous fluoride is removed from the exit

gas stream by such device prior to discharging the cleaned gas stream to the open air; and the particulate

matter loading in the exit gas stream is not greater than 0.01 grains per standard cubic foot of dry stack gas.

b. The emissions of gaseous fluorides and particulate fluorides from prebake cells shall be controlled by a

system for continuous emission reduction which system shall achieve at least ninety percent (90%) fluoride

emissions capture efficiency through its primary collection system and at least ninety-nine percent (99%)

fluoride emissions removal efficiency through its primary removal system; and

c. Anode butts from such a plant which are recycled in an on-site anode bake plant shall be cleaned as

necessary to minimize adherent fluoride bearing bath material.

[45CSR§7-4.7.]
Title V Operating Permit R30-03500002-2010 Page 50 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

9.1.6. Potlines. The permittee shall not discharge or cause to be discharged into the atmosphere any emissions of total

fluorides (TF) in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline.

[40 C.F.R. § 63.843(a)(1)(ii) and 45CSR34]

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in the table

below using the procedures in paragraphs (1) and (2) below.

1. Monthly average emissions of TF shall not exceed the applicable emission limit in the table below. The

emission rate shall be calculated based on the total emissions from all potlines over the period divided by

the quantity of aluminum produced during the period, from all potlines comprising the averaging group.

2. To determine compliance with the applicable emission limit for TF emissions, the permittee shall determine

the monthly average emissions in lb/ton from each potline from at least three runs per potline each month

for TF secondary emissions using the procedures and methods in Sections 9.3.1. and 9.3.2. The permittee

shall combine the results of secondary TF monthly average emissions with the TF results for the primary

control system and divide total emissions by total aluminum production.

Type

Monthly TF limit (1b/ton) for given number of potlines

2 lines 3 lines 4 lines 5 lines 6 lines 7 lines 8 lines

CWPB2 2.9 2.8 2.7 2.7 2.6 2.6 2.6

[40 C.F.R. § 63.846(b) and 45CSR34]

9.1.7. Paste production plants. The permittee shall install, operate, and maintain equipment to capture and control

polycyclic organic matter (POM) emissions from each paste production plant.

1. The emission capture system shall be installed and operated to meet the generally accepted 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 Handbook of Recommended Practice"

(incorporated by reference in 40 C.F.R. § 63.841); and

2. Captured emissions shall be routed through a closed system to a dry coke scrubber;

[40 C.F.R. §63.843(b)(1)&(2) and 45CSR34 (VR-371 & Sonair Baghouse R-300)]

9.1.8. Anode bake furnaces. The permittee shall not discharge or cause to be discharged into the atmosphere any

emissions of total fluorides (TF) or polycyclic organic matter (POM) in excess of the limits below.

1. Emissions of total fluorides (TF) shall not exceed 0.10 kg/Mg (0.20 lb/ton) of green anode; and

2. Emissions of polycyclic organic matter (POM) shall not exceed 0.09 kg/Mg (0.18 lb/ton) of green anode.

[40 C.F.R. § 63.843(c)(1) and (2) and 45CSR34 (003P109 and 003P110)]

The permittee may average TF emissions and POM emissions from anode bake furnaces and demonstrate

compliance with the limits in the table below using the procedures in paragraphs 1. and 2. below.

1. Annual emissions of TF and/or POM from a given number of anode bake furnaces making up each

averaging group shall not exceed the applicable emission limit in the table below in any one year; and
Title V Operating Permit R30-03500002-2010 Page 51 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

2. To determine compliance with the applicable emission limit in the table below for anode bake furnaces,

the permittee shall determine TF and/or POM emissions from the control device for each furnace at least

once a year using the procedures and methods in Sections 9.3.1. and 9.3.2.

Number of furnaces 

Emission limit (lb/ton of anode)

TF POM

2 0.11 0.17

3 0.09 0.17

4 0.077 0.17

5 0.07 0.17

[40 C.F.R. § 63.846(c) and 45CSR34]

9.1.9. Pitch storage tanks. Each pitch storage tank shall be equipped with an emission control system designed and

operated to reduce inlet emissions of polycyclic organic matter (POM) by 95 percent or greater.

[40 C.F.R. § 63.844(d) and 45CSR34]

9.1.10. Applicability. The provisions in 40 C.F.R. §§ 63.845(a) through (i) shall apply to any CWPB2 potline that

adds a new potroom group to an existing potline or that is associated with a potroom group that meets the

definition of "modified potroom group" or "reconstructed potroom group."

[40 C.F.R. §§ 63.845(a) through (i) and 45CSR34]

9.2. Monitoring Requirements

9.2.1. The permittee shall demonstrate compliance with Section 9.1.3. by monitoring as set forth in an approved

monitoring plan (see Appendix A) for each emission unit.

[45CSR§10-8.2.c. (003P109, 003110, 004P101 through 004P104, 004P201 through 004P204)]

9.2.2. Initial compliance with the standards in Section 9.1.7. for existing paste production plants will be demonstrated

through site inspection(s) and review of site records by the applicable regulatory authority.

[40 C.F.R. §63.847(f) and 45CSR34 (VR-371 & Sonair Baghouse R-300)]

9.2.3. The permittee shall demonstrate initial compliance with the standard for pitch storage tanks in Section 9.1.9.

by preparing a design evaluation or by conducting a performance test. The permittee shall submit for approval

by the regulatory authority the information specified in 1. and 2. below where a design evaluation is performed

or the information specified in 3. of this section where a performance test is conducted.

1. A description of the parameters to be monitored to ensure that the control device is being properly operated

and maintained, an explanation of the criteria used for selection of that parameter (or parameters), and the

frequency with which monitoring will be performed; and

2. Where a design evaluation is performed, documentation demonstrating that the control device used

achieves the required control efficiency during reasonably expected maximum filling rate. The

documentation shall include a description of the gas stream that enters the control device, including flow

and POM content under varying liquid level conditions, and the information specified in paragraphs i.

through vi., as applicable.
Title V Operating Permit R30-03500002-2010 Page 52 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

i. If the control device receives vapors, gases, or liquids, other than fuels, from emission points other

than pitch storage tanks, the efficiency demonstration is to include consideration of all vapors, gases,

and liquids, other than fuels, received by the control device;

ii. If an enclosed combustion device with a minimum residence time of 0.5 seconds and a minimum

temperature of 760 C (1,400 F) is used to meet the emission reduction requirement specified in

9.1.9., documentation that those conditions exist is sufficient to meet the requirements of 9.1.9.;

iii. Except as provided in paragraph ii. of this section, for thermal incinerators, the design evaluation shall

include the autoignition temperature of the organic HAP, the flow rate of the organic HAP emission

stream, the combustion temperature, and the residence time at the combustion temperature;

iv. If the pitch storage tank is vented to the emission control system installed for control of emissions from

the paste production plant pursuant to Section 9.1.7., documentation of compliance with the

requirements of 9.1.7. is sufficient to meet the requirements of 9.1.9.;

v. For carbon adsorbers, the design evaluation shall include the affinity of the organic vapors for carbon,

the amount of carbon in each bed, the number of beds, the humidity of the feed gases, the temperature

of the feed gases, the flow rate of the organic HAP emission stream, and if applicable, the desorption

schedule, the regeneration stream pressure or temperature, and the flow rate of the regeneration stream.

For vacuum desorption, the pressure drop shall be included; and

vi. For condensers, the design evaluation shall include the final temperature of the organic HAP vapors,

the type of condenser, and the design flow rate of the organic HAP emission stream.

3. If a performance test is conducted, the permittee shall determine the control efficiency for POM during tank

loading using Method 315 in 40 C.F.R. Part 63 appendix A and shall include the following information:

i. Identification of the pitch storage tank and control device for which the performance test will be

submitted; and

ii. Identification of the emission point(s) that share the control device with the pitch storage tank and for

which the performance test will be conducted.

[40 C.F.R. §63.847(g) and 45CSR34]

9.2.4. The permittee shall determine the operating limits and monitoring frequency for each control device that is to

be monitored as required in Section 9.2.7.

1. For potlines and anode bake furnaces, the owner or operator shall determine upper and/or lower operating

limits, as appropriate, for each monitoring device for the emission control system from the values recorded

during each of the runs performed during the initial performance test and from historical data from previous

performance tests conducted by the methods specified in this subpart.

2. For a paste production plant, the owner or operator shall specify and provide the basis or rationale for

selecting parameters to be monitored and the associated operating limits for the emission control device.

3. The owner or operator may redetermine the upper and/or lower operating limits, as appropriate, based on

historical data or other information and submit an application to the applicable regulatory authority to
Title V Operating Permit R30-03500002-2010 Page 53 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

change the applicable limit(s). The redetermined limits shall become effective upon approval by the

applicable regulatory authority.

[40 C.F.R. §63.847(h) and 45CSR34]

9.2.5. TF emissions from potlines. Using the procedures in Section 9.3.1. and in the approved test plan, the permittee

shall monitor emissions of TF from each potline by conducting monthly performance tests. The permittee shall

compute and record the monthly average from at least three runs for secondary emissions and the previous 12-

month average of all runs for the primary control system to determine compliance with the applicable emission

limit. The owner or operator must include all valid runs in the monthly average. The duration of each run for

secondary emissions must represent a complete operating cycle.

[40 C.F.R. §63.848(a) and 45CSR34]

Similar potlines. As an alternative to monthly monitoring of TF emissions from each potline using the test

methods in Section 9.3.2., the permittee may perform monthly monitoring of TF emissions from one potline

using the test methods in Section 9.3.2. to represent the performance of similar potline(s). The similar potline(s)

shall be monitored using an alternative method that meets the requirements of paragraphs 1. through 7. of this

section. Two or more potlines are similar if the owner or operator demonstrates that their structure, operability,

type of emissions, volume of emissions, and concentration of emissions are substantially equivalent.

1. To demonstrate (to the satisfaction of the regulatory authority) that the level of emission control

performance is the same or better, the owner or operator shall perform an emission test using an alternative

monitoring procedure for the similar potline simultaneously with an emission test using the applicable test

methods. The results of the emission test using the applicable test methods must be in compliance with the

applicable emission limit for existing potlines in Section 9.1.6. An alternative method for TF emissions

must account for or include gaseous fluoride and cannot be based on measurement of particulate matter

or particulate fluoride alone.

2. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF

secondary emissions.

3. An permittee electing to use an alternative monitoring procedure shall establish an alternative emission

limit based on at least nine simultaneous runs using the applicable test methods and the alternative

monitoring method. All runs must represent a full process cycle.

4. The owner or operator shall derive an alternative emission limit for the HF continuous emission monitor

or an alternative method using either of the following procedures:

i. Use the highest value from the alternative method associated with a simultaneous run by the applicable

test method that does not exceed the applicable emission limit; or

ii. Correlate the results of the two methods (the applicable test method results and the alternative

monitoring method results) and establish an emission limit for the alternative monitoring system that

corresponds to the applicable emission limit.

5. The owner or operator shall submit the results required in paragraph 4. of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

6. The regulatory authority shall review and approve or disapprove the request for an alternative method and

alternative emission limit. The criterion for approval shall be a demonstration (to the satisfaction of the
Title V Operating Permit R30-03500002-2010 Page 54 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

regulatory authority) that the alternative method and alternative emission limit achieve a level of emission

control that is the same as or better than the level that would have otherwise been achieved by the

applicable method and emission limit.

7. If the alternative method is approved by the applicable regulatory authority, the owner or operator shall

perform monthly emission monitoring using the approved alternative monitoring procedure to demonstrate

compliance with the alternative emission limit for each similar potline.

[40 C.F.R. §63.848(d) and 45CSR34]

Reduced sampling frequency. The permittee may submit a written request to the applicable regulatory authority

to establish an alternative testing requirement to reduce the sampling of secondary TF emissions from potlines

from monthly to quarterly.

1. In the request, the permittee shall provide information and data demonstrating, to the satisfaction of the

applicable regulatory authority, that secondary emissions of TF from potlines have low variability during

normal operations using the procedures in paragraphs i. or ii. below.

i. Submit data from 24 consecutive months of sampling that show the average TF emissions are less than

60 percent of the applicable limit and that no monthly performance test in the 24 months of sampling

exceeds 75 percent of the applicable limit; or

ii. Submit data and a statistical analysis that the regulatory authority may evaluate based on the approach

used in "Primary Aluminum: Statistical Analysis of Potline Fluoride Emissions and Alternative

Sampling Frequency" (EPA-450-86-012, October 1986), which is available from the National

Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, VA 22161.

2. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

3. The owner or operator of a plant that has received approval of an alternative sampling frequency under 40

C.F.R. § 60.194 is deemed to have approval of the alternative sampling frequency under this subpart.

4. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph 1.i. of this section, the owner or operator shall return to monthly sampling for at least 12 months

and may reduce to quarterly sampling when:

i. The average of all tests performed over the most recent 24-month period does not exceed 60 percent

of the applicable limit, and

ii. No more than one monthly performance test in the most recent 24-month period exceeds 75 percent

of the applicable limit.

5. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph 1.ii. of this section, the owner or operator shall immediately return to the monthly sampling

schedule until another request for an alternative sampling frequency is approved by the applicable

regulatory authority.

[40 C.F.R. §63.848(e) and 45CSR34]
Title V Operating Permit R30-03500002-2010 Page 55 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

9.2.6. TF and POM emissions from anode bake furnaces. Using the procedures in Section 9.3.1. and in the approved

test plan, thepermittee shall monitor TF and POM emissions from each anode bake furnace on an annual basis.

The permittee shall compute and record the annual average of TF and POM emissions from at least three runs

to determine compliance with the applicable emission limits. The permittee must include all valid runs in the

annual average.

[40 C.F.R. §63.848(c) and 45CSR34]

9.2.7. Monitoring parameters for emission control devices. The permittee shall install, operate, calibrate, and maintain

a continuous parameter monitoring system for each emission control device. The owner or operator shall

submit for approval by the regulatory authority a description of the parameter(s) to be monitored, the operating

limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained.

An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring

frequency, including how these relate to emission control also shall be submitted to the regulatory authority.

For dry alumina scrubbers, devices for the measurement of alumina flow and air flow shall be installed.

[40 C.F.R. §63.848(f) and 45CSR34]

9.2.8. Visible emissions. The owner or operator shall visually inspect the exhaust stack(s) of each control device on

a daily basis for evidence of any visible emissions indicating abnormal operation.

[40 C.F.R. §63.848(g) and 45CSR34]

9.2.9. Corrective action. If a monitoring device for a primary control device measures an operating parameter outside

the limit(s) established pursuant to Section 9.2.4., if visible emissions indicating abnormal operation are

observed from the exhaust stack of a control device during a daily inspection, or if a problem is detected during

the daily inspection of a wet roof scrubber for potline secondary emission control, the owner or operator shall

initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within 1 hour.

Failure to initiate the corrective action procedures within 1 hour or to take the necessary corrective actions to

remedy the problem is a violation.

[40 C.F.R. §63.848(h) and 45CSR34]

9.2.10. Exceedances. If the limit for a given operating parameter associated with monitoring a specific control device

is exceeded six times in any semiannual reporting period, then any subsequent exceedance in that reporting

period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance

shall be attributed in any given 24-hour period.

[40 C.F.R. §63.848(i) and 45CSR34]

9.2.11. Weight of aluminum and green anodes. The owner or operator of a new or existing potline or anode bake

furnace shall install, operate, and maintain a monitoring device to determine the daily weight of aluminum

produced and the weight of green anode material placed in the anode bake furnace. The weight of green anode

material may be determined by monitoring the weight of all anodes or by monitoring the number of anodes

placed in the furnace and determining an average weight from measurements of a representative sample of

anodes.

[40 C.F.R. §63.848(j) and 45CSR34]

9.2.12. Accuracy and calibration. The owner or operator shall submit recommended accuracy requirements to the

regulatory authority for review and approval. All monitoring devices required by this section must be certified

by the owner or operator to meet the accuracy requirements and must be calibrated in accordance with the

manufacturer's instructions.

[40 C.F.R. §63.848(k) and 45CSR34]
Title V Operating Permit R30-03500002-2010 Page 56 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

9.2.13. Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

[40 C.F.R. §63.848(l) and 45CSR34]

9.2.14. Other control systems. A permittee using a control system not identified in this section shall request that the

applicable regulatory authority include the recommended parameters for monitoring in the facility's part 70

permit.

[40 C.F.R. §63.848(m) and 45CSR34]

9.3. Testing Requirements

9.3.1. Test plan. The permittee shall prepare a site-specific test plan prior to the performance test according to the

requirements of 40 C.F.R. § 63.7(c). The test plan must include procedures for conducting the performance

test required in Section 9.2.5.and 9.2.6. for emission monitoring. In addition to the information required by 40

C.F.R. § 63.7, the test plan shall include:

1. Procedures to ensure a minimum of three runs are performed annually for the primary control system for

each source;

2. For a source with a single control device exhausted through multiple stacks, procedures to ensure that at

least three runs are performed annually by a representative sample of the stacks satisfactory to the

applicable regulatory authority;

3. For multiple control devices on a single source, procedures to ensure that at least one run is performed

annually for each control device by a representative sample of the stacks satisfactory to the applicable

regulatory authority;

4. Procedures for sampling single stacks associated with multiple anode bake furnaces;

5. For plants with roof scrubbers, procedures for rotating sampling among the scrubbers or other procedures

to obtain representative samples as approved by the applicable regulatory authority;

6. Procedures for establishing the frequency of testing to ensure that at least one run is performed before the

15th of the month, at least one run is performed after the 15th of the month, and that there are at least 6

days between two of the runs during the month, or that secondary emissions are measured according to an

alternate schedule satisfactory to the applicable regulatory authority.

[40 C.F.R. § 63.847(b) and 45CSR34]

Performance test requirements. The initial performance test and all subsequent performance tests shall be

conducted in accordance with the requirements of the general provisions in 40 C.F.R. 63 Subpart A, the

approved test plan, and the procedures in this section.

1. TF emissions from potlines. For each potline, the permittee shall measure and record the emission rate of

TF exiting the outlet of the primary control system for each potline and the rate of secondary emissions

exiting through each roof monitor, or for a plant with roof scrubbers, exiting through the scrubbers. Using

Equation 1, the owner or operator shall compute and record the average of at least three runs each month

for secondary emissions and at least three runs each year for the primary control system to determine

compliance with the applicable emission limit. Compliance is demonstrated when the emission rate of TF

is equal to or less than the applicable emission limit in Section 9.1.6. of this permit.
Title V Operating Permit R30-03500002-2010 Page 57 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

Compute the emission rate (Ep) of TF from each potline using Equation 1:

Where:

Ep=emission rate of TF from a potline, kg/Mg (lb/ton);

Cs1=concentration of TF from the primary control system, mg/dscm (mg/dscf);

Qsd=volumetric flow rate of effluent gas corresponding to the appropriate subscript location, dscm/hr

(dscf/hr);

Cs2=concentration of TF as measured for roof monitor emissions, mg/dscm (mg/dscf);

P=aluminum production rate, Mg/hr (ton/hr);

K=conversion factor, 10 6 mg/kg (453,600 mg/lb);

1 = subscript for primary control system effluent gas; and

2 = subscript for secondary control system or roof monitor effluent gas.

2. Previous control device tests. If the permittee has performed more than one test of primary emission

control device(s) for a potline or for a bake furnace during the previous consecutive 12 months, the

average of all runs performed in the previous 12-month period shall be used to determine the

contribution from the primary emission control system.

3. TF and POM emissions from anode bake furnaces. For each anode bake furnace, the permittee shall

measure and record the emission rate of TF and POM exiting the exhaust stacks(s) of the primary

emission control system for each anode bake furnace. Using Equation 2, the permittee shall compute

and record the average of at least three runs each year to determine compliance with the applicable

emission limits for TF and POM. Compliance is demonstrated when the emission rates of TF and POM

are equal to or less than the applicable TF and POM emission limits in Section 9.1.8. of this permit.

[40 C.F.R. § 63.847(d) and 45CSR34]

Compute the emission rate (Eb

) of TF from each anode bake furnace using Equation 2,

Where:

Eb = emission rate of TF, kg/mg (lb/ton) of green anodes produced;

Cs

 = concentration of TF, mg/dscm (mg/dscf);

Qsd = volumetric flow rate of effluent gas, dscm/hr (dscf/hr);

Pb = quantity of green anode material placed in the furnace, mg/hr (ton/hr); and

K = conversion factor, 10 6 mg/kg (453,600 mg/lb).
Title V Operating Permit R30-03500002-2010 Page 58 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

4. Compute the emission rate of POM from each anode bake furnace using Equation 2, where Cs =

concentration of POM, mg/dscm (mg/dscf).

5. Determine the weight of the aluminum tapped from the potline and the weight of the green anode material

placed in the anode bake furnace using the monitoring devices required in 40 C.F.R. § 63.848(j).

6. Determine the aluminum production rate (P) by dividing the number of hours in the calendar month into

the weight of aluminum tapped from the potline during the calendar month that includes the three runs of

a performance test.

7. Determine the rate of green anode material introduced into the furnace by dividing the number of operating

hours in the calendar month into the weight of green anode material used during the calendar month in

which the performance test was conducted.

[40 C.F.R. § 63.847(e) and 45CSR34]

9.3.2. The permittee shall use the following reference methods to determine compliance with the applicable emission

limits for TF and POM emissions:

1. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

2. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

3. Method 3 in appendix A to part 60 of this chapter for gas analysis;

4. Method 13A or Method 13B in appendix A to part 60 of this chapter, or an approved alternative, for the

concentration of TF where stack or duct emissions are sampled;

5. Method 13A or Method 13B and Method 14 or Method 14A in appendix A to part 60 of this chapter or

an approved alternative method for the concentration of TF where emissions are sampled from roof

monitors not employing wet roof scrubbers;

6. Method 315 in appendix A to this part or an approved alternative method for the concentration of POM

where stack or duct emissions are sampled; and

7. Method 315 in appendix A to this part and Method 14 in appendix A to part 60 of this chapter or an

approved alternative method for the concentration of POM where emissions are sampled from roof

monitors not employing wet roof scrubbers.

[40 C.F.R. § 63.849(a) and 45CSR34]

9.3.3. The permittee may use an alternative test method for TF or POM emissions providing:

1. The owner or operator has already demonstrated the equivalency of the alternative method for a specific

plant and has received previous approval from the Administrator or the applicable regulatory authority for

TF or POM measurements using the alternative method; or

2. The owner or operator demonstrates to the satisfaction of the applicable regulatory authority that the results

from the alternative method meet the criteria specified in Section 9.2.5. under Similar Potlines. The results

from the alternative method shall be based on simultaneous sampling using the alternative method and the

following reference methods:
Title V Operating Permit R30-03500002-2010 Page 59 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter; or 

ii. For POM, Method 315 in appendix A to this part and Method 14 in appendix A to part 60 of this

chapter.

[40 C.F.R. § 63.849(e) and 45CSR34]

9.4. Recordkeeping Requirements

9.4.1. The permittee shall maintain on-site a record of all required monitoring data as established in a monitoring plan

(see Appendix A) pursuant to 45CSR§10-8.2.c. Such records shall be made available to the Director or his duly

authorized representative upon request. Such records shall be retained on-site for a minimum of five years.

[45CSR§10-8.3.a. (003P109, 003P110, 004P101 through 004P104, 004P201 through 004P204)]

9.4.2. The permittee shall maintain files of all information (including all reports and notifications) required by 40

C.F.R. § 63.10(b) and by this subpart.

1. The owner or operator must retain each record for at least 5 years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. The most recent 2 years of records must

be retained at the facility. The remaining 3 years of records may be retained offsite;

2. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic

tape, or on microfiche;

3. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

4. In addition to the general records required by 40 C.F.R. § 63.10(b), the owner or operator shall maintain

records of the following information:

i. Daily production rate of aluminum;

ii. Daily production rate of green anode material placed in the anode bake furnace;

iii. A copy of the startup, shutdown, and malfunction plan;

iv. Records of design information for paste production plant capture systems;

v. Records of design information for an alternative emission control device for a paste production plant;

vi. Records supporting the monitoring of similar potlines demonstrating that the performance of similar

potlines is the same as or better than that of potlines sampled by manual methods;

vii. Records supporting a request for reduced sampling of potlines;

 viii. Records supporting the correlation of emissions measured by a continuous emission monitoring system

to emissions measured by manual methods and the derivation of the alternative emission limit derived

from the measurements;

ix. The current implementation plan for emission averaging and any subsequent amendments;
Title V Operating Permit R30-03500002-2010 Page 60 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

x. Records, such as a checklist or the equivalent, demonstrating that the daily inspection of a potline with

wet roof scrubbers for secondary emission control has been performed as required in Section 9.2.7.,

including the results of each inspection;

xi. Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the

exhaust stack for each control device has been performed as required in Section 9.2.8., including the

results of each inspection;

xii. For a potline equipped with an HF continuous emission monitor, records of information and data

required by 40 C.F.R. § 63.10(c);

 xiii. Records documenting the corrective actions taken when the limit(s) for an operating parameter

established under § 63.847(h) were exceeded, when visible emissions indicating abnormal operation

were observed from a control device stack during a daily inspection required under Section 9.2.8., or

when a problem was detected during the daily inspection of a wet roof scrubber for potline secondary

control required in Section 9.2.7.;

xiv. Records documenting any POM data that are invalidated due to the installation and startup of a

cathode; and

xv. Records documenting the portion of TF that is measured as particulate matter and the portion that is

measured as gaseous when the particulate and gaseous fractions are quantified separately using an

approved test method.

[40 C.F.R. § 63.850(e) and 45CSR34]

9.5. Reporting Requirements

9.5.1. The permittee shall submit a periodic exception report to the Director, in a manner specified by the Director.

Such an exception report shall provide details of all excursions outside the range of measured emissions or

monitored parameters established in an approved monitoring plan (see Appendix A) and shall include, but not

be limited to, the time of the excursion, the magnitude of the excursion, the duration of the excursion, the cause

of the excursion and the corrective action taken.

[45CSR§10-8.3.b. (003P109, 003P110, 004P101 through 004P104, 004P201 through 004P204)]

9.5.2. Notifications. The owner or operator shall submit the following written notifications:

1. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

2. Notification that a source is subject to the standard, where the initial startup is before the effective date of

the standard;

3. Notification that a source is subject to the standard, where the source is new or has been reconstructed, the

initial startup is after the effective date of the standard, and for which an application for approval of

construction or reconstruction is not required;

4. Notification of intention to construct a new major source or reconstruct a major source; of the date

construction or reconstruction commenced; of the anticipated date of startup; of the actual date of startup,

where the initial startup of a new or reconstructed source occurs after the effective date of the standard, and
Title V Operating Permit R30-03500002-2010 Page 61 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

for which an application for approval of construction or reconstruction is required [see 40 C.F.R. §§

63.9(b)(4) and (b)(5)];

5. Notification of initial performance test;

6. Notification of initial compliance status;

7. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

8. Notification of compliance approach. The owner or operator shall develop and submit to the applicable

regulatory authority, if requested, an engineering plan that describes the techniques that will be used to

address the capture efficiency of the reduction cells for gaseous hazardous air pollutants in compliance with

the emission limits in Sections 9.1.6., 9.1.7., 9.1.8, and 9.1.9.

[40 C.F.R. § 63.850(a) and 45CSR34]

9.5.3. Performance test reports. The owner or operator shall report the results of the initial performance test as part

of the notification of compliance status required in Section 9.5.2.6. of this section. Except as provided in

Section 9.5.5., the owner or operator shall submit a summary of all subsequent performance tests to the

applicable regulatory authority on an annual basis.

[40 C.F.R. § 63.850(b) and 45CSR34]

9.5.4. Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in 40 C.F.R. § 63.6(e)(3) that contains specific procedures to be followed for

operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a

program of corrective action for malfunctioning process and control systems used to comply with the standard.

The plan does not have to be submitted with the permit appplication or included in the operating permit. The

permitting authority may review the plan upon request. In addition to the information required in 40 C.F.R. §

63.6(e)(3), the plan shall include:

1. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Section 9.2.4., if visible emissions from an exhaust stack

indicating abnormal operation of a control device are observed by the owner or operator during the daily

inspection required in Section 9.2.8., or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Section 9.2.7.; and

2. The owner or operator shall also keep records of each event as required by 40 C.F.R. § 63.10(b) and record

and report if an action taken during a startup, shutdown, or malfunction is not consistent with the

procedures in the plan as described in 40 C.F.R. § 63.6(e)(3)(iv).

[40 C.F.R. § 63.850(c) and 45CSR34]

9.5.5. Excess emissions report. As required by 40 C.F.R. § 63.10(e)(3), the owner or operator shall submit a report

(or a summary report) if measured emissions are in excess of the applicable standard. The report shall contain

the information specified in 40 C.F.R. § 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports

are required as a result of excess emissions.

[40 C.F.R. § 63.850(d) and 45CSR34]

9.6. Compliance Plan

9.6.1. None.
Title V Operating Permit R30-03500002-2010 Page 62 of 69

Century Aluminum of West Virginia, Inc. • Ravenswood Operations

West Virginia Department of Environmental Protection • Division of Air Quality

Approved: April 13, 2010

APPENDIX A

45CSR10 Monitoring Plan