Street Address: Mailing Address:

Lazarus Gov. Center TELE: (614) 644-3020 FAX: (614) 644-2329 Lazarus Gov. Center

122 S. Front Street P.O. Box 1049

Columbus, OH 43215 Columbus, OH 43216-1049

State of Ohio Environmental Protection Agency

02/10/04 CERTIFIED MAIL

06-56-00-0001

Ormet Primary Aluminum Corp.

John Reggi

43840 State Route 7

Hannibal, OH 43931

RE: Final Title V Chapter 3745-77 permit

Dear John Reggi:

Enclosed is the Title V permit that allows you to operate the facility in the manner indicated in the permit. Because this permit may

contain several conditions and restrictions, we urge you to read it carefully.

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not only will this reduce

pollution and energy consumption, but it can also save you money. If you would like to learn ways you can save money while

protecting the environment, please contact our Office of Pollution Prevention at (614) 644-3469.

You are hereby notified that this action of the Director is final and may be appealed to the Environmental Review Appeals

Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing and set forth the action

complained of and the grounds upon which the appeal is based. It must be filed with the Environmental Review Appeals Commission

within thirty (30) days after notice of the Director's action. A copy of the appeal must be served on the Director of the Ohio

Environmental Protection Agency within three (3) days of filing with the Commission. It is also requested by the Director that a copy

of the appeal be served upon the Environmental Enforcement Section of the Office of the Attorney General. An appeal may be filed

with the Environmental Review Appeals Commission at the following address:

Environmental Review Appeals Commission

309 South Fourth Street, Room 222

Columbus, Ohio 43215

If you have any questions, please contact Southeast District Office.

Sincerely,

Michael W. Ahern

Permit Issuance and Data Management Section

Division of Air Pollution Control

cc: Southeast District Office

File, DAPC PMU
State of Ohio Environmental Protection Agency

FINAL TITLE V PERMIT

Issue Date: 02/10/04 Effective Date: 03/02/04 Expiration Date: 03/02/09

This document constitutes issuance of a Title V permit for Facility ID: 06-56-00-0001 to:

Ormet Primary Aluminum Corp.

43840 State Route 7

Hannibal, OH 43931

Emissions Unit ID (Company ID)/Emissions Unit Activity Description

B004 (Gas or Oil Field Boiler-36.4

MMBTU/hr.-291-1)

Boiler-36.4 MMBTU/hr.

B005 (Gas or Oil Field Boiler-36.4

MMBTU/hr.-292-2)

Boiler-36.4 MMBTU/hr.-292-2

B006 (Preheater (Glass Plant))

Glass Plant Preheater

F002 (Roads and Parking)

Roads and Parking

F003 (Dross Handling)

Dross Handling 

F004 (Crushed Spent Anode Handling & Barge

Loading)

Crushed Spent Anode Handling and Loading

P022 (Rod Cleaner)

Rod Cleaner

P036 (Butt/Coke Class. K-640-37)

Butt/Coke Class. K-640-37

P072 (1-640-339 North System)

Belt Elevator

P080 (Thixo Casting)

Billet Casting facility

P101 (Coke Belt Conveyor)

Coke Belt Conveyor

P102 (Belt Elevator)

Belt Evelator

P103 (Butt/Fractions Blend)

Butt/Fractions Blend

P134 (K-640-325/329)

K-640-325/329

P203 (Tumbling Mill)

Tumbling Mill

P213 (Hartman System Coke Fines-K661)

Hartman System Coke Fines

P214 (Hartman System Coke Fines-K662)

Hartman System Coke Fines

P215 (Hartman System Coke Fines-K663)

Hartman System Coke Fines-K663

P216 (Hartman System Coke Fines-K664)

Hartman System Coke Fines-K664

P217 (Hartman System Coke Fines-K665)

Hartman System Coke Fines-K665

P230 (Electromelt Furnace F-670-1)

Electromelt Furnace F-670-1

P231 (Electromelt Furnace F-670-2)

Electromelt Furnace F-670-2

P232 (Electromelt Furnace F-670-3)

Electromelt Furnace F-670-3

P233 (Direct Chill Casting Pit No. 3)

Direct Chill Casting Pit No. 3

P235 (Direct Chill Casting Pit No. 1)

Direct Chill Casting Pit No. 1

P236 (SPL Vitrification #1)

Spent Potliner vitrification (permit 2 of 2)

P238 (Induction Furnace)

Casthouse Induction Furnace

P900 (Anode Baking Furnace-665)

Anode Baking Furnace-665

P901 (Alumina Ore Handling)

Conveyor Alumina Ore Handling System

P902 (Hartman Unloader #1)

Hartman Unloader #1

P903 (Hartman Unloader #2)

Hartman Unloader #2

P904 (Hartman Unloader #3)

Hartman Unloader #3

P905 (Hartman Unloader #4)

Hartman Unloader #4

P919 (Bath Screen Feeder)

Bath Screen Feeder

P920 (Bath Crusher)

Bath Crusher Hammer Mill

P923 (Scrap Carbon Crusher)

Carbon Crusher

P955 (Pots 0-42, 1-A)

Pots 0-42, 1-A

P956 (Pots 43-85, 1A)

Pots 43-85, 1A

P957 (Pots 0-42, 1-B)

Pots 0-42, 1-B

P958 (Pots 43-85, 1B)

Pots 43-85, 1B

P959 (Pots 0-42, 2A)

Pots 0-42, 2A

P960 (Pots 43-85, 2A)

Pots 43-85, 2A

P961 (Pots 0-42, 2B)

Pots 0-42, 2B

P962 (Pots 43-85, 2B)

Pots 43-85, 2B

P963 (Pots 0-42, 3A)

Pots 0-42, 3A

P964 (Pots 43-85, 3A)

Pots 43-85, 3A

P965 (Pots 0-42, 3B)

Pots 0-42, 3B

P966 (Pots 43-85, 3B)

Pots 43-85, 3B

P967 (Pots 0-42, 4A)

Pots 0-42, 4A

P968 (Pots 43-85, 4A)

Pots 43-85, 4A

P969 (Pots 0-42, 4B)

Pots 0-42, 4B

P970 (Pots 43-85, 4B)

Pots 43-85, 4B

P971 (Pots 0-42, 5A)

Pots 0-42, 5A

P972 (Pots 43-85, 5A)

Pots 43-85, 5A

P973 (Pots 0-42, 5B)

Pots 0-42, 5B

P974 (Pots 43-85, 5B)

Pots 43-85, 5B
P975 (Pots 0-42, 6A)

Pots 0-42, 6A

P976 (Pots 43-85, 6A)

Pots 43-85, 6A

P977 (Pots 0-42, 6B)

Pots 0-42, 6B

P978 (Pots 43-85, 6B)

Pots 43-85, 6B

P979 (SPL Vitrification #2)

Spent Potliner vitrification (permit 1 of 2)

P996 (Anode Baking Furnace-661)

Anode Baking Furnace-661

P997 (Anode Baking Furnace-662)

Anode Baking Furnace-662

P998 (Anode Baking Furnace-663)

Anode Baking Furnace-663

P999 (Anode Baking Furnace-664)

Anode Baking Furnace-664

R001 (Paint Booth Bld 212)

Paint Shop (Building 212) Paint Booth 

You will be contacted approximately eighteen (18) months prior to the expiration date regarding the renewal of this permit. If you are

not contacted, please contact the appropriate Ohio EPA District Office or local air agency listed below. This permit and the

authorization to operate the air contaminant sources (emissions units) at this facility shall expire at midnight on the expiration date

shown above. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate pursuant to OAC

rule 3745-77-08(E) and in accordance with the terms of this permit beyond the expiration date, provided that a complete renewal

application is submitted no earlier than eighteen (18) months and no later than one-hundred eighty (180) days prior to the expiration

date.

Described below is the current Ohio EPA District Office or local air agency that is responsible for processing and administering your

Title V permit:

Southeast District Office

2195 Front Street

Logan, OH 43138

(740) 385-8501

OHIO ENVIRONMENTAL PROTECTION AGENCY

Christopher Jones

Director
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 1

PART I - GENERAL TERMS AND CONDITIONS

A. State and Federally Enforceable Section

1. Monitoring and Related Record Keeping and Reporting Requirements

a. Except as may otherwise be provided in the terms and conditions for a specific emissions unit, i.e., in

Section A.III of Part III of this Title V permit, the permittee shall maintain records that include the

following, where applicable, for any required monitoring under this permit:

i. The date, place (as defined in the permit), and time of sampling or measurements.

ii. The date(s) analyses were performed.

iii. The company or entity that performed the analyses.

iv. The analytical techniques or methods used.

v. The results of such analyses.

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

(Authority for term: OAC rule 3745-77-07(A)(3)(b)(i))

b. Each record of any monitoring data, testing data, and support information required pursuant to this permit

shall be retained for a period of five years from the date the record was created. Support information

shall include all calibration and maintenance records and all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Such records may be

maintained in computerized form.

(Authority for term: OAC rule 3745-77-07(A)(3)(b)(ii))

c. The permittee shall submit required reports in the following manner:

i. All reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviations

caused by malfunctions shall be submitted in the following manner:

Any malfunction, as defined in OAC rule 3745-15-06(B)(1), shall be promptly reported to the

Ohio EPA in accordance with OAC rule 3745-15-06. In addition, to fulfill the OAC rule 3745-

77-07(A)(3)(c) deviation reporting requirements for malfunctions, written reports that identify

each malfunction that occurred during each calendar quarter (including each malfunction

reported only verbally in accordance with OAC rule 3745-15-06) shall be submitted by January

31, April 30, July 31, and October 31 of each year in accordance with General Term and

Condition A.1.c.ii below; and each report shall cover the previous calendar quarter.

In accordance with OAC rule 3745-15-06, a malfunction constitutes a violation of an emission

limitation (or control requirement) and, therefore, is a deviation of the federally enforceable

permit requirements. Even though verbal notifications and written reports are required for

malfunctions pursuant to OAC rule 3745-15-06, the written reports required pursuant to this term

must be submitted quarterly to satisfy the prompt reporting provision of OAC rule 3745-77-

07(A)(3)(c).

In identifying each deviation caused by a malfunction, the permittee shall specify the emission

limitation(s) (or control requirement(s)) for which the deviation occurred, describe each

deviation, and provide the magnitude and duration of each deviation. For a specific malfunction,

if this information has been provided in a written report that was submitted in accordance with

OAC rule 3745-15-06, the permittee may simply reference that written report to identify the

deviation. Nevertheless, all malfunctions, including those reported only verbally in accordance

with OAC rule 3745-15-06, must be reported in writing on a quarterly basis.
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 2

Any scheduled maintenance, as referenced in OAC rule 3745-15-06(A)(1), that results in a

deviation from a federally enforceable emission limitation (or control requirement) shall be

reported in the same manner as described above for malfunctions.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

ii. Except as may otherwise be provided in the terms and conditions for a specific emissions

unit, i.e., in Section A.IV of Part III of this Title V permit or, in some cases, in Part II of

this Title V permit, all reporting required in accordance with OAC rule 3745-77-

07(A)(3)(c) for deviations of the emission limitations, operational restrictions, and control

device operating parameter limitations shall be submitted in the following manner:

Written reports of (a) any deviations from federally enforceable emission limitations, operational

restrictions, and control device operating parameter limitations, (b) the probable cause of such

deviations, and (c) any corrective actions or preventive measures taken, shall be promptly made

to the appropriate Ohio EPA District Office or local air agency. Except as provided below, the

written reports shall be submitted by January 31, April 30, July 31, and October 31 of each year;

and each report shall cover the previous calendar quarter.

In identifying each deviation, the permittee shall specify the emission limitation(s), operational

restriction(s), and/or control device operating parameter limitation(s) for which the deviation

occurred, describe each deviation, and provide the estimated magnitude and duration of each

deviation.

These written reports shall satisfy the requirements (in part) of OAC rule 3745-77-07(A)(3)(c)

pertaining to the submission of monitoring reports every six months and to the prompt reporting

of all deviations. OAC rule 3745-77-07(A)(3)(c) is not fully satisfied until the permittee

addresses all other deviations of the federally enforceable requirements specified in the permit.

If an emissions unit has a deviation reporting requirement for a specific emission limitation,

operational restriction, or control device operating parameter limitation that is not on a quarterly

basis (e.g., within 30 days following the end of the calendar month, or within 30 or 45 days after

the exceedance occurs), that deviation reporting requirement overrides the reporting

requirements specified in this General Term and Condition for that specific emission limitation,

operational restriction, or control device parameter limitation. Following the provisions of that

non-quarterly deviation reporting requirement will also satisfy the requirements (in part) of OAC

rule 3745-77-07(A)(3)(c) pertaining to the submission of monitoring reports every six months

and to the prompt reporting of all deviations, and additional quarterly deviation reports for that

specific emission limitation, operational restriction, or control device parameter limitation are

not required pursuant to this General Term and Condition.

See B.6 below if no deviations occurred during the quarter.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

iii. All reporting required in accordance with the OAC rule 3745-77-07(A)(3)(c) for other

deviations of the federally enforceable permit requirements which are not reported in

accordance with General Term and Condition A.1.c.ii above shall be submitted in the

following manner:

Written reports that identify all other deviations of the federally enforceable requirements

contained in this permit, including the monitoring, record keeping, and reporting requirements,

which are not reported in accordance with General Term and Condition A.1.c.ii above shall be
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 3

submitted to the appropriate Ohio EPA District Office or local air agency by January 31 and July

31 of each year; and each report shall cover the previous six calendar months.

In identifying each deviation, the permittee shall specify the federally enforceable requirement

for which the deviation occurred, describe each deviation, and provide the magnitude and

duration of each deviation.

These semi-annual written reports shall satisfy the reporting requirements of OAC rule 3745-77-

07(A)(3)(c) for any deviations from the federally enforceable requirements contained in this

permit that are not reported in accordance with General Term and Condition A.1.c.ii above.

If no such deviations occurred during a six-month period, the permittee shall submit a semiannual report which states that no such deviations occurred during that period.

(Authority for term: OAC rules 3745-77-07(A)(3)(c)(i) and (ii))

iv. Each written report shall be signed by a responsible official certifying that, "based on

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

report (including any written malfunction reports required by OAC rule 3745-15-06 that are

referenced in the deviation reports) are true, accurate, and complete."

(Authority for term: OAC rule 3745-77-07(A)(3)(c)(iv))

v. Reports of any required monitoring and/or record keeping information shall be submitted to the

appropriate Ohio EPA District Office or local air agency.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

2. Scheduled Maintenance

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph

(A) of OAC rule 3745-15-06. Except as provided in OAC rule 3745-15-06(A)(3), any scheduled maintenance

necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the

shutdown of the emissions unit(s) that is (are) served by such control system(s). Any scheduled maintenance, as

defined in OAC rule 3745-15-06(A)(1), that results in a deviation from a federally enforceable emission

limitation (or control requirement) shall be reported in the same manner as described for malfunctions in General

Term and Condition A.1.c.i above.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

3. Risk Management Plans

If applicable, the permittee shall develop and register a risk management plan pursuant to section 112(r) of the

Clean Air Act, as amended, 42 U.S.C. § 7401 et seq. (“Act”); and, pursuant to 40 C.F.R. 68.215(a), the permittee

shall submit either of the following:

a. a compliance plan for meeting the requirements of 40 C.F.R. Part 68 by the date specified in 40

C.F.R. 68.10(a) and OAC 3745-104-05(A); or

b. as part of the compliance certification submitted under 40 C.F.R. 70.6(c)(5), a certification

statement that the source is in compliance with all requirements of 40 C.F.R. Part 68 and OAC

Chapter 3745-104, including the registration and submission of the risk management plan.

(Authority for term: OAC rule 3745-77-07(A)(4))

4. Title IV Provisions

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee shall ensure

that any affected emissions unit complies with those requirements. Emissions exceeding any allowances that are

lawfully held under Title IV of the Act, or any regulations adopted thereunder, are prohibited.
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 4

(Authority for term: OAC rule 3745-77-07(A)(5))

5. Severability Clause

A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any

other term or condition thereof, except to the extent that any other term or condition depends in whole or in part

for its operation or implementation upon the term or condition declared invalid.

(Authority for term: OAC rule 3745-77-07(A)(6))

6. General Requirements

a. The permittee must comply with all terms and conditions of this permit. Any noncompliance with the

federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is

grounds for enforcement action or for permit revocation, revocation and reissuance, or modification, or

for denial of a permit renewal application.

b. It shall not be a defense for the 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 federally enforceable terms

and conditions of this permit.

c. This permit may be modified, reopened, revoked, or revoked and reissued, for cause, in accordance with

A.10 below. The filing of a request by the permittee for a permit modification, revocation and

reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not

stay any term and condition of this permit.

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

e. The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the

Director, upon receipt of a written request and within a reasonable time, any information that may be

requested to determine whether cause exists for modifying, reopening or revoking this permit or to

determine compliance with this permit. Upon request, the permittee shall also furnish to the Director or

an authorized representative of the Director, copies of records required to be kept by this permit. For

information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S.

EPA requests such information, the permittee may furnish such records directly to the Administrator

along with a claim of confidentiality.

(Authority for term: OAC rule 3745-77-07(A)(7))

7. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 and OAC

Chapter 3745-78.

(Authority for term: OAC rule 3745-77-07(A)(8))

8. Marketable Permit Programs

No revision of this permit is required under any approved economic incentive, marketable permits, emissions

trading, and other similar programs or processes for changes that are provided for in this permit.

(Authority for term: OAC rule 3745-77-07(A)(9))

9. Reasonably Anticipated Operating Scenarios

The permittee is hereby authorized to make changes among operating scenarios authorized in this permit without

notice to the Ohio EPA, but, contemporaneous with making a change from one operating scenario to another, the

permittee must record in a log at the permitted facility the scenario under which the permittee is operating. The

permit shield provided in these general terms and conditions shall apply to all operating scenarios authorized in

this permit.

(Authority for term: OAC rule 3745-77-07(A)(10))
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 5

10. Reopening for Cause

This Title V permit will be reopened prior to its expiration date under the following conditions:

a. Additional applicable requirements under the Act become applicable to one or more emissions units

covered by this permit, and this permit has a remaining term of three 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 paragraph (E)(1) of OAC rule 3745-77-08.

b. This permit is issued to an affected source under the acid rain program and additional requirements

(including excess emissions requirements) become applicable. Upon approval by the Administrator,

excess emissions offset plans shall be deemed to be incorporated into the permit, and shall not require a

reopening of this permit.

 c. The Director of the Ohio EPA or the Administrator of the U.S. EPA determines that the federally

applicable requirements in this permit are based on a material mistake, or that inaccurate statements were

made in establishing the emissions standards or other terms and conditions of this permit related to such

federally applicable requirements.

 d. The Administrator of the U.S. EPA or the Director of the Ohio EPA determines that this permit must be

revised or revoked to assure compliance with the applicable requirements.

(Authority for term: OAC rules 3745-77-07(A)(12) and 3745-77-08(D))

11. Federal and State Enforceability

Only those terms and conditions designated in this permit as federally enforceable, that are required under the

Act, or any of its applicable requirements, including relevant provisions designed to limit the potential to emit of

a source, are enforceable by the Administrator of the U.S. EPA, the State, and citizens under the Act. All other

terms and conditions of this permit shall not be federally enforceable and shall be enforceable under State law

only.

(Authority for term: OAC rule 3745-77-07(B))

12. Compliance Requirements

a. Any document (including reports) required to be submitted and required by a federally applicable

requirement in this Title V permit shall include a certification by a responsible official that, based on

information and belief formed after reasonable inquiry, the statements in the document are true, accurate,

and complete.

b. Upon presentation of credentials and other documents as may be required by law, the permittee shall

allow the Director of the Ohio EPA or an authorized representative of the Director to:

i. At reasonable times, enter upon the permittee's premises where a source is located or the

emissions-related activity is conducted, or where records must be kept under the conditions of

this permit.

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

of this permit, subject to the protection from disclosure to the public of confidential information

consistent with paragraph (E) of OAC rule 3745-77-03.

iii. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution

control equipment), practices, or operations regulated or required under this permit.

iv. As authorized by the Act, sample or monitor at reasonable times substances or parameters for the

purpose of assuring compliance with the permit and applicable requirements.
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 6

c. The permittee shall submit progress reports to the appropriate Ohio EPA District Office or local air

agency concerning any schedule of compliance for meeting an applicable requirement. Progress reports

shall be submitted semiannually, or more frequently if specified in the applicable requirement or by the

Director of the Ohio EPA. Progress reports shall contain the following:

i. Dates for achieving the activities, milestones, or compliance required in any schedule of

compliance, and dates when such activities, milestones, or compliance were achieved. 

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

any preventive or corrective measures adopted.

d. Compliance certifications concerning the terms and conditions contained in this permit that are federally

enforceable emission limitations, standards, or work practices, shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) and the Administrator of the U.S. EPA in the

following manner and with the following content:

i. Compliance certifications shall be submitted annually on a calendar year basis. The annual

certification shall be submitted on or before April 30th of each year during the permit term.

ii. Compliance certifications shall include the following:

(a) An identification of each term or condition of this permit that is the basis of the

certification.

(b) The permittee's current compliance status.

(c) Whether compliance was continuous or intermittent.

(d) The method(s) used for determining the compliance status of the source currently and

over the required reporting period.

(e) Such other facts as the Director of the Ohio EPA may require in the permit to determine

the compliance status of the source.

iii. Compliance certifications shall contain such additional requirements as may be specified 

pursuant to sections 114(a)(3) and 504(b) of the Act.

(Authority for term: OAC rules 3745-77-07(C)(1),(2),(4) and (5) and ORC section 3704.03(L))

13. Permit Shield

a. Compliance with the terms and conditions of this permit (including terms and conditions established for

alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and

conditions for which the permit shield is expressly prohibited under OAC rule 3745-77-07) shall be

deemed compliance with the applicable requirements identified and addressed in this permit as of the

date of permit issuance.

b. This permit shield provision shall apply to any requirement identified in this permit pursuant to OAC rule

3745-77-07(F)(2), as a requirement that does not apply to the source or to one or more emissions units

within the source.

(Authority for term: OAC rule 3745-77-07(F))

14. Operational Flexibility

The permittee is authorized to make the changes identified in OAC rule 3745-77-07(H)(1)(a) to (H)(1)(c) within

the permitted stationary source without obtaining a permit revision, if such change is not a modification under

any provision of Title I of the Act [as defined in OAC rule 3745-77-01(JJ)], and does not result in an exceedance

of the emissions allowed under this permit (whether expressed therein as a rate of emissions or in terms of total

emissions), and the permittee provides the Administrator of the U.S. EPA and the appropriate Ohio EPA District

Office or local air agency with written notification within a minimum of seven days in advance of the proposed

changes, unless the change is associated with, or in response to, emergency conditions. If less than seven days

notice is provided because of a need to respond more quickly to such emergency conditions, the permittee shall

provide notice to the Administrator of the U.S. EPA and the appropriate District Office of the Ohio EPA or local
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 7

air agency as soon as possible after learning of the need to make the change. The notification shall contain the

items required under OAC rule 3745-77-07(H)(2)(d).

(Authority for term: OAC rules 3745-77-07(H)(1) and (2))

15. Emergencies

The permittee shall have an affirmative defense of emergency to an action brought for noncompliance with

technology-based emission limitations if the conditions of OAC rule 3745-77-07(G)(3) are met. This emergency

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

(Authority for term: OAC rule 3745-77-07(G))

16. Off-Permit Changes

The owner or operator of a Title V source may make any change in its operations or emissions at the source that

is not specifically addressed or prohibited in the Title V permit, without obtaining an amendment or modification

of the permit, provided that the following conditions are met:

a. The change does not result in conditions that violate any applicable requirements or that violate any

existing federally enforceable permit term or condition.

b. The permittee provides contemporaneous written notice of the change to the Director and the

Administrator of the U.S. EPA. Such written notice shall describe each such change, the date of such

change, any change in emissions or pollutants emitted, and any federally applicable requirement that

would apply as a result of the change.

c. The change shall not qualify for the permit shield under OAC rule 3745-77-07(F).

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

regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit,

and the emissions resulting from those changes. 

e. The change is not subject to any applicable requirement under Title IV of the Act or is not a modification

under any provision of Title I of the Act.

Paragraph (I) of rule 3745-77-07 of the Administrative Code applies only to modification or amendment of the

permittee's Title V permit. The change made may require a permit to install under Chapter 3745-31 of the

Administrative Code if the change constitutes a modification as defined in that Chapter. Nothing in paragraph (I)

of rule 3745-77-07 of the Administrative Code shall affect any applicable obligation under Chapter 3745-31 of

the Administrative Code.

(Authority for term: OAC rule 3745-77-07(I))

17. Compliance Method Requirements

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 (see 62 Fed. Reg. 8314, Feb. 24, 1997), in the context of any future

proceeding.

(This term is provided for informational purposes only.)

18. Insignificant Activities

Each insignificant activity that has one or more applicable requirements shall comply with those applicable

requirements.

(Authority for term: OAC rule 3745-77-07(A)(1))
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 8

19. Permit to Install Requirement

Prior to the “installation” or “modification” of any “air contaminant source,” as those terms are defined in OAC

rule 3745-31-01, a permit to install must be obtained from the Ohio EPA pursuant to OAC Chapter 3745-31.

(Authority for term: OAC rule 3745-77-07(A)(1))

20. Air Pollution Nuisance

The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in

violation of OAC rule 3745-15-07.

(Authority for term: OAC rule 3745-77-07(A)(1))

21. Permanent Shutdown of an Emissions Unit

The permittee may notify Ohio EPA of any emissions unit that is permanently shut down by submitting a

certification by the responsible official of the date on which the emissions unit was permanently shut down.

Authorization to operate the affected part or activity of the stationary source shall cease upon the date certified by

the responsible official that the emissions unit was permanently shut down.

If an emissions unit is permanently shut down (i.e., that has been physically removed from service or has been

altered in such a way that it can no longer operate without a subsequent “modification” or “installation” as

defined in OAC Chapter 3745-31 and therefore ceases to meet the definition of an “emissions unit” as defined in

OAC rule 3745-77-01(O)), rendering existing permit terms and conditions irrelevant, the permittee shall not be

required, after the date of the certification and submission to Ohio EPA, to meet any monitoring, record keeping,

reporting, or testing requirements, applicable to that emissions unit, except for any residual requirements, such as

the quarterly deviation reports, semi-annual deviation reports and annual compliance certification covering the

period during which the emissions unit last operated. All records relating to the shutdown emissions unit,

generated while the emissions unit was in operation, must be maintained in accordance with law. 

No emissions unit certified by the responsible official as being permanently shut down may resume operation

without first applying for and obtaining a permit to install pursuant to OAC Chapter 3745-31.
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 9

B. State Only Enforceable Section

1. Reporting Requirements Related to Monitoring and Record Keeping Requirements

The permittee shall submit required reports in the following manner:

a. Reports of any required monitoring and/or record keeping information shall be submitted to the

appropriate Ohio EPA District Office or local air agency.

b. Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterly

written reports of (i) any deviations (excursions) from emission limitations, operational restrictions, and

control device operating parameter limitations that have been detected by the testing, monitoring, and

record keeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii)

any corrective actions or preventive measures which have been or will be taken, shall be submitted to the

appropriate Ohio EPA District Office or local air agency. In identifying each deviation, the permittee

shall specify the applicable requirement for which the deviation occurred, describe each deviation, and

provide the magnitude and duration of each deviation. If no deviations occurred during a calendar

quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that

quarter. The reports shall be submitted quarterly, i.e., by January 31, April 30, July 31, and October 31

of each year and shall cover the previous calendar quarters. (These quarterly reports shall exclude

deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)

2. Records Retention Requirements

Each record of any monitoring data, testing data, and support information required pursuant to this permit shall

be retained for a period of five years from the date the record was created. Support information shall include,

but not be limited to, all calibration and maintenance records and all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in

computerized form.

3. Inspections and Information Requests

The Director of the Ohio EPA, or an authorized representative of the Director, may, subject to the safety

requirements of the permittee and without undue delay, enter upon the premises of this source at any reasonable

time for purposes of making inspections, conducting tests, examining records or reports pertaining to any

emission of air contaminants, and determining compliance with any applicable State air pollution laws and

regulations and the terms and conditions of this permit. The permittee shall furnish to the Director of the Ohio

EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable

time, any information that may be requested to determine whether cause exists for modifying, reopening or

revoking this permit or to determine compliance with this permit. Upon verbal or written request, the permittee

shall also furnish to the Director of the Ohio EPA, or an authorized representative of the Director, copies of

records required to be kept by this permit.

4. Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph

(A) of OAC rule 3745-15-06. The malfunction of any emissions units or any associated air pollution control

system(s) shall be reported to the appropriate Ohio EPA District Office or local air agency in accordance with

paragraph (B) of OAC rule 3745-15-06. Except as provided in that rule, any scheduled maintenance or

malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied

by the shutdown of the emissions unit(s) that is (are) served by such control system(s).

5. Permit Transfers

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The appropriate Ohio

EPA District Office or local air agency must be notified in writing of any transfer of this permit.
Facility Name: Ormet Primary Aluminum Corp.

Facility ID: 06-56-00-0001

Final Title V Permit - General Terms and Conditions Page 10

6. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission

Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations (See Section A

of This Permit)

If no emission limitation (or control requirement), operational restriction and/or control device parameter

limitation deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which

states that no deviations occurred during that quarter. The reports shall be submitted by January 31, April 30,

July 31, and October 31 of each year; and each report shall cover the previous calendar quarter.

The permittee is not required to submit a quarterly report which states that no deviations occurred during that

quarter for the following situations:

a. where an emissions unit has deviation reporting requirements for a specific emission limitation,

operational restriction, or control device parameter limitation that override the deviation reporting

requirements specified in General Term and Condition A.1.c.ii;

b. where an uncontrolled emissions unit has no monitoring, record keeping, or reporting requirements and

the emissions unit’s applicable emission limitations are established at the potentials to emit; and

c. where the company’s responsible official has certified that an emissions unit has been permanently shut

down.
1 1

Facility Name: Ormet Primary Aluminum Corp. 

Facility ID: 06-56-00-0001

Part II - Specific Facility Terms and Conditions

A. State and Federally Enforcable Section

1. The following insignificant emissions units are located at this facility:

P234 - superstructure cleaning facility (Permit to Install # 17-660);

P237 - aluminum flouride tank (Permit to Install # 17-1498);

Z002 - 1,500,000-gallon fuel oil tank;

Z003 - 500,000-gallon fuel oil tank;

P083 - anode mixer L-640-1;

P084 - anode mixer L-640-2;

P085 - anode mixer L-640-3;

P086 - anode mixer L-640-4;

P087 - anode mixer L-640-5;

P088 - anode mixer L-640-6;

P089 - anode mixer L-640-7;

P090 - anode mixer L-640-8;

P091 - anode mixer L-640-9;

P092 - anode mixer L-640-10;

P093 - anode mixer L-640-11;

Z001 - anode pressing and handling;

Z009 - billet saws (3);

Z018 - chip compactor;

Z019 - pot bakeout unit;

Z020 - 100,000-gallon diesel tank;

Z021 - crucible heaters (2);

Z022 - sand blaster;

Z023 - trackhopper;

Z024 - bath & alumina storage pile;

Z025 - pot pad cutting; and

Z026 - casthouse hot caps (3).

Each insignificant emissions unit at this facility must comply with all applicable State and federal regulations, as

well as any emission limitations and/or control requirements contained within the identified permit to install for

the emissions unit. Insignificant emissions units listed above that are not subject to specific permit to install

requirements are subject to one or more applicable requirements contained in the SIP-approved versions of OAC

Chapters 3745-17, 3745-18, and 3745-21.

B. State Only Enforceable Section

1. The following insignificant emissions units located at this facility are exempt from permit requirements because

they are not subject to any applicable requirements or because they meet the "de minimis" criteria established

in OAC rule 3745-15-05:

B001 - natural gas-fired heater to heat pitch;

B002 - natural gas-fired heater to heat pitch;

P018 - Jeffrey dryer;

Z004 - pitch handling;

Z005 - Spenser 101 system;

Z010 - parts washer tanks (17);

Z011 - GW treatment plant bulk storage tanks;

Z012 - lab hoods; and

Z013 - gasoline dispensing facility.

Specific Facility Terms and Conditions

Title V Final Permit

Page 11
3

1

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-291-1 (B004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

1. The permittee shall burn only natural gas and/or #2 fuel oil in this emissions unit.

The quality of the oil burned in this emissions unit shall meet a sulfur content that is sufficient to comply with the

allowable sulfur dioxide emission limitation specified in section A.I.1 above.

2.

III. Monitoring and/or Record Keeping Requirements

For each day during which the permittee burns a fuel other than natural gas and/or #2 fuel oil, the permittee shall

maintain a record of the type and quantity of fuel burned in this emissions unit.

1.

Gas or Oil Field Boiler-36.4 MMBTU/hr.-291-1 (B004)

Boiler-36.4 MMBTU/hr.

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

36.4 million Btu/hr natural gas and/or

#2 fuel oil-fired boiler

OAC rule 3745-17-10(B)(1) Particulate emissions shall not

exceed 0.020 pound per million Btu

of actual heat input.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-18-06(D) When burning #2 fuel oil, sulfur

dioxide emissions shall not exceed

1.6 pounds per million Btu of actual

heat input.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 12
3

2

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-291-1 (B004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the oil burned in this emissions unit in accordance with either Alternative

1 or Alternative 2 described below.

a. Alternative 1:

For each shipment of oil received for burning in this emissions unit, the permittee shall collect or require the oil

supplier to collect a representative grab sample of oil and maintain records of the total quantity of oil received,

the permittee's or oil supplier's analyses for sulfur content and heat content, and the calculated sulfur dioxide

emission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shall be calculated in accordance with the

formula specified in OAC rule 3745-18-04(F).) A shipment may be comprised of multiple tank truck loads from

the same supplier's batch, or may be represented by single or multiple pipeline deliveries from the same

supplier's batch, and the quality of the oil for those loads or pipeline deliveries may be represented by a single

batch analysis from the supplier.

b. Alternative 2:

The permittee shall collect a representative grab sample of oil that is burned in this emissions unit for each day

when the emissions unit is in operation. If additional fuel oil is added to the tank serving this emissions unit on a

day when the emissions unit is in operation, the permittee shall collect a sufficient number of grab samples to

develop a composite sample representative of the fuel oil burned in this emissions unit. A representative grab

sample of oil does not need to be collected on days when this emissions unit is only operated for the purpose of

"test-firing." The permittee shall maintain records of the total quantity of oil burned each day, except for the

purpose of test-firing, the permittee's analyses for sulfur content and heat content, and the calculated sulfur

dioxide emission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shall be calculated in accordance with

the formula specified in OAC rule 3745-18-04(F).)

2.

The permittee shall perform or require the supplier to perform the analyses for sulfur content and heat content in

accordance with 40 CFR Part 60, Appendix A, Method 19, or the appropriate ASTM methods (such as, ASTM

methods D240 and D4294), or equivalent methods as approved by the Director.

3.

IV. Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas

and/or #2 fuel oil was burned in this emissions unit. Each report shall be submitted within 30 days after the

deviation occurs.

1.

The permittee shall notify the Ohio EPA, Southeast District Office in writing of any record which shows a

deviation of the allowable sulfur dioxide emission limitation based upon the calculated sulfur dioxide emission

rates from section A.III above. The notification shall include a copy of such record and shall be sent to the Ohio

EPA, Southeast District Office within 45 days after the deviation occurs.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 13
3

3

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-291-1 (B004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

0.020 pound of particulates per million Btu of actual heat input

Applicable Compliance Method:

When burning natural gas, compliance may be demonstrated by dividing the applicable AP-42, 5th Edition

(supplement B) emission factor for filterable particulate matter from table 1.4-1 (for units between 10 and 100

million Btu/hr) by the assumed heat content of natural gas (1000 Btu/cubic foot):

(1.9 lbs of particulates/million cubic feet) X (cubic foot/1000 Btu) = 0.0019 lb of particulates/million Btu

When burning #2 fuel oil, compliance may be demonstrated by multiplying an emission factor of 2.0 lbs of

particulate per 1000 gallons of oil combusted by the heat content of the oil as determined through the fuel

analyses required in section A.III.1 above. This emission factor is specified in USEPA reference document

AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.3, Table 1.3-2.

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.a

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance shall be demonstrated through visible particulate emission observations performed in accordance

with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1). No

visible emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may

be requested pursuant to OAC rule 3745-15-04(A).

1.b

Emission Limitation:

1.6 lbs/million Btu of sulfur dioxide when burning #2 fuel oil

Applicable Compliance Method:

Compliance with the allowable sulfur dioxide emission limitation may be demonstrated by documenting that the

sulfur content of each shipment of oil received or each daily sample collected during a calendar month meets the

limitation.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 14
1

1

Gas or Oil Field Boiler-36.4 MMBTU/hr.-291-1 (B004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 15
3

1

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-292-2 (B005)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

1. The permittee shall burn only natural gas and/or #2 fuel oil in this emissions unit.

The quality of the oil burned in this emissions unit shall meet a sulfur content that is sufficient to comply with the

allowable sulfur dioxide emission limitation specified in section A.I.1 above.

2.

III. Monitoring and/or Record Keeping Requirements

For each day during which the permittee burns a fuel other than natural gas and/or #2 fuel oil, the permittee shall

maintain a record of the type and quantity of fuel burned in this emissions unit.

1.

Gas or Oil Field Boiler-36.4 MMBTU/hr.-292-2 (B005)

Boiler-36.4 MMBTU/hr.-292-2

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

36.4 million Btu/hr natural gas and/or

#2 fuel oil-fired boiler

OAC rule 3745-17-10(B)(1) Particulate emissions shall not

exceed 0.020 pound per million Btu

of actual heat input.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-18-06(D) When burning #2 fuel oil, sulfur

dioxide emissions shall not exceed

1.6 pounds per million Btu of actual

heat input.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 16
3

2

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-292-2 (B005)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the oil burned in this emissions unit in accordance with either Alternative

1 or Alternative 2 described below.

a. Alternative 1:

For each shipment of oil received for burning in this emissions unit, the permittee shall collect or require the oil

supplier to collect a representative grab sample of oil and maintain records of the total quantity of oil received,

the permittee's or oil supplier's analyses for sulfur content and heat content, and the calculated sulfur dioxide

emission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shall be calculated in accordance with the

formula specified in OAC rule 3745-18-04(F).) A shipment may be comprised of multiple tank truck loads from

the same supplier's batch, or may be represented by single or multiple pipeline deliveries from the same

supplier's batch, and the quality of the oil for those loads or pipeline deliveries may be represented by a single

batch analysis from the supplier.

b. Alternative 2:

The permittee shall collect a representative grab sample of oil that is burned in this emissions unit for each day

when the emissions unit is in operation. If additional fuel oil is added to the tank serving this emissions unit on a

day when the emissions unit is in operation, the permittee shall collect a sufficient number of grab samples to

develop a composite sample representative of the fuel oil burned in this emissions unit. A representative grab

sample of oil does not need to be collected on days when this emissions unit is only operated for the purpose of

"test-firing." The permittee shall maintain records of the total quantity of oil burned each day, except for the

purpose of test-firing, the permittee's analyses for sulfur content and heat content, and the calculated sulfur

dioxide emission rate (in lbs/mmBtu). (The sulfur dioxide emission rate shall be calculated in accordance with

the formula specified in OAC rule 3745-18-04(F).)

2.

The permittee shall perform or require the supplier to perform the analyses for sulfur content and heat content in

accordance with 40 CFR Part 60, Appendix A, Method 19, or the appropriate ASTM methods (such as, ASTM

methods D240 and D4294), or equivalent methods as approved by the Director.

3.

IV. Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas

and/or #2 fuel oil was burned in this emissions unit. Each report shall be submitted within 30 days after the

deviation occurs.

1.

The permittee shall notify the Ohio EPA, Southeast District Office in writing of any record which shows a

deviation of the allowable sulfur dioxide emission limitation based upon the calculated sulfur dioxide emission

rates from section A.III above. The notification shall include a copy of such record and shall be sent to the Ohio

EPA, Southeast District Office within 45 days after the deviation occurs.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 17
3

3

Facility Name:

Facility ID:

Emissions Unit: Gas or Oil Field Boiler-36.4 MMBTU/hr.-292-2 (B005)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

0.020 pound of particulates per million Btu of actual heat input

Applicable Compliance Method:

When burning natural gas, compliance may be demonstrated by dividing the applicable AP-42, 5th Edition

(supplement B) emission factor for filterable particulate matter from table 1.4-1 (for units between 10 and 100

million Btu/hr) by the assumed heat content of natural gas (1000 Btu/cubic foot):

(1.9 lbs of particulates/million cubic feet) X (cubic foot/1000 Btu) = 0.0019 lb of particulates/million Btu

When burning #2 fuel oil, compliance may be demonstrated by multiplying an emission factor of 2.0 lbs of

particulate per 1000 gallons of oil combusted by the heat content of the oil as determined through the fuel

analyses required in section A.III.1 above. This emission factor is specified in USEPA reference document

AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, Section 1.3, Table 1.3-2.

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.a

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance shall be demonstrated through visible particulate emission observations performed in accordance

with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1). No

visible emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may

be requested pursuant to OAC rule 3745-15-04(A).

1.b

Emission Limitation:

1.6 lbs/million Btu of sulfur dioxide when burning #2 fuel oil

Applicable Compliance Method:

Compliance with the allowable sulfur dioxide emission limitation may be demonstrated by documenting that the

sulfur content of each shipment of oil received or each daily sample collected during a calendar month meets the

limitation.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 18
1

1

Gas or Oil Field Boiler-36.4 MMBTU/hr.-292-2 (B005)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 19
3

1

Facility Name:

Facility ID:

Emissions Unit: Preheater (Glass Plant) (B006)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

1. The permittee shall burn only natural gas as fuel in this emissions unit.

III. Monitoring and/or Record Keeping Requirements

For each day during which the permittee burns a fuel other than natural gas, the permittee shall maintain a

record of the type and quantity of fuel burned in this emissions unit.

1.

Preheater (Glass Plant) (B006)

Glass Plant Preheater

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

12 million Btu/hr natural gas-fired air

preheater

OAC rule 3745-31-05(A)(3)

(PTI 17-1657)

Particulate emissions shall not

exceed 0.24 pound per hour and 1.05

tons per year.

Nitrogen oxides emissions shall not

exceed 1.68 pounds per hour and

7.36 tons per year.

The requirements of this rule also

include compliance with the

requirements of OAC rules

3745-17-10(B)(1)and 3745-17-07(A).

471868 471868

OAC rule 3745-17-10(B)(1) Particulate emissions from the air

preheater shall not exceed 0.020

pound per million Btu of actual heat

input.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 20
3

2

Facility Name:

Facility ID:

Emissions Unit: Preheater (Glass Plant) (B006)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify each day when a fuel other than natural gas

was burned in this emissions unit. Each report shall be submitted within 30 days after the deviation occurs.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

Particulate emissions from the air preheater shall not exceed 0.020 pound per million Btu of actual heat input.

Applicable Compliance Method:

Compliance may be demonstrated by dividing the applicable emission factor for filterable particulate matter (for

units between 10 and 100 million Btu/hr) from AP-42 table 1.4-2 (7/98) (1.9 lbs/million cubic feet) by the

assumed heat content of natural gas (1000 Btu/cubic foot):

(1.9 lbs of particulates/million cubic feet) / (1000 Btu/cubic foot) = 0.0019 lb of particulates/million Btu

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A). Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

1.a

Emission Limitation:

Particulate emissions shall not exceed 0.24 pound per hour.

Applicable Compliance Method:

Compliance may be demonstrated by dividing the applicable emission factor for filterable particulate matter (for

units between 10 and 100 million Btu/hr) from AP-42 table 1.4-2 (7/98) (1.9 lbs/million cubic feet) by the

assumed heat content of natural gas (1000 Btu/cubic foot), and then multiplying by the rated heat input capacity

of 12 million Btu/hr:

[(1.9 lbs of particulates/million cubic feet) X (12 million Btu/hr)] / 1000 Btu/cubic foot = 0.0228 lbs/hr

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(9). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A). Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

1.b

Emission Limitation:

Particulate emissions shall not exceed 1.05 tons per year.

Applicable Compliance Method:

This emission limitation was established by multiplying the allowable hourly emission limitation of 0.24 pound

per hour by the maximum annual hours of operation, 8760 hours per year, and then dividing by 2000 pounds per

ton. Therefore, provided that the permittee complies with the pound per hour emission limitation, compliance with

the annual emission limitation will also be demonstrated.

1.c

Terms and Conditions for Emissions Units

Title V Final Permit Page 21
3

3

Facility Name:

Facility ID:

Emissions Unit: Preheater (Glass Plant) (B006)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Applicable Compliance Method:

Compliance shall be demonstrated through visible particulate emission observations performed in accordance

with 40 CFR Part 60, Appendix A, Method 9. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.d

Emission Limitation:

Nitrogen oxides emissions shall not exceed 1.68 pounds per hour.

Applicable Compliance Method:

Compliance may be demonstrated by dividing the applicable emission factor for NOx (for units between 10 and

100 million Btu/hr) from AP-42 table 1.4-1 (7/98) (140 lbs/million cubic feet) by the assumed heat content of

natural gas (1000 Btu/cubic foot), and then multiplying by the rated heat input capacity of 12 million Btu/hr:

[(140 lbs of NOx/million cubic feet) X (12 million Btu/hr)] / 1000 Btu/cubic foot = 1.68 lbs/hr

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 4 and Method 7. No emission testing is specifically required to

demonstrate compliance with this limit but, if appropriate, may be requested pursuant to OAC rule

3745-15-04(A). Alternative U.S. EPA-approved test methods may be used with prior approval from the Ohio

EPA.

1.e

Emission Limitation:

Nitrogen oxides emissions shall not exceed 7.36 tons per year.

Applicable Compliance Method:

This emission limitation was established by multiplying the allowable hourly emission limitation of 1.68 pounds

per hour by the maximum annual hours of operation, 8760 hours per year, and then dividing by 2000 pounds per

ton. Therefore, provided that the permittee complies with the pound per hour emission limitation, compliance with

the annual emission limitation will also be demonstrated.

1.f

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 22
1

1

Preheater (Glass Plant) (B006)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 23
3

1

Facility Name:

Facility ID:

Emissions Unit: Roads and Parking (F002)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The paved roadways and parking areas that are covered by this permit and subject to the requirements of

OAC rules 3745-17-07 and 3745-17-08 are listed below:

paved roadways:

entrance road

main road

carbon plant road

casting road

north potroom road

south potroom road

west road

DSS/ore dock road

paved parking area:

entrance parking area

2.b The permittee shall employ reasonably available control measures on all paved roadways and parking areas

for the purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance

with the permittee's permit application, the permittee has committed to treat the paved roadways and parking

areas by sweeping and vacuuming at sufficient treatment frequencies to ensure compliance. Nothing in this

paragraph shall prohibit the permittee from employing other equally effective control measures to ensure

compliance.

Roads and Parking (F002)

Roads and Parking

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

paved roadways and parking areas OAC rule 3745-17-07(B)(4) no visible particulate emissions

except for 6 minutes during any

60-minute period

471868 471868

OAC rule 3745-17-08(B), (B)(8),

(B)(9)

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust

See sections A.I.2.b through A.I.2.f.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 24
3

2

Facility Name:

Facility ID:

Emissions Unit: Roads and Parking (F002)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.c The needed frequencies of implementation of the control measures shall be determined by the permittee's

inspections pursuant to the monitoring section of this permit. Implementation of the control measures shall

not be necessary for a paved roadway or parking area that is covered with snow and/or ice or if precipitation

has occurred that is sufficient for that day to ensure compliance with the above-mentioned applicable

requirements. Implementation of any control measure may be suspended if unsafe or hazardous driving

conditions would be created by its use.

2.d The permittee shall promptly remove, in such a manner as to minimize or prevent resuspension, earth and/or

other material from paved streets onto which such material has been deposited by trucking or earth moving

equipment or erosion by water or other means.

2.e Open-bodied vehicles transporting materials likely to become airborne shall have such materials covered at

all times if the control measure is necessary for the materials being transported.

2.f Implementation of the above-mentioned control measures in accordance with the terms and conditions of this

permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

Except as otherwise provided in this section, the permittee shall perform inspections of each of the paved

roadway segments and parking areas in accordance with the following frequencies:

paved roadways minimum inspection frequency

all weekly

paved parking areas minimum inspection frequency

all weekly

1.

The purpose of the inspections is to determine the need for implementing the above-mentioned control

measures. The inspections shall be performed during representative, normal traffic conditions. No inspection

shall be necessary for a roadway or parking area that is covered with snow and/or ice or if precipitation has

occurred that is sufficient for that day to ensure compliance with the above-mentioned applicable requirements.

Any required inspection that is not performed due to any of the above-identified events shall be performed as

soon as such event(s) has (have) ended, except if the next required inspection is within one week.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 25
3

3

Facility Name:

Facility ID:

Emissions Unit: Roads and Parking (F002)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information:

a. the date and reason any required inspection was not performed, including those inspections that were not

performed due to snow and/or ice cover or precipitation;

b. the date of each inspection where it was determined by the permittee that it was necessary to implement the

control measures;

c. the dates the control measures were implemented; and

d. on a calendar quarter basis, the total number of days the control measures were implemented and the total

number of days where snow and/or ice cover or precipitation were sufficient to not require the control measures.

The information required in A.III.4.d shall be updated on a calendar quarter basis within 30 days after the end of

each calendar quarter.

3.

IV. Reporting Requirements

The permittee shall submit deviation reports that identify any of the following occurrences:

a. each day during which an inspection was not performed by the required frequency, excluding an inspection

which was not performed due to an exemption for snow and/or ice cover or precipitation; and

b. each instance when a control measure, that was to be implemented as a result of an inspection, was not

implemented.

1.

The deviation reports shall be submitted in accordance with the reporting requirements specified in Part I -

General Term and Condition A.1.c of this permit.

2.

V. Testing Requirements

Compliance with the emission limitation for the paved roadways and parking areas identified above shall be

determined in accordance with Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60

("Standards of Performance for New Stationary Sources," as such Appendix existed on July 1, 1996, and the

modifications listed in paragraphs (B)(4)(a) through (B)(4)(d) of OAC rule 3745-17-03.

1.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 26
1

1

Roads and Parking (F002)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 27
2

1

Facility Name:

Facility ID:

Emissions Unit: Dross Handling (F003)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The material handling operations that are covered by this permit and subject to the requirements of OAC

rules 3745-17-07 and 3745-17-08 are listed below:

aluminum dross handling (cooling, dumping, storage, and load out)

2.b The permittee shall employ reasonably available control measures for the above-identified material handling

operations for the purpose of ensuring compliance with the above-mentioned applicable requirements. In

accordance with the permittee's permit application, the permittee has committed to perform the following

control measures to ensure compliance:

Material Handling Operations

aluminum dross handling

Control Measures

i. Maintain the aluminum dross within a 3-sided enclosure to keep it dry.

ii. Load out only cool, dry dross within the 3-sided enclosure.

iii. Minimize the drop height and tarp all transporting trucks.

Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure

compliance.

Dross Handling (F003)

Dross Handling 

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

aluminum dross handling (cooling,

dumping, storage, and load out)

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B) reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust

See sections A.I.2.b and A.I.2.c.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 28
2

2

Facility Name:

Facility ID:

Emissions Unit: Dross Handling (F003)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.c Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from this emissions unit. The presence or absence

of any visible emissions shall be noted in an operations log. If visible emissions are observed, the permittee

shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any fugitive visible

particulate emissions were observed from this emissions unit and (b) describe any corrective actions taken to

minimize or eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

V. Testing Requirements

Compliance with the visible emission limitation for the material handling operation(s) identified above shall be

determined in accordance with Test Method 9 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60

("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996, and the

modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule 3745-17-03.

1.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 29
1

1

Dross Handling (F003)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 30
3

1

Facility Name:

Facility ID:

Emissions Unit: Crushed Spent Anode Handling & Barge Loading (F004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The material handling operation(s) that are covered by this permit and subject to the above-mentioned

requirements are listed below:

Truck Loading

Truck Dumping

Crane Clamshell Pickup

Crane Clamshell Barge Loading

Crushed Spent Anode Handling & Barge Loading (F004)

Crushed Spent Anode Handling and Loading

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

crushed spent anode loading

operation

OAC rule 3745-31-05(A)(3)

(PTI #06-06863)

Particulate emissions shall not

exceed 6.0 tons per year.

The requirements of this rule also

include compliance with the

requirements of OAC rule

3745-17-08(B).

471868 471868

OAC rule 3745-17-08 (B) Best available control measures that

are sufficient to minimize or eliminate

visible emissions of fugitive dust (see

Sections A.I.2.b through A.I.2.d).

471868 471868

OAC rule 3745-17-07 (B)(1) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 31
3

2

Facility Name:

Facility ID:

Emissions Unit: Crushed Spent Anode Handling & Barge Loading (F004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b The permittee shall employ best available control measures for the above-identified material handling

operation(s) for the purpose of ensuring compliance with the above-mentioned applicable requirements. In

accordance with the permittee's permit application, the permittee has committed to perform the following

control measure(s) to ensure compliance:

Truck Loading by Front-End Loader: All trucks shall be loaded while inside a total enclosure. Minimize drop

height distance from front-end loader to truck bed.

Truck Loading by Conveyor: Maintain moisture content sufficient to minimize or eliminate visible emissions.

Truck Dumping: Maintain moisture content sufficient to minimize or eliminate visible emissions. All dumping

shall occur within a 3-sided enclosure.

Crane Clamshell Pickup: Maintain moisture content sufficient to minimize or eliminate visible emissions.

Crane Clamshell Barge Loading: Maintain moisture content sufficient to minimize or eliminate visible

emissions.

Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure

compliance.

2.c For each material handling operation that is not adequately enclosed, the above-identified control measure(s)

shall be implemented if the permittee determines, as a result of the inspection conducted pursuant to the

monitoring section of this permit, that the control measure(s) is (are) necessary to ensure compliance with

the above-mentioned applicable requirements. Any required implementation of the control measure(s) shall

continue during the operation of the material handling operation(s) until further observation confirms that use

of the control measure(s) is unnecessary.

2.d Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rules 3745-17-08 and 3745-31-05.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

Except as otherwise provided in this section, for material handling operations that are not adequately enclosed,

the permittee shall perform inspections of such operations in accordance with the following minimum frequencies:

Material handling operation(s) minimum inspection frequency

all daily

1.

2. The above-mentioned inspections shall be performed during representative, normal operating conditions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 32
3

3

Facility Name:

Facility ID:

Emissions Unit: Crushed Spent Anode Handling & Barge Loading (F004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information:

a. the date and reason any required inspection was not performed;

b. the date of each inspection where it was determined by the permittee that it was necessary to implement the

control measure(s);

c. the dates the control measure(s) was (were) implemented; and

d. on a calendar quarter basis, the total number of days the control measure(s) was (were) implemented.

The information in A.III.4.d shall be kept separately for each material handling operation identified above, and

shall be updated on a calendar quarter basis within 30 days after the end of each calendar quarter.

3.

IV. Reporting Requirements

The permittee shall submit deviation reports that identify any of the following occurrences:

a. each day during which an inspection was not performed by the required frequency; and

b. each instance when a control measure, that was to be performed as a result of an inspection, was not

implemented.

1.

The deviation reports shall be submitted in accordance with the reporting requirements of the General Terms and

Conditions of this permit.

2.

V. Testing Requirements

Compliance with the emission limitation(s) in section A.1. of these terms and conditions shall be determined in

accordance with the following method(s):

1.

Emission Limitation:

Best available control measures that are sufficient to minimize or eliminate visible emissions of fugitive dust.

Compliance Method:

Compliance with the visible emission limitation for the material handling operation(s) identified above shall be

determined in accordance with Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60

("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.a

Emission Limitation:

Particulate emissions shall not exceed 6.0 tons per year.

Compliance Method:

Compliance with the 6.0 ton per year limit shall be determined by using the emission factor calculation for

material handling from AP-42 Section 13.2.4(1/95) and the tons per year throughput of spent anodes.

1.b

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 33
1

1

Crushed Spent Anode Handling & Barge Loading (F004)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 34
3

1

Facility Name:

Facility ID:

Emissions Unit: Rod Cleaner (P022)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures(RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 6.85 pound of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Rod Cleaner (P022)

Rod Cleaner

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

rod cleaner vented to a baghouse OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

6.85 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 35
3

2

Facility Name:

Facility ID:

Emissions Unit: Rod Cleaner (P022)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.). The presence or absence of any visible emissions shall be noted in an operations

log. If visible emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

3. The above-mentioned weekly checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit, and (b) describe any

corrective actions taken to minimize or eliminate the visible fugitive particulate emissions. These reports shall be

submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31

of each year and shall cover the previous 6-month period.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 36
3

3

Facility Name:

Facility ID:

Emissions Unit: Rod Cleaner (P022)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.),

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 6.85 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 37
1

1

Rod Cleaner (P022)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 38
3

1

Facility Name:

Facility ID:

Emissions Unit: Butt/Coke Class. K-640-37 (P036)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 22.4 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Butt/Coke Class. K-640-37 (P036)

Butt/Coke Class. K-640-37

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

butt/coke classification system

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

22.4 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 39
3

2

Facility Name:

Facility ID:

Emissions Unit: Butt/Coke Class. K-640-37 (P036)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 40
3

3

Facility Name:

Facility ID:

Emissions Unit: Butt/Coke Class. K-640-37 (P036)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 22.4 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 41
1

1

Butt/Coke Class. K-640-37 (P036)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 42
3

1

Facility Name:

Facility ID:

Emissions Unit: 1-640-339 North System (P072)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 28.0 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

1-640-339 North System (P072)

Belt Elevator

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

1-640-339 north system operation

vented to two baghouses

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

28.0 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 43
3

2

Facility Name:

Facility ID:

Emissions Unit: 1-640-339 North System (P072)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 44
3

3

Facility Name:

Facility ID:

Emissions Unit: 1-640-339 North System (P072)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 28.0 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 45
1

1

1-640-339 North System (P072)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 46
25

1

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Thixo Casting (P080)

Billet Casting facility

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

thixo casting OAC rule 3745-31-05(A)(3)

(PTI 17-1606) issued 4/8/98

Emissions from the melt stack shall

not exceed the following:

0.09 pound/hour and 0.39 tpy of

particulate emissions

0.18 pound/hour and 0.08 tpy of

sulfur dioxide

0.84 pound/hour and 0.37 tpy of

volatile organic compounds

1.05 pounds/hour and 4.60 tpy of

carbon monoxide

1.80 pounds/hour and 7.88 tpy of

nitrogen oxides

471868 471868

Emissions from the hold stack shall

not exceed the following:

1.836 pounds/hour and 8.04 tpy of

particulate emissions

0.007 pound/hour and 0.032 tpy of

sulfur dioxide

0.034 pound/hour and 0.15 tpy of

volatile organic compounds

0.42 pound/hour and 1.84 tpy of

carbon monoxide

0.72 pound/hour and 3.15 tpy of

nitrogen oxides

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 47
25

2

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a The maximum hourly aluminum production rate for this emissions unit shall not exceed 15,000 pounds per

hour.

2.b The maximum chlorine consumption rate shall not exceed 1.63 cubic feet of chlorine per ton of aluminum

produced.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Emissions from casting activities

shall not exceed the following:

0.15 pound/hour and 0.66 tpy of

sulfur dioxide

0.08 pound/hour and 0.35 tpy of

nitrogen oxides

1.05 pounds/hour and 4.60 tpy of

volatile organic compounds

Visible particulate emissions from

the melt stack, hold stack, and

casting activities shall not exceed

5% opacity as a 6-minute average.

471868 471868

OAC rule 3745-17-07(A) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

40 CFR Part 63.1505

(Subpart RRR)

471868 471868 See A.I.2.c through A.I.2.e below.

Terms and Conditions for Emissions Units

Title V Final Permit Page 48
25

3

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.c [40 CFR 63.1505(i)]

The owner or operator of a group 1 furnace must use the limits in this paragraph to determine the emission

standards for a SAPU.

0.20 kg of PM per Mg (0.40 lb of PM per ton) of feed/charge from a group 1 furnace, that is not a

melting/holding furnace processing only clean charge, at a secondary aluminum production facility that is a

major source;

0.40 kg of PM per Mg (0.80 lb of PM per ton) of feed/charge from a group 1 melting/holding furnace

processing only clean charge at a secondary aluminum production facility that is a major source;

15 microgram of D/F TEQ per Mg (.00021gr of D/F TEQ per ton) of feed/charge from a group 1 furnace at a

secondary aluminum production facility that is a major or area source. This limit does not apply if the furnace

processes only clean charge; and

0.20 kg of HCl per Mg (0.40 lb of HCl per ton) of feed/charge or, if the furnace is equipped with an add-on air

pollution control device, 10 percent of the uncontrolled HCl emissions, by weight, for a group 1 furnace at a

secondary aluminum production facility that is a major source.

The owner or operator may determine the emission standards for a SAPU by applying the group 1 furnace

limits on the basis of the aluminum production weight in each group 1 furnace, rather than on the basis of

feed/charge.

2.d [40 CFR 63.1505(j)]

Except as provided in paragraph (j)(3) of 63.1505 for an in-line fluxer using no reactive flux material, the owner

or operator of an in-line fluxer must use the limits in this paragraph to determine the emission standards for a

SAPU.

0.02 kg of HCl per Mg (0.04 lb of HCl per ton) of feed/charge; and

0.005 kg of PM per Mg (0.01 lb of PM per ton) of feed/charge.

The owner or operator may determine the emission standards for a SAPU by applying the in-line fluxer limits

on the basis of the aluminum production weight in each in-line fluxer, rather than on the basis of feed/charge.

2.e [40 CFR 63.1505(k)(1) through (4)]

On and after the date of approval of the operation, maintenance and monitoring (OM&M) plan, the owner or

operator must comply with the emission limits calculated using the equations for PM and HCl in paragraphs

(k)(1) and (k)(2) of 63.1505 for each secondary aluminum processing unit at a secondary aluminum

production facility that is a major source. The owner or operator must comply with the emission limit

calculated using the equation for D/F in paragraph (k)(3) of 63.1505 for each secondary aluminum processing

unit at a secondary aluminum production facility that is a major or area source.

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of PM in excess of:

LcPM = {sum from {i=1} to n (LtiPM times Tti)} over {sum from {i=1} to n (Tti)}

Where,

LtiPM = The PM emission limit for individual emission unit i in paragraph (i)(1) and (2) of 63.1505 for a group

1 furnace or in paragraph (j)(2) of 63.1505 for an in-line fluxer;

Tti = The feed/charge rate for individual emission unit I; and

LcPM = The PM emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the PM limit.

Terms and Conditions for Emissions Units

Title V Final Permit Page 49
25

4

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of HCl in excess of:

LcHCl = {sum from {i=1} to n (LtiHCl times Tti)} over {sum from {i=1} to n ( Tti)}

Where,

LtiHCl = The HCl emission limit for individual emission unit i in paragraph (i)(4) of 63.1505 for a group 1

furnace or in paragraph (j)(1) of 63.1505 for an in-line fluxer; and

LcHCl = The HCl emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the HCl limit.

The owner or operator of a SAPU at a secondary aluminum production facility that is a major source may

demonstrate compliance with the emission limits of paragraphs (k)(1) through (3) of 63.1505 by

demonstrating that each emission unit within the SAPU is in compliance with the applicable emission limits

of paragraphs (i) and (j) of 63.1505.

II. Operational Restrictions

[40 CFR 63.1506(a)(1) and (2)]

On and after the date on which the initial performance test is conducted or required to be conducted, whichever

date is earlier, the owner or operator must operate all new and existing affected sources and control equipment

according to the requirements in this section.

The completion of the initial performance tests for SAPUs shall be considered to be the date of approval of the

OM&M plan by the permitting authority.

1.

[40 CFR 63.1506(b)(1) and (2)]

The owner or operator must provide and maintain easily visible labels posted at each group 1 furnace, group 2

furnace, in-line fluxer and scrap dryer/delacquering kiln/decoating kiln that identifies the applicable emission

limits and means of compliance, including:

The type of affected source or emission unit (e.g., scrap dryer/delacquering kiln/decoating kiln, group 1 furnace,

group 2 furnace, in-line fluxer).

The applicable operational standard(s) and control method(s) (work practice or control device). This includes, but

is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials

and addition practices, and the applicable operating parameter ranges and requirements as incorporated in the

OM&M plan.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 50
25

5

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.1506(d)(1) through (3)]

The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of

feed/charge must:

Except as provided in paragraph (d)(3) of 63.1506, install and operate a device that measures and records or

otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the

performance test; and

Operate each weight measurement system or other weight determination procedure in accordance with the

OM&M plan.

The owner or operator may chose to measure and record aluminum production weight from an affected source or

emission unit rather than feed/charge weight to an affected source or emission unit, provided that:

(i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission

units within a SAPU; and

(ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum

production weight rather than feed/charge weight.

3.

[40 CFR 63.1506(n)(1) through (3)]

The owner or operator of a group 1 furnace (including a group 1 furnace that is part of a secondary aluminum

processing unit) without add-on air pollution control devices must:

Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the

performance test at or below the average rate established during the performance test.

Operate each furnace in accordance with the work practice/pollution prevention measures documented in the

OM&M plan and within the parameter values or ranges established in the OM&M plan.

Operate each group 1 melting/holding furnace subject to the emission standards in 63.1505(i)(2) using only clean

charge as the feedstock.

4.

[40 CFR 63.1506(p)]

When a process parameter or add-on air pollution control device operating parameter deviates from the value or

range established during the performance test and incorporated in the OM&M plan, the owner or operator must

initiate corrective action. Corrective action must restore operation of the affected source or emission unit

(including the process or control device) to its normal or usual mode of operation as expeditiously as practicable

in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must

include follow-up actions necessary to return the process or control device parameter level(s) to the value or

range of values established during the performance test and steps to prevent the likely recurrence of the cause of

a deviation.

5.

III. Monitoring and/or Record Keeping Requirements

The permittee shall maintain daily records of the following information for this emissions unit:

a. the tons of aluminum produced;

b. the hours of operation;

c. the total cubic feet of chlorine employed; and

d. the average daily cubic feet of chlorine per ton of aluminum employed.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 51
25

6

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(a)]

On and after the date the initial performance test is completed or required to be completed, whichever date is

earlier, the owner or operator of a new or existing affected source or emission unit must monitor all control

equipment and processes according to the requirements in this section. Monitoring requirements for each type

of affected source and emission unit are summarized in Table 3 to Subpart RRR.

2.

[40 CFR 63.1510(b)(1) through (8)]

The owner or operator must prepare and implement for each new or existing affected source and emission unit, a

written operation, maintenance, and monitoring (OM&M) plan. The owner or operator must submit the plan to

the applicable permitting authority for review and approval as part of the application for a part 70 or part 71 permit.

Any subsequent changes to the plan must be submitted to the applicable permitting authority for review and

approval. Pending approval by the applicable permitting authority of an initial or amended plan, the owner or

operator must comply with the provisions of the submitted plan. Each plan must contain the following

information:

Process and control device parameters to be monitored to determine compliance, along with established

operating levels or ranges, as applicable, for each process and control device.

A monitoring schedule for each affected source and emission unit.

Procedures for the proper operation and maintenance of each process unit and add-on control device used to

meet the applicable emission limits or standards in 63.1505.

3.

Procedures for the proper operation and maintenance of monitoring devices or systems used to determine

compliance, including:

(i) Calibration and certification of accuracy of each monitoring device, at least once every 6 months, according to

the manufacturer's instructions; and

(ii) Procedures for the quality control and quality assurance of continuous emission or opacity monitoring

systems as required by the general provisions in subpart A of this part.

Procedures for monitoring process and control device parameters, including procedures for annual inspections of

afterburners, and if applicable, the procedure to be used for determining charge/feed (or throughput) weight if a

measurement device is not used.

Corrective actions to be taken when process or operating parameters or add-on control device parameters

deviate from the value or range established in paragraph (b)(1) of 63.1510, including:

(i) Procedures to determine and record the cause of an deviation or excursion, and the time the deviation or

excursion began and ended; and

(ii) Procedures for recording the corrective action taken, the time corrective action was initiated, and the

time/date corrective action was completed.

A maintenance schedule for each process and control device that is consistent with the manufacturer's

instructions and recommendations for routine and long-term maintenance.

Documentation of the work practice and pollution prevention measures used to achieve compliance with the

applicable emission limits and a site-specific monitoring plan as required in paragraph (o) of 63.1510 for each

group 1 furnace not equipped with an add-on air pollution control device.

[40 CFR 63.1510(c)]

The owner or operator must inspect the labels for each group 1 furnace, group 2 furnace, in-line fluxer and scrap

dryer/delacquering kiln/decoating kiln at least once per calendar month to confirm that posted labels as required

by the operational standard in 63.1506(b) are intact and legible.

4.

Terms and Conditions for Emissions Units

Title V Final Permit Page 52
25

7

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(e)(1) and (2)]

The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or

g/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the

total weight of feed/charge to, or the aluminum production from, the affected source or emission unit over the

same operating cycle or time period used in the performance test. Feed/charge or aluminum production within

SAPUs must be measured and recorded on an emission unit-by-emission unit basis. As an alternative to a

measurement device, the owner or operator may use a procedure acceptable to the applicable permitting

authority to determine the total weight of feed/charge or aluminum production to the affected source or emission

unit.

The accuracy of the weight measurement device or procedure must be plus or minus 1 percent of the weight

being measured. The owner or operator may apply to the permitting agency for approval to use a device of

alternative accuracy if the required accuracy cannot be achieved as a result of equipment layout or charging

practices. A device of alternative accuracy will not be approved unless the owner or operator provides assurance

through data and information that the affected source will meet the relevant emission standard.

The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

5.

[40 CFR 63.1510(j)(1) through (5)]

These requirements apply to the owner or operator of a group 1 furnace (with or without add-on air pollution

control devices) or in-line fluxer. The owner or operator must:

Install, calibrate, operate, and maintain a device to continuously measure and record the weight of gaseous or

liquid reactive flux injected to each affected source or emission unit.

(i) The monitoring system must record the weight for each 15-minute block period, during which reactive fluxing

occurs, over the same operating cycle or time period used in the performance test.

(ii) The accuracy of the weight measurement device must be plus or minus 1 percent of the weight of the reactive

component of the flux being measured. The owner or operator may apply to the permitting authority for

permission to use a weight measurement device of alternative accuracy in cases where the reactive flux flow

rates are so low as to make the use of a weight measurement device of plus or minus 1 percent impracticable.

A device of alternative accuracy will not be approved unless the owner or operator provides assurance through

data and information that the affected source will meet the relevant emission standards.

(iii) The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

Calculate and record the gaseous or liquid reactive flux injection rate (kg/Mg or lb/ton) for each operating cycle or

time period used in the performance test using the procedure in 63.1512(o).

Record, for each 15-minute block period during each operating cycle or time period used in the performance test

during which reactive fluxing occurs, the time, weight, and type of flux for each addition of:

(i) Gaseous or liquid reactive flux other than chlorine; and

(ii) Solid reactive flux.

6.

Calculate and record the total reactive flux injection rate for each operating cycle or time period used in the

performance test using the procedure in 63.1512(o).

The owner or operator of a group 1 furnace or in-line fluxer performing reactive fluxing may apply to the

Administrator for approval of an alternative method for monitoring and recording the total reactive flux addition rate

based on monitoring the weight or quantity of reactive flux per ton of feed/charge for each operating cycle or time

period used in the performance test. An alternative monitoring method will not be approved unless the owner or

operator provides assurance through data and information that the affected source will meet the relevant

emission standards on a continuous basis.

Terms and Conditions for Emissions Units

Title V Final Permit Page 53
25

8

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(o)(1) through (8)]

These requirements apply to the owner or operator of a group 1 furnace that is not equipped with an add-on air

pollution control device.

The owner or operator must develop, in consultation with the applicable permitting authority, a written

site-specific monitoring plan. The site-specific monitoring plan must be part of the OM&M plan that addresses

monitoring and compliance requirements for PM, HCl, and D/F emissions.

(i) The owner or operator of an existing affected source must submit the site-specific monitoring plan to the

applicable permitting authority for review at least 6 months prior to the compliance date.

(ii) The permitting authority will review and approve or disapprove a proposed plan, or request changes to a plan,

based on whether the plan contains sufficient provisions to ensure continuing compliance with applicable

emission limits and demonstrates, based on documented test results, the relationship between emissions of

PM, HCl, and D/F and the proposed monitoring parameters for each pollutant. Test data must establish the

highest level of PM, HCl, and D/F that will be emitted from the furnace. Subject to permitting agency approval of

the OM&M plan, this may be determined by conducting performance tests and monitoring operating parameters

while charging the furnace with feed/charge materials containing the highest anticipated levels of oils and

coatings and fluxing at the highest anticipated rate.

Each site-specific monitoring plan must document each work practice, equipment/design practice, pollution

prevention practice, or other measure used to meet the applicable emission standards.

Each site-specific monitoring plan must include provisions for unit labeling as required in paragraph (c) of

63.1510, feed/charge weight measurement (or production weight measurement) as required in paragraph (e) of

this section and flux weight measurement as required in paragraph

7.

Each site-specific monitoring plan for a melting/holding furnace subject to the clean charge emission standard in

63.1505(i)(3) must include these requirements:

(i) The owner or operator must record the type of feed/ charge (e.g., ingot, thermally dried chips, dried scrap,

etc.) for each operating cycle or time period used in the performance test; and

(ii) The owner or operator must submit a certification of compliance with the applicable operational standard for

clean charge materials in 63.1506(n)(3) for each 6-month reporting period. Each certification must contain the

information in 63.1516(b)(2)(iv).

If a continuous emission monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of the general provisions in subpart A of this part.

If a continuous opacity monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of this subpart.

If a site-specific monitoring plan includes a scrap inspection program for monitoring the scrap contaminant level

of furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of

the program in accordance with all applicable requirements in paragraph (p) of 63.1510.

If a site-specific monitoring plan includes a calculation method for monitoring the scrap contaminant level of

furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of the

program in accordance with all applicable requirements in paragraph (q) of this section.

Terms and Conditions for Emissions Units

Title V Final Permit Page 54
25

9

Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(p)(1) through (6)]

A scrap inspection program must include:

A proven method for collecting representative samples and measuring the oil and coatings content of scrap

samples;

A scrap inspector training program;

An established correlation between visual inspection and physical measurement of oil and coatings content of

scrap samples;

Periodic physical measurements of oil and coatings content of randomly-selected scrap samples and

comparison with visual inspection results;

A system for assuring that only acceptable scrap is charged to an affected group 1 furnace; and

Recordkeeping requirements to document conformance with plan requirements.

8.

[40 CFR 63.1510(q)(1) through (3)]

The owner or operator of a group 1 furnace dedicated to processing a distinct type of furnace feed/charge

composed of scrap with a uniform composition (such as rejected product from a manufacturing process for which

the coating-to-scrap ratio can be documented) may include a program in the site-specific monitoring plan for

determining, monitoring, and certifying the scrap contaminant level using a calculation method rather than a

scrap inspection program. A scrap contaminant monitoring program using a calculation method must include:

Procedures for the characterization and documentation of the contaminant level of the scrap prior to the

performance test.

Limitations on the furnace feed/charge to scrap of the same composition as that used in the performance test. If

the performance test was conducted with a mixture of scrap and clean charge, limitations on the proportion of

scrap in the furnace feed/charge to no greater than the proportion used during the performance test.

Operating, monitoring, recordkeeping, and reporting requirements to ensure that no scrap with a contaminant

level higher than that used in the performance test is charged to the furnace.

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 55
25

10 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(s)(1) through (3)]

An owner or operator of a secondary aluminum processing unit at a facility must include, within the OM&M plan

prepared in accordance with 63.1510(b), the following information:

(i) The identification of each emission unit in the secondary aluminum processing unit;

(ii) The specific control technology or pollution prevention measure to be used for each emission unit in the

secondary aluminum processing unit and the date of its installation or application;

(iii) The emission limit calculated for each secondary aluminum processing unit and performance test results

with supporting calculations demonstrating initial compliance with each applicable emission limit;

(iv) Information and data demonstrating compliance for each emission unit with all applicable design, equipment,

work practice or operational standards of this subpart; and

(v) The monitoring requirements applicable to each emission unit in a secondary aluminum processing unit and

the monitoring procedures for daily calculation of the 3-day, 24-hour rolling average using the procedure in

63.1510(t).

The SAPU compliance procedures within the OM&M plan may not contain any of the following provisions:

(i) Any averaging among emissions of differing pollutants;

(ii) The inclusion of any affected sources other than emission units in a secondary aluminum processing unit;

(iii) The inclusion of any emission unit while it is shutdown; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction in emission calculations.

To revise the SAPU compliance provisions within the OM&M plan prior to the end of the permit term, the owner

or operator must submit a request to the applicable permitting authority containing the information required by

paragraph (s)(1) of this section and obtain approval of the applicable permitting authority prior to implementing

any revisions.

10.

[40 CFR 63.1510(t)(1) through (5)]

Except as provided in paragraph (u) of this section, the owner or operator must calculate and record the 3-day,

24-hour rolling average emissions of PM, HCl, and D/F for each secondary aluminum processing unit on a daily

basis. To calculate the 3-day, 24-hour rolling average, the owner or operator must:

Calculate and record the total weight of material charged to each emission unit in the secondary aluminum

processing unit for each 24-hour day of operation using the feed/charge weight information required in paragraph

(e) of this section. If the owner or operator chooses to comply on the basis of weight of aluminum produced by

the emission unit, rather than weight of material charged to the emission unit, all performance test emissions

results and all calculations must be conducted on the aluminum production weight basis.

Multiply the total feed/charge weight to the emission unit, or the weight of aluminum produced by the emission

unit, for each emission unit for the 24-hour period by the emission rate (in lb/ton of feed/charge) for that emission

unit (as determined during the performance test) to provide emissions for each emission unit for the 24-hour

period, in pounds.

Divide the total emissions for each SAPU for the 24-hour period by the total material charged to the SAPU, or

the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the

SAPU.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 56
25

11 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Compute the 24-hour daily emission rate using Equation 4:

Eday~=~{sum from {i=1} to n (Ti x ERi)} OVER {sum from {i=1} to n Ti}

Where,

Eday = The daily PM, HCl, or D/F emission rate for the secondary aluminum processing unit for the

24-hour period;

Ti = The total amount of feed, or aluminum produced, for emission unit i for the 24-hour period (tons);

ERi = The measured emission rate for emission unit i as determined in the performance test (lb/ton or g/Mg

of feed/charge); and

n = The number of emission units in the secondary aluminum processing unit.

Calculate and record the 3-day, 24-hour rolling average for each pollutant each day by summing the daily

emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3.

[40 CFR 63.1510(u)]

As an alternative to the procedures of paragraph (t) of this section, an owner or operator may demonstrate,

through performance tests, that each individual emission unit within the secondary aluminum production unit is in

compliance with the applicable emission limits for the emission unit.

12.

[40 CFR 63.1517(a)(1) through (3)]

As required by 63.10(b), the owner or operator shall maintain files of all information (including all reports and

notifications) required by the general provisions and this subpart.

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 off site.

The owner or operator may retain records on microfilm, computer disks, magnetic tape, or microfiche; and

The owner or operator may report required information on paper or on a labeled computer disk using commonly

available and EPA-compatible computer software.

13.

[40 CFR 63.1517(b)]

In addition to the general records required by

63.10(b), the owner or operator of a new or existing affected source (including an emission unit in a secondary

aluminum processing unit) must maintain records of:

For each group 1 furnace (with or without add-on air pollution control devices) or in-line fluxer, records of

15-minute block average weights of gaseous or liquid reactive flux injection, total reactive flux injection rate and

calculations (including records of the identity, composition, and weight of each addition of gaseous, liquid or

solid reactive flux), including records of any period the rate exceeds the compliant operating parameter value and

corrective action taken.

For each affected source and emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge,

records of feed/charge (or throughput) weights for each operating cycle or time period used in the performance

test.

Approved site-specific monitoring plan for a group 1 furnace without add-on air pollution control devices with

records documenting conformance with the plan.

Records of all charge materials for each thermal chip dryer, dross-only furnace, and group 1 melting/holding

furnaces without air pollution control devices processing only clean charge.

14.

Terms and Conditions for Emissions Units

Title V Final Permit Page 57
25

12 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Records of monthly inspections for proper unit labeling for each affected source and emission unit subject to

labeling requirements.

Records for any approved alternative monitoring or test procedure.

Current copy of all required plans, including any revisions, with records documenting conformance with the

applicable plan, including:

(i) Startup, shutdown, and malfunction plan;

(ii) For major sources, OM&M plan; and

(iii) Site-specific secondary aluminum processing unit emission plan (if applicable).

For each secondary aluminum processing unit, records of total charge weight, or if the owner or operator

chooses to comply on the basis of aluminum production, total aluminum produced for each 24-hour period and

calculations of 3-day, 24-hour rolling average emissions.

[40 CFR 63.1510(w)(1) through (6)]

Alternative monitoring methods. An owner or operator may submit an application to the Administrator for approval

of alternate monitoring requirements to demonstrate compliance with the emission standards of this subpart,

subject to the provisions of paragraphs (w)(1) through (6) of this section. The Administrator will not approve

averaging periods other than those specified in this section.

The owner or operator must continue to use the original monitoring requirement until necessary data are

submitted and approval is received to use another monitoring procedure.

The owner or operator shall submit the application for approval of alternate monitoring methods no later than the

notification of the performance test. The application must contain the information specified in paragraphs (w)(3) (i)

through (iii) of this section:

(i) Data or information justifying the request, such as the technical or economic infeasibility, or the impracticality

of using the required approach;

(ii) A description of the proposed alternative monitoring

requirements, including the operating parameters to be monitored, the

monitoring approach and technique, and how the limit is to be

calculated; and

(iii) Data and information documenting that the alternative monitoring requirement(s) would provide equivalent or

better assurance of compliance with the relevant emission standard(s).

15.

The Administrator will not approve an alternate monitoring application unless it would provide equivalent or better

assurance of compliance with the relevant emission standard(s). Before disapproving any alternate monitoring

application, the Administrator will provide:

(i) Notice of the information and findings upon which the intended disapproval is based; and

(ii) Notice of opportunity for the owner or operator to present additional supporting information before final action

is taken on the application. This notice will specify how much additional time is allowed for the owner or operator

to provide additional supporting information.

The owner or operator is responsible for submitting any supporting information in a timely manner to enable the

Administrator to consider the application prior to the performance test. Neither submittal of an application nor the

Administrator's failure to approve or disapprove the application relieves the owner or operator of the responsibility

to comply with any provisions of this subpart.

The Administrator may decide at any time, on a case-by-case basis, that additional or alternative operating

limits, or alternative approaches to establishing operating limits, are necessary to demonstrate compliance with

the emission standards of this subpart.

Terms and Conditions for Emissions Units

Title V Final Permit Page 58
25

13 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements

The permittee shall submit quarterly deviation (excursion) reports that identify any exceedances of the aluminum

production rate limitation and the chlorine gas consumption limitation as well as the corrective actions that were

taken to achieve compliance. These reports shall be submitted to the Ohio EPA, Southeast District Office in

accordance with General Term and Condition A.1.c.ii.

1.

[40 CFR 63.1515(b)(1) through (4), (9) and (10)]

Each owner or operator must submit a notification of compliance status report within 60 days after the

compliance dates specified in 63.1501. The notification must be signed by the responsible official who must

certify its accuracy. A complete notification of compliance status report must include the information specified

in paragraphs (a)(1) through (10) of 63.1515. The required information may be submitted in an operating permit

application, in an amendment to an operating permit application, in a separate submittal, or in any combination.

In a State with an approved operating permit program where delegation of authority under section 112(l) of the

CAA has not been requested or approved, the owner or operator must provide duplicate notification to the

applicable Regional Administrator. If an owner or operator submits the information specified in this section at

different times or in different submittals, later submittals may refer to earlier submittals instead of duplicating and

resubmitting the information previously submitted. A complete notification of compliance status report must

include:

All information required in 63.9(h). The owner or operator must provide a complete performance test report for

each affected source and emission unit for which a performance test is required. A complete performance test

report includes all data, associated measurements, and calculations (including visible emission and opacity

tests).

The approved site-specific test plan and performance evaluation test results for each continuous monitoring

system (including a continuous emission or opacity monitoring system).

Unit labeling as described in 63.1506(b), including process type or furnace classification and

operating requirements.

2.

The compliant operating parameter value or range established for each affected source or emission unit with

supporting documentation and a description of the procedure used to establish the value (e.g., lime injection

rate, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet temperature),

including the operating cycle or time period used in the performance test.

Approved OM&M plan (including site-specific monitoring plan for each group 1 furnace with no add-on air

pollution control device).

Startup, shutdown, and malfunction plan, with revisions.

[40 CFR 63.1516(a)(1) through (3)]

The owner or operator must develop and implement a written plan as described in 63.6(e)(3) that contains

specific procedures to be followed for operating and maintaining the source during periods of startup, shutdown,

and malfunction, and a program of corrective action for malfunctioning process and air pollution control

equipment used to comply with the standard. The owner or operator shall also keep records of each event as

required by 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 63.6(e)(3). In addition to the information required in

63.6(e)(3), the plan must include:

Procedures to determine and record the cause of the malfunction and the time the malfunction began and ended;

and

Corrective actions to be taken in the event of a malfunction of a process or control device, including procedures

for recording the actions taken to correct the malfunction or minimize emissions.

3.

Terms and Conditions for Emissions Units

Title V Final Permit Page 59
25

14 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.1516(b)]

As required by 63.10(e)(3), the owner or operator must submit semiannual reports within 60 days after the end of

each 6-month period. Each report must contain the information specified in 63.10(c). When no deviations of

parameters have occurred, the owner or operator must submit a report stating that no excess emissions

occurred during the reporting period.

A report must be submitted if any of these conditions occur during a 6-month reporting period:

(i) An excursion of a compliant process or operating parameter value or range (e.g., lime injection rate or screw

feeder setting, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet

temperature, definition of acceptable scrap, or other approved operating parameter).

(ii) An action taken during a startup, shutdown, or malfunction was not consistent with the procedures in the plan

as described in 63.6(e)(3).

(iii) An affected source (including an emission unit in a secondary aluminum processing unit) was not operated

according to the requirements of this subpart.

(iv) A deviation from the 3-day, 24-hour rolling average emission limit for a secondary aluminum processing unit.

4.

Each report must include this certification: For each group 1 melting/holding furnace without add-on air pollution

control devices and using pollution prevention measures that processes only clean charge material: "Each group

1 furnace without add-on air pollution control devices subject to emission limits in 63.1505(i)(2) processed only

clean charge during this reporting period."

The owner or operator must submit the results of any performance test conducted during the reporting period,

including one complete report documenting test methods and procedures, process operation, and monitoring

parameter ranges or values for each test method used for a particular type of emission point tested.

[40 CFR 63.1516(c)]

For the purpose of annual certifications of compliance required by 40 CFR part 70 or 71, the owner or operator

must certify continuing compliance based upon, but not limited to, the following conditions:

Any period of excess emissions, as defined in paragraph (b)(1) of 63.1516, that occurred during the year were

reported as required by this subpart; and

All monitoring, recordkeeping, and reporting requirements were met during the year.

5.

[40 CFR 63.1512(r)]

The owner or operator of each scrap dryer/delacquering kiln/decoating kiln, group 1 furnace, group 2 furnace and

in-line fluxer must submit the information described in Sec. 63.1515(b)(3) as part of the notification of compliance

status report to document conformance with the operational standard in Sec. 63.1506(b).

6.

[40 CFR 63.1515(a)(6)]

As required by Sec. 63.9(e) and (f), the owner or operator must provide notification of the anticipated date for

conducting performance tests and visible emission observations. The owner or operator must notify the

Administrator of the intent to conduct a performance test at least 60 days before the performance test is

scheduled; notification of opacity or visible emission observations for a performance test must be provided at

least 30 days before the observations are scheduled to take place.

7.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions for the hold stack for this

emissions unit shall be determined in accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 60
25

15 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

1.836 pounds per hour of particulate emissions (hold stack)

Applicable Compliance Method:

The particulate emission factor for fluxing is derived from the chemical formulation of chlorine reacting with

aluminum to form dross AlCl3 and the chlorine usage rate of 1.63 cubic feet per ton of aluminum produced. This

analysis results in an emission factor (conservatively assumes that all of the dross is emitted as particulate

matter) of 0.24 pound of dross per ton of aluminum produced. Multiply the emission factor times the hourly

production rate of aluminum to determine the pounds of particulate matter emitted. 0.24 pound of

particulates/ton of aluminum times 15,000 pounds of aluminum per hour divide by 2,000 pounds/ton equals 1.8

pound/hour particulate emission rate from the fluxing activity.

The particulate emission factor for natural gas firing is from AP-42 Compilation of Air Pollutant Emission Factors

of 3 pounds/million cubic feet of gas fired. The hold furnace has two 6 million Btu/hour burners. Multiply the

number of burners (2) by the maximum rating (6 million Btu/hour) and divide by the heat content of one cubic foot

of natural gas (1,000 Btu/cubic foot) divide by one million to match emission factor units and multiply by the

emission factor 3 pounds/million cubic feet equal the maximum particulate emission rate of 0.036 pound/hour.

The total potential hold furnace stack particulate emission rate is the sum of the fluxing emission rate and gas

combustion emission rate (1.8 + 0.036 = 1.836 pounds/hour).

1.a

Emission Limitation:

8.04 tpy of particulate emissions (hold stack)

Applicable Compliance Method:

Compliance shall be demonstrated by the following:

i. Multiply the fluxing particulate emission factor of 0.24 pound of particulates/ton of aluminum times the annual

tons of aluminum produced and divide by 2,000 pounds/ton to determine the annual tons of particulate emissions

per year.

ii. Multiply the natural gas maximum hourly emission rate (0.036 pound/hour) by the annual hours of operation

and divide by 2,000 pounds/ton to determine the annual particulate emission rate, in tons per year.

The total hold furnace stack particulate emission rate is the sum of the fluxing emission rate and gas

combustion emission rate.

1.b

Emission Limitation:

0.007 pound per hour of sulfur dioxide (hold stack)

Applicable Compliance Method:

Compliance may be demonstrated by multiplying the sulfur dioxide emission factor of 0.6 pound of sulfur

dioxide/million cubic feet of natural gas usage by the maximum hourly natural gas consumption rate, in million

cubic feet/hour. The sulfur dioxide emission factor was obtained from USEPA, AP-42, Section 1.4, 5th edition

published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6.

1.c

Terms and Conditions for Emissions Units

Title V Final Permit Page 61
25

16 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

0.032 tpy of sulfur dioxide (hold stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.007 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

1.d

Emission Limitation:

0.034 pound VOC/hour (hold stack)

Applicable Compliance Method:

Compliance may be demonstrated by multiplying the VOC emission factor of 5.5 pounds of VOC/million cubic

feet of natural gas usage by the maximum hourly natural gas consumption rate, in million cubic feet/hour. The

VOC emission factor was obtained from USEPA, AP-42, Section 1.4, 5th edition published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 25 or 25A, as appropriate.

1.e

Emission Limitation:

0.15 tpy VOC (hold stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.034 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

1.f

Emission Limitation:

0.42 pound CO/hour (hold stack)

Applicable Compliance Method:

Compliance may be demonstrated by multiplying the CO emission factor of 84 pounds of CO/million cubic feet of

natural gas usage by the maximum hourly natural gas consumption rate, in million cubic feet/hour. The CO

emission factor was obtained from USEPA, AP-42, Section 1.4, 5th edition published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10.

1.g

Terms and Conditions for Emissions Units

Title V Final Permit Page 62
25

17 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

1.84 tpy CO (hold stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.42 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

1.h

Emission Limitation:

0.72 pound NOx/hour (hold stack)

Applicable Compliance Method:

Compliance may be demonstrated by multiplying the NOx emission factor of 0.06 pound of NOx/million Btu by

the maximum burner capacity, in million Btu/hour. The NOx emission factor was provided by the burner

manufacturer.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 7.

1.i

Emission Limitation:

3.15 tpy NOx (hold stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.72 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

1.j

Compliance with the emission limitations in section A.I.1 of these terms and conditions for the melt stack for this

emissions unit shall be determined in accordance with the following methods:

2.

Emission Limitation:

0.09 pound PM/hour (melt stack)

Applicable Compliance Method:

Compliance may be determined by multiplying the particulate emission factor of 1.9 pounds of

particulates/million cubic feet of natural gas by the maximum hourly natural gas consumption rate, in million

cubic feet/hour. The particulate emission factor was obtained from USEPA, AP-42, Section 1.4, 5th edition

published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5.

2.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 63
25

18 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

0.39 tpy PM (melt stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.09 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

2.b

Emission Limitation:

0.18 pound SO2/hour (melt stack)

Applicable Compliance Method:

Compliance may be determined by multiplying the SO2 emission factor of 0.6 pound of SO2/million cubic feet of

natural gas by the maximum hourly natural gas consumption rate, in million cubic feet/hour. The SO2 emission

factor was obtained from USEPA, AP-42, Section 1.4, 5th edition published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6.

2.c

Emission Limitation:

0.8 tpy SO2 (melt stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.18 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

2.d

Emission Limitation:

0.84 pound VOC/hour (melt stack)

Applicable Compliance Method:

Compliance may be determined by multiplying the VOC emission factor of 5.5 pounds of VOC/million cubic feet

of natural gas by the maximum hourly natural gas consumption rate, in million cubic feet/hour. The VOC

emission factor was obtained from USEPA, AP-42, Section 1.4, 5th edition published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 25 or 25A, as appropriate.

2.e

Terms and Conditions for Emissions Units

Title V Final Permit Page 64
25

19 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

3.7 tpy VOC (melt stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.84 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

2.f

Emission Limitation:

1.05 pounds CO/hour (melt stack)

Applicable Compliance Method:

Compliance may be determined by multiplying the CO emission factor of 84 pounds of CO/million cubic feet of

natural gas by the maximum hourly natural gas consumption rate, in million cubic feet/hour. The CO emission

factor was obtained from USEPA, AP-42, Section 1.4, 5th edition published in July, 1998.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 10.

2.g

Emission Limitation:

4.60 tpy CO (melt stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 1.05 pounds per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

2.h

Emission Limitation:

1.80 pounds NOx/hour (melt stack)

Applicable Compliance Method:

Compliance may be determined by multiplying the NOx emission factor of 0.06 pound of NOx/million Btu by the

maximum hourly heat input, in million Btu/hour. The NOx emission factor was provided by the burner

manufacturer.

If required, the permittee shall demonstrate compliance with this emission limitation through emission tests

performed in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 7.

2.i

Terms and Conditions for Emissions Units

Title V Final Permit Page 65
25

20 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

7.88 tpy NOx (melt stack)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 1.80 pounds per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

2.j

Compliance with the emission limitations in section A.I.1 of these terms and conditions for the casting activities

for this emissions unit shall be determined in accordance with the following methods:

3.

Emission Limitation:

0.15 pound SO2/hour (casting fugitive)

Applicable Compliance Method:

Compliance shall be determined by multiplying the SO2 emission factor of 0.02 pound of SO2/ton produced by

the maximum hourly aluminum production rate. The SO2 emission factor was obtained from USEPA, AIRS.

3.a

Emission Limitation:

0.66 tpy SO2 (casting fugitive)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.15 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

3.b

Emission Limitation:

0.08 pound NOx/hour (casting fugitive)

Applicable Compliance Method:

Compliance shall be determined by multiplying the NOx emission factor of 0.01 pound of NOx/ton produced by

the maximum hourly aluminum production rate. The NOx emission factor was obtained from USEPA, AIRS.

3.c

Emission Limitation:

0.35 tpy NOx (casting fugitive)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 0.08 pound per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

3.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 66
25

21 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

1.05 pounds VOC/hour (casting fugitive)

Applicable Compliance Method:

Compliance shall be determined by multiplying the VOC emission factor of 0.14 pound of VOC/ton produced by

the maximum hourly aluminum production rate. The VOC emission factor was obtained from USEPA, AIRS.

3.e

Emission Limitation:

4.60 tpy VOC (casting fugitive)

Applicable Compliance Method:

This emission limitation was established by multiplying the hourly emission limitation of 1.05 pounds per hour by

the maximum annual hours of operation (8,760 hrs), and then dividing by 2,000 pounds/ton. Compliance with the

annual emission limitation may be assumed provided compliance with the hourly emission limitation has been

maintained.

3.f

Compliance with the visible emission limitation in section A.I.1 of these terms and conditions shall be

determined in accordance with the following method:

Emission Limitation:

Visible particulate emissions from the melt stack, hold stack, and casting activities shall not exceed 5% opacity

as a 6-minute average.

Applicable Compliance Method:

Compliance shall be determined by performing visible particulate emission observations in accordance with the

methods and procedures specified in 40 CFR Part 60, Appendix A, Method 9.

4.

Compliance with the operational restrictions in sections A.II.1 and A.II.2 of these terms and conditions shall be

determined in accordance with the following method:

Operational Restrictions:

The maximum hourly aluminum production rate for this emissions unit shall not exceed 15,000 pounds per hour.

The maximum chlorine consumption rate shall not exceed 1.63 cubic feet of chlorine per ton of aluminum

produced.

Applicable Compliance Method:

Compliance shall be demonstrated based upon the monitoring and record keeping requirements specified in

section A.III.1.

5.

[40 CFR 63.1511(a)]

Prior to conducting a performance test required by this subpart, the owner or operator must prepare and submit a

site-specific test plan meeting the requirements in 63.7(c).

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 67
25

22 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(b)]

Following approval of the site-specific test plan, the owner or operator must demonstrate initial compliance with

each applicable emission, equipment, work practice, or operational standard for each affected source and

emission unit, and report the results in the notification of compliance status report as described in 63.1515(b).

The owner or operator must conduct each performance test according to the requirements of the general

provisions in subpart A of this part and this subpart. Owners or operators of affected sources located at facilities

which are area sources are subject only to those performance testing requirements pertaining to D/F. Owners or

operators of sweat furnaces meeting the specifications of 63.1505(f)(1) are not required to conduct a performance

test.

The owner or operator must conduct each test while the affected source or emission unit is operating at the

highest production level with charge materials representative of the range of materials processed by the unit and,

if applicable, at the highest reactive fluxing rate.

7.

Each performance test for a continuous process must consist of 3 separate runs; pollutant sampling for each run

must be conducted for the time period specified in the applicable method or, in the absence of a specific time

period in the test method, for a minimum of 3 hours.

Each performance test for a batch process must consist of three separate runs; pollutant sampling for each run

must be conducted over the entire process operating cycle.

Where multiple affected sources or emission units are exhausted through a common stack, pollutant sampling

for each run must be conducted over a period of time during which all affected sources or emission units

complete at least 1 entire process operating cycle or for 24 hours, whichever is shorter.

Initial compliance with an applicable emission limit or standard is demonstrated if the average of three runs

conducted during the performance test is less than or equal to the applicable emission limit or standard.

[40 CFR 63.1511(c)]

The owner or operator must use the following methods in appendix A to 40 CFR part 60 to determine compliance

with the applicable emission limits or standards:

Method 1 for sample and velocity traverses.

Method 2 for velocity and volumetric flow rate.

Method 3 for gas analysis.

Method 4 for moisture content of the stack gas.

Method 5 for the concentration of PM.

Method 9 for visible emission observations.

Method 26A for the concentration of HCl. Where a lime-injected fabric filter is used as the control device to

comply with the 90 percent reduction standard, the owner or operator must measure the fabric filter inlet

concentration of HCl at a point before lime is introduced to the system.

8.

[40 CFR 63.1511(d)]

The owner or operator may use an alternative test method, subject to approval by the Administrator.

9.

[40 CFR 63.1511(e)]

The owner or operator of new or existing affected sources and emission units located at secondary aluminum

production facilities that are major sources must conduct a performance test every 5 years following the initial

performance test.

10.

Terms and Conditions for Emissions Units

Title V Final Permit Page 68
25

23 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(f)(1) through (6)]

With the approval of the permitting authority, a single representative or similar group 1 furnace or in-line fluxer

which is not controlled by an add-on control device may be tested to determine the emission rate of all like

affected sources at a facility provided that:

The tested emission unit must use identical feed/charge and flux materials in the same proportions as the

emission units that it represents;

The tested emission unit is subject to the same work practices and the emission units that it represents;

The tested emission unit is of the same design as the emission units that it represents;

The tested emission unit is tested under the highest load or capacity reasonably expected to occur for any of the

emission units that it represents;

At least one of each different style of emission unit at the facility is tested; and

All add-on control devices are tested.

11.

[40 CFR 63.1511(g)(1) through (4)]

The owner or operator of new or existing affected sources and emission units must establish a minimum or

maximum operating parameter value, or an operating parameter range for each parameter to be monitored as

required by 63.1510 that ensures compliance with the applicable emission limit or standard. To establish the

minimum or maximum value or range, the owner or operator must use the appropriate procedures in this section

and submit the information required by 63.1515(b)(4) in the notification of compliance status report. The owner or

operator may use existing data in addition to the results of performance tests to establish operating parameter

values for compliance monitoring provided each of the following conditions are met to the satisfaction of the

applicable permitting authority:

The complete emission test report(s) used as the basis of the parameter(s) is submitted.

The same test methods and procedures as required by Subpart RRR were used in the test.

The owner or operator certifies that no design or work practice changes have been made to the source, process,

or emission control equipment since the time of the report.

All process and control equipment operating parameters required to be monitored were monitored as required in

this subpart and documented in the test report.

12.

Terms and Conditions for Emissions Units

Title V Final Permit Page 69
25

24 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(e)(1) through (3)]

In the site-specific monitoring plan required by 63.1510(o), the owner or operator of a group 1 furnace (including a

melting/holding furnaces) without add-on air pollution control devices must include data and information

demonstrating compliance with the applicable emission limits.

If the group 1 furnace processes other than clean charge material, the owner or operator must conduct emission

tests to measure emissions of PM, HCl, and D/F at the furnace exhaust outlet.

If the group 1 furnace processes only clean charge, the owner or operator must conduct emission tests to

simultaneously measure emissions of PM and HCl at the furnace exhaust outlet. A D/F test is not required.

Each test must be conducted while the group 1 furnace (including a melting/holding furnace) processes only

clean charge.

The owner or operator may choose to determine the rate of reactive flux addition to the group 1 furnace and

assume, for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added

to the group 1 furnace is emitted. Under these circumstances, the owner or operator is not required to conduct

an emission test for HCl.

13.

[40 CFR 63.1512(h)(1) and (2)]

The owner or operator must conduct a performance test to measure emissions of HCl and PM. If the in-line

fluxer is equipped with an add-on control device, the emissions must be measured at the outlet of the control

device. If the in-line fluxer uses no reactive flux materials, emission tests for PM and HCl are not required.

The owner or operator may choose to determine the rate of reactive flux addition to the in-line fluxer and assume,

for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added to the

in-line fluxer is emitted. Under these circumstances, the owner or operator is not required to conduct an

emission test for HCl.

14.

[40 CFR 63.1512(j)(1) through (3)]

The owner or operator must conduct performance tests as described in paragraphs (j)(1) through (3) of this

section. The results of the performance tests are used to establish emission rates in lb/ton of feed/charge for

PM and HCl and g TEQ/Mg of feed/charge for D/F emissions from each emission unit. These emission rates

are used for compliance monitoring in the calculation of the 3-day, 24-hour rolling average emission rates using

the equation in 63.1510(t). A performance test is required for:

Each group 1 furnace processing only clean charge to measure emissions of PM and either:

(i) Emissions of HCl (for the emission limit); or

(ii) The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

Each group 1 furnace that processes scrap other than clean charge to measure emissions of PM and D/F and

either:

(i) Emissions of HCl (for the emission limit); or

(ii) The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

Each in-line fluxer to measure emissions of PM and HCl.

15.

Terms and Conditions for Emissions Units

Title V Final Permit Page 70
25

25 Facility Name:

Facility ID:

Emissions Unit: Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(k)]

During the emission test(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format,

the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of

feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the

affected source or emission unit for each of the three test runs and calculate and record the total weight. An

owner or operator that chooses to demonstrate compliance on the basis of the aluminum production weight must

measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge

weight.

16.

[40 CFR 63.1512(o)(1) through (5)]

The owner or operator must use these procedures to establish an operating parameter value or range for the total

reactive chlorine flux injection rate.

Continuously measure and record the weight of gaseous or liquid reactive flux injected for each 15 minute period

during the HCl and D/F tests, determine and record the 15-minute block average weights, and calculate and

record the total weight of the gaseous or liquid reactive flux for the 3 test runs;

Record the identity, composition, and total weight of each addition of solid reactive flux for the 3 test runs;

Determine the total reactive chlorine flux injection rate by adding the recorded measurement of the total weight of

chlorine in the gaseous or liquid reactive flux injected and the total weight of chlorine in the solid reactive flux

using this equation:

Wt = F1W1 + F2W2

Where,

Wt = Total chlorine usage, by weight;

F1 = Fraction of gaseous or liquid flux that is chlorine;

W1 = Weight of reactive flux gas injected;

F2 = Fraction of solid reactive chloride flux that is chlorine (e.g., F = 0.75 for magnesium chloride; and

W2 = Weight of solid reactive flux;

Divide the weight of total chlorine usage (Wt) for the 3 test runs by the recorded measurement of the total weight

of feed for the 3 test runs; and

If a solid reactive flux other than magnesium chloride is used, the owner or operator must derive the appropriate

proportion factor subject to approval by the applicable permitting authority.

17.

[40 CFR 63.1513(b)]

The permittee shall use the equations contained in 40 CFR 63.1513 to determine compliance with the applicable

emission limits.

18.

VI. Miscellaneous Requirements

The permittee shall seek a Permit to Install (PTI) modification for PTI 17-1606 to adjust the permit allowables to

be consistent with the applicable 40 CFR Part 63, Subpart RRR emission limits. This modification application

shall be submitted within three months of Title V permit issuance.

1.

2. The permittee shall obtain a PTI prior to using other than clean charge in this furnace.

Terms and Conditions for Emissions Units

Title V Final Permit Page 71
1

1

Thixo Casting (P080)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 72
3

1

Facility Name:

Facility ID:

Emissions Unit: Coke Belt Conveyor (P101)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 12.3 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Coke Belt Conveyor (P101)

Coke Belt Conveyor

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

spent anode belt conveyor vented to

a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

12.3 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 73
3

2

Facility Name:

Facility ID:

Emissions Unit: Coke Belt Conveyor (P101)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 74
3

3

Facility Name:

Facility ID:

Emissions Unit: Coke Belt Conveyor (P101)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 12.3 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 75
1

1

Coke Belt Conveyor (P101)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 76
2

1

Facility Name:

Facility ID:

Emissions Unit: Belt Elevator (P102)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The material handling operation(s) that are covered by this permit and subject to the requirements of OAC

rules 3745-17-07 and 3745-17-08 are listed below:

belt elevator

2.b The permittee shall employ reasonably available control measures for the belt elevator for the purpose of

ensuring compliance with the above-mentioned applicable requirements. In accordance with the permittee's

permit application, the permittee has committed to use a partial enclosure to minimize or eliminate visible

emissions of fugitive dust.

Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure

compliance.

2.c Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

Belt Elevator (P102)

Belt Evelator

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

belt elevator OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 77
2

2

Facility Name:

Facility ID:

Emissions Unit: Belt Elevator (P102)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 78
1

1

Belt Elevator (P102)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 79
3

1

Facility Name:

Facility ID:

Emissions Unit: Butt/Fractions Blend (P103)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 22.4 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Butt/Fractions Blend (P103)

Butt/Fractions Blend

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

butt/fractions blend operation vented

to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

22.4 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 80
3

2

Facility Name:

Facility ID:

Emissions Unit: Butt/Fractions Blend (P103)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 81
3

3

Facility Name:

Facility ID:

Emissions Unit: Butt/Fractions Blend (P103)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 22.4 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 82
1

1

Butt/Fractions Blend (P103)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 83
3

1

Facility Name:

Facility ID:

Emissions Unit: K-640-325/329 (P134)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 28.0 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

K-640-325/329 (P134)

K-640-325/329

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

K-640-325/329 system operation OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

28.0 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 84
3

2

Facility Name:

Facility ID:

Emissions Unit: K-640-325/329 (P134)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 85
3

3

Facility Name:

Facility ID:

Emissions Unit: K-640-325/329 (P134)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 28.0 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 86
1

1

K-640-325/329 (P134)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 87
3

1

Facility Name:

Facility ID:

Emissions Unit: Tumbling Mill (P203)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 17.7 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Tumbling Mill (P203)

Tumbling Mill

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

tumbling mill operation vented to a

baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a through A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

17.7 pounds per hour, as calculated

from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 88
3

2

Facility Name:

Facility ID:

Emissions Unit: Tumbling Mill (P203)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned weekly checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 89
3

3

Facility Name:

Facility ID:

Emissions Unit: Tumbling Mill (P203)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stack shall not exceed 17.7 lbs/hr.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 90
1

1

Tumbling Mill (P203)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 91
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K661 (P213)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 50.0 pounds of particulate

emissions per hour from the baghouse exhaust stacks serving emissions units P213, P214, P215, P216 and

P217, combined.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

Hartman System Coke Fines-K661 (P213)

Hartman System Coke Fines

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman system coke fines - K661

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

50.0 pounds per hour for emissions

units P213, P214, P215, P216 and

P217, combined.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 92
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K661 (P213)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 93
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K661 (P213)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stacks shall not exceed 50.0 pounds per hour for emissions units P213, P214, P215,

P216 and P217, combined.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 94
1

1

Hartman System Coke Fines-K661 (P213)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 95
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K662 (P214)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 50.0 pounds of particulate

emissions per hour from the baghouse exhaust stacks serving emissions units P213, P214, P215, P216 and

P217, combined.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

Hartman System Coke Fines-K662 (P214)

Hartman System Coke Fines

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman system coke fines - K662

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

50.0 pounds per hour for emissions

units P213, P214, P215, P216 and

P217, combined.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 96
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K662 (P214)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 97
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K662 (P214)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stacks shall not exceed 50.0 pounds per hour for emissions units P213, P214, P215,

P216 and P217, combined.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 98
1

1

Hartman System Coke Fines-K662 (P214)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 99
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K663 (P215)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 50.0 pounds of particulate

emissions per hour from the baghouse exhaust stacks serving emissions units P213, P214, P215, P216 and

P217, combined.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

Hartman System Coke Fines-K663 (P215)

Hartman System Coke Fines-K663

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman system coke fines - K663

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

50.0 pounds per hour for emissions

units P213, P214, P215, P216 and

P217, combined.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 100
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K663 (P215)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 101
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K663 (P215)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stacks shall not exceed 50.0 pounds per hour for emissions units P213, P214, P215,

P216 and P217, combined.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 102
1

1

Hartman System Coke Fines-K663 (P215)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 103
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K664 (P216)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 50.0 pounds of particulate

emissions per hour from the baghouse exhaust stacks serving emissions units P213, P214, P215, P216 and

P217, combined.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

Hartman System Coke Fines-K664 (P216)

Hartman System Coke Fines-K664

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman system coke fines - K664

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

50.0 pounds per hour for emissions

units P213, P214, P215, P216 and

P217, combined.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 104
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K664 (P216)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 105
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K664 (P216)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stacks shall not exceed 50.0 pounds per hour for emissions units P213, P214, P215,

P216 and P217, combined.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 106
1

1

Hartman System Coke Fines-K664 (P216)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 107
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K665 (P217)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 50.0 pounds of particulate

emissions per hour from the baghouse exhaust stacks serving emissions units P213, P214, P215, P216 and

P217, combined.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows and roof openings.

Hartman System Coke Fines-K665 (P217)

Hartman System Coke Fines-K665

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman system coke fines - K665

vented to a baghouse

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B)(3) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions (PE)

from any baghouse stack shall not

exceed 20% opacity, as a 6-minute

average, except as provided by rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions (PE) from the

baghouse stacks shall not exceed

50.0 pounds per hour for emissions

units P213, P214, P215, P216 and

P217, combined.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 108
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K665 (P217)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse stack serving this emissions unit and

for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors,

etc.). The presence or absence of any visible fugitive emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit or any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

and (b) describe any corrective actions taken to minimize or eliminate the visible fugitive particulate emissions.

These reports shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) by

January 31 and July 31 of each year and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 109
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman System Coke Fines-K665 (P217)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Emission Limitation:

Visible PE from the baghouse stacks shall not exceed 20% opacity, as a 6-minute average, except as provided

by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR, Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

PE from the baghouse stacks shall not exceed 50.0 pounds per hour for emissions units P213, P214, P215,

P216 and P217, combined.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(7).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 110
1

1

Hartman System Coke Fines-K665 (P217)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 111
2

1

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-1 (P230)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

Electromelt Furnace F-670-1 (P230)

Electromelt Furnace F-670-1

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

electromelt furnace F-670-1 vented to

a baghouse

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 4.76 pounds per hour.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 112
2

2

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-1 (P230)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04 (A).

1.a

Emission Limitation:

4.76 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance may be determined by multiplying the maximum hourly production rate of 1.25 tons of metal per

hour by the particulate emission factor of 0.9 pound of particulate per ton of metal produced per hour. This

emission factor is contained in AP-42 Table 12.10-3, dated 1/95.

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(10). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.b

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 113
1

1

Electromelt Furnace F-670-1 (P230)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 114
2

1

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-2 (P231)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

Electromelt Furnace F-670-2 (P231)

Electromelt Furnace F-670-2

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

electromelt furnace F-670-2 vented to

a baghouse

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 4.76 pounds per hour.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 115
2

2

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-2 (P231)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04 (A).

1.a

Emission Limitation:

4.76 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance may be determined by multiplying the maximum hourly production rate of 1.25 tons of metal per

hour by the particulate emission factor of 0.9 pound of particulate per ton of metal produced per hour. This

emission factor is contained in AP-42 Table 12.10-3, dated 1/95.

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(10). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.b

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 116
1

1

Electromelt Furnace F-670-2 (P231)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 117
2

1

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-3 (P232)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

Electromelt Furnace F-670-3 (P232)

Electromelt Furnace F-670-3

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

electromelt furnace F-670-3 vented to

a baghouse

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 4.76 pounds per hour.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 118
2

2

Facility Name:

Facility ID:

Emissions Unit: Electromelt Furnace F-670-3 (P232)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04 (A).

1.a

Emission Limitation:

4.76 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance may be determined by multiplying the maximum hourly production rate of 1.25 tons of metal per

hour by the particulate emission factor of 0.9 pound of particulate per ton of metal produced per hour. This

emission factor is contained in AP-42 Table 12.10-3, dated 1/95.

If required, compliance shall be demonstrated based upon the emission testing procedures specified in 40 CFR

Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(10). No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.b

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 119
1

1

Electromelt Furnace F-670-3 (P232)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 120
21

1

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Direct Chill Casting Pit No. 3 (P233)

Direct Chill Casting Pit No. 3

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

direct chill casting pit no. 3 OAC rule 3745-31-05(A)(3)

(PTI 17-609)

This emissions unit is limited to:

1.0 pound per hour of particulate

emissions

0.05 pound per hour of sulfur dioxide

emissions

0.24 pound per hour of organic

compound emissions

11.13 pounds per hour of nitrogen

oxides emissions

2.75 pounds per hour of carbon

monoxide emissions

0.33 mg per cubic meter of hydrogen

chloride emissions

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11 The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-18-06 The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 121
21

2

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.1505(i)]

The owner or operator of a group 1 furnace must use the limits in this paragraph to determine the emission

standards for a SAPU.

0.40 kg of PM per Mg (0.80 lb of PM per ton) of feed/charge from a group 1 melting/holding furnace

processing only clean charge at a secondary aluminum production facility that is a major source; and

0.20 kg of HCl per Mg (0.40 lb of HCl per ton) of feed/charge or, if the furnace is equipped with an add-on air

pollution control device, 10 percent of the uncontrolled HCl emissions, by weight, for a group 1 furnace at a

secondary aluminum production facility that is a major source.

The owner or operator may determine the emission standards for a SAPU by applying the group 1 furnace

limits on the basis of the aluminum production weight in each group 1 furnace, rather than on the basis of

feed/charge.

2.b [40 CFR 63.1505(j)]

Except as provided in paragraph (j)(3) of 63.1505 for an in-line fluxer using no reactive flux material, the owner

or operator of an in-line fluxer must use the limits in this paragraph to determine the emission standards for a

SAPU.

0.02 kg of HCl per Mg (0.04 lb of HCl per ton) of feed/charge; and

0.005 kg of PM per Mg (0.01 lb of PM per ton) of feed/charge.

The owner or operator may determine the emission standards for a SAPU by applying the in-line fluxer limits

on the basis of the aluminum production weight in each in-line fluxer, rather than on the basis of feed/charge.

2.c [40 CFR 63.1505(k)(1) through (3)]

On and after the date of approval of the operation, maintenance and monitoring (OM&M) plan, the owner or

operator must comply with the emission limits calculated using the equations for PM and HCl in paragraphs

(k)(1) and (k)(2) of 63.1505 for each secondary aluminum processing unit at a secondary aluminum

production facility that is a major source. The owner or operator must comply with the emission limit

calculated using the equation for D/F in paragraph (k)(3) of 63.1505 for each secondary aluminum processing

unit at a secondary aluminum production facility that is a major or area source.

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of PM in excess of:

LcPM = {sum from {i=1} to n (LtiPM times Tti)} over {sum from {i=1} to n (Tti)}

Where,

LtiPM = The PM emission limit for individual emission unit i in paragraph (i)(1) and (2) of 63.1505 for a group

1 furnace or in paragraph (j)(2) of 63.1505 for an in-line fluxer;

Tti = The feed/charge rate for individual emission unit I; and

LcPM = The PM emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the PM limit.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

40 CFR Part 63.1505

(Subpart RRR)

471868 471868 See A.I.2.a through A.I.2.c below.

Terms and Conditions for Emissions Units

Title V Final Permit Page 122
21

3

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of HCl in excess of:

LcHCl = {sum from {i=1} to n (LtiHCl times Tti)} over {sum from {i=1} to n ( Tti)}

Where,

LtiHCl = The HCl emission limit for individual emission unit i in paragraph (i)(4) of 63.1505 for a group 1

furnace or in paragraph (j)(1) of 63.1505 for an in-line fluxer; and

LcHCl = The HCl emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the HCl limit.

The owner or operator of a SAPU at a secondary aluminum production facility that is a major source may

demonstrate compliance with the emission limits of paragraphs (k)(1) through (3) of 63.1505 by

demonstrating that each emission unit within the SAPU is in compliance with the applicable emission limits

of paragraphs (i) and (j) of 63.1505.

II. Operational Restrictions

[40 CFR 63.1506(a)(1) and (2)]

On and after the date on which the initial performance test is conducted or required to be conducted, whichever

date is earlier, the owner or operator must operate all new and existing affected sources and control equipment

according to the requirements in this section.

The completion of the initial performance tests for SAPUs shall be considered to be the date of approval of the

OM&M plan by the permitting authority.

1.

[40 CFR 63.1506(b)(1) and (2)]

The owner or operator must provide and maintain easily visible labels posted at each group 1 furnace, group 2

furnace, in-line fluxer and scrap dryer/delacquering kiln/decoating kiln that identifies the applicable emission

limits and means of compliance, including:

The type of affected source or emission unit (e.g., scrap dryer/delacquering kiln/decoating kiln, group 1 furnace,

group 2 furnace, in-line fluxer).

The applicable operational standard(s) and control method(s) (work practice or control device). This includes, but

is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials

and addition practices, and the applicable operating parameter ranges and requirements as incorporated in the

OM&M plan.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 123
21

4

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.1506(d)(1) through (3)]

The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of

feed/charge must:

Except as provided in paragraph (d)(3) of 63.1506, install and operate a device that measures and records or

otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the

performance test; and

Operate each weight measurement system or other weight determination procedure in accordance with the

OM&M plan.

The owner or operator may chose to measure and record aluminum production weight from an affected source or

emission unit rather than feed/charge weight to an affected source or emission unit, provided that:

(i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission

units within a SAPU; and

(ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum

production weight rather than feed/charge weight.

3.

[40 CFR 63.1506(n)(1) through (3)]

The owner or operator of a group 1 furnace (including a group 1 furnace that is part of a secondary aluminum

processing unit) without add-on air pollution control devices must:

Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the

performance test at or below the average rate established during the performance test.

Operate each furnace in accordance with the work practice/pollution prevention measures documented in the

OM&M plan and within the parameter values or ranges established in the OM&M plan.

Operate each group 1 melting/holding furnace subject to the emission standards in 63.1505(i)(2) using only clean

charge as the feedstock.

4.

[40 CFR 63.1506(p)]

When a process parameter or add-on air pollution control device operating parameter deviates from the value or

range established during the performance test and incorporated in the OM&M plan, the owner or operator must

initiate corrective action. Corrective action must restore operation of the affected source or emission unit

(including the process or control device) to its normal or usual mode of operation as expeditiously as practicable

in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must

include follow-up actions necessary to return the process or control device parameter level(s) to the value or

range of values established during the performance test and steps to prevent the likely recurrence of the cause of

a deviation.

5.

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 124
21

5

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information:

a. the natural gas usage for each day;

b. the production rate, in pounds of aluminum per day; and

c. the hours of operation.

2.

[40 CFR 63.1510(a)]

On and after the date the initial performance test is completed or required to be completed, whichever date is

earlier, the owner or operator of a new or existing affected source or emission unit must monitor all control

equipment and processes according to the requirements in this section. Monitoring requirements for each type

of affected source and emission unit are summarized in Table 3 to Subpart RRR.

3.

[40 CFR 63.1510(b)(1) through (8)]

The owner or operator must prepare and implement for each new or existing affected source and emission unit, a

written operation, maintenance, and monitoring (OM&M) plan. The owner or operator must submit the plan to

the applicable permitting authority for review and approval as part of the application for a part 70 or part 71 permit.

Any subsequent changes to the plan must be submitted to the applicable permitting authority for review and

approval. Pending approval by the applicable permitting authority of an initial or amended plan, the owner or

operator must comply with the provisions of the submitted plan. Each plan must contain the following

information:

Process and control device parameters to be monitored to determine compliance, along with established

operating levels or ranges, as applicable, for each process and control device.

A monitoring schedule for each affected source and emission unit.

Procedures for the proper operation and maintenance of each process unit and add-on control device used to

meet the applicable emission limits or standards in 63.1505.

4.

Procedures for the proper operation and maintenance of monitoring devices or systems used to determine

compliance, including:

(i) Calibration and certification of accuracy of each monitoring device, at least once every 6 months, according to

the manufacturer's instructions; and

(ii) Procedures for the quality control and quality assurance of continuous emission or opacity monitoring

systems as required by the general provisions in subpart A of this part.

Procedures for monitoring process and control device parameters, including procedures for annual inspections of

afterburners, and if applicable, the procedure to be used for determining charge/feed (or throughput) weight if a

measurement device is not used.

Corrective actions to be taken when process or operating parameters or add-on control device parameters

deviate from the value or range established in paragraph (b)(1) of 63.1510, including:

(i) Procedures to determine and record the cause of an deviation or excursion, and the time the deviation or

excursion began and ended; and

(ii) Procedures for recording the corrective action taken, the time corrective action was initiated, and the

time/date corrective action was completed.

A maintenance schedule for each process and control device that is consistent with the manufacturer's

instructions and recommendations for routine and long-term maintenance.

Documentation of the work practice and pollution prevention measures used to achieve compliance with the

applicable emission limits and a site-specific monitoring plan as required in paragraph (o) of 63.1510 for each

group 1 furnace not equipped with an add-on air pollution control device.

Terms and Conditions for Emissions Units

Title V Final Permit Page 125
21

6

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(c)]

The owner or operator must inspect the labels for each group 1 furnace, group 2 furnace, in-line fluxer and scrap

dryer/delacquering kiln/decoating kiln at least once per calendar month to confirm that posted labels as required

by the operational standard in 63.1506(b) are intact and legible.

5.

[40 CFR 63.1510(e)(1) and (2)]

The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or

g/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the

total weight of feed/charge to, or the aluminum production from, the affected source or emission unit over the

same operating cycle or time period used in the performance test. Feed/charge or aluminum production within

SAPUs must be measured and recorded on an emission unit-by-emission unit basis. As an alternative to a

measurement device, the owner or operator may use a procedure acceptable to the applicable permitting

authority to determine the total weight of feed/charge or aluminum production to the affected source or emission

unit.

The accuracy of the weight measurement device or procedure must be plus or minus 1 percent of the weight

being measured. The owner or operator may apply to the permitting agency for approval to use a device of

alternative accuracy if the required accuracy cannot be achieved as a result of equipment layout or charging

practices. A device of alternative accuracy will not be approved unless the owner or operator provides assurance

through data and information that the affected source will meet the relevant emission standard.

The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

6.

[40 CFR 63.1510(j)(1) through (5)]

These requirements apply to the owner or operator of a group 1 furnace (with or without add-on air pollution

control devices) or in-line fluxer. The owner or operator must:

Install, calibrate, operate, and maintain a device to continuously measure and record the weight of gaseous or

liquid reactive flux injected to each affected source or emission unit.

(i) The monitoring system must record the weight for each 15-minute block period, during which reactive fluxing

occurs, over the same operating cycle or time period used in the performance test.

(ii) The accuracy of the weight measurement device must be plus or minus 1 percent of the weight of the reactive

component of the flux being measured. The owner or operator may apply to the permitting authority for

permission to use a weight measurement device of alternative accuracy in cases where the reactive flux flow

rates are so low as to make the use of a weight measurement device of plus or minus 1 percent impracticable.

A device of alternative accuracy will not be approved unless the owner or operator provides assurance through

data and information that the affected source will meet the relevant emission standards.

(iii) The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

Calculate and record the gaseous or liquid reactive flux injection rate (kg/Mg or lb/ton) for each operating cycle or

time period used in the performance test using the procedure in 63.1512(o).

Record, for each 15-minute block period during each operating cycle or time period used in the performance test

during which reactive fluxing occurs, the time, weight, and type of flux for each addition of:

(i) Gaseous or liquid reactive flux other than chlorine; and

(ii) Solid reactive flux.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 126
21

7

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Calculate and record the total reactive flux injection rate for each operating cycle or time period used in the

performance test using the procedure in 63.1512(o).

The owner or operator of a group 1 furnace or in-line fluxer performing reactive fluxing may apply to the

Administrator for approval of an alternative method for monitoring and recording the total reactive flux addition rate

based on monitoring the weight or quantity of reactive flux per ton of feed/charge for each operating cycle or time

period used in the performance test. An alternative monitoring method will not be approved unless the owner or

operator provides assurance through data and information that the affected source will meet the relevant

emission standards on a continuous basis.

[40 CFR 63.1510(o)(1) through (8)]

These requirements apply to the owner or operator of a group 1 furnace that is not equipped with an add-on air

pollution control device.

The owner or operator must develop, in consultation with the applicable permitting authority, a written

site-specific monitoring plan. The site-specific monitoring plan must be part of the OM&M plan that addresses

monitoring and compliance requirements for PM, HCl, and D/F emissions.

(i) The owner or operator of an existing affected source must submit the site-specific monitoring plan to the

applicable permitting authority for review at least 6 months prior to the compliance date.

(ii) The permitting authority will review and approve or disapprove a proposed plan, or request changes to a plan,

based on whether the plan contains sufficient provisions to ensure continuing compliance with applicable

emission limits and demonstrates, based on documented test results, the relationship between emissions of

PM, HCl, and D/F and the proposed monitoring parameters for each pollutant. Test data must establish the

highest level of PM, HCl, and D/F that will be emitted from the furnace. Subject to permitting agency approval of

the OM&M plan, this may be determined by conducting performance tests and monitoring operating parameters

while charging the furnace with feed/charge materials containing the highest anticipated levels of oils and

coatings and fluxing at the highest anticipated rate.

Each site-specific monitoring plan must document each work practice, equipment/design practice, pollution

prevention practice, or other measure used to meet the applicable emission standards.

Each site-specific monitoring plan must include provisions for unit labeling as required in paragraph (c) of

63.1510, feed/charge weight measurement (or production weight measurement) as required in paragraph (e) of

this section and flux weight measurement as required in paragraph

8.

Terms and Conditions for Emissions Units

Title V Final Permit Page 127
21

8

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Each site-specific monitoring plan for a melting/holding furnace subject to the clean charge emission standard in

63.1505(i)(3) must include these requirements:

(i) The owner or operator must record the type of feed/ charge (e.g., ingot, thermally dried chips, dried scrap,

etc.) for each operating cycle or time period used in the performance test; and

(ii) The owner or operator must submit a certification of compliance with the applicable operational standard for

clean charge materials in 63.1506(n)(3) for each 6-month reporting period. Each certification must contain the

information in 63.1516(b)(2)(iv).

If a continuous emission monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of the general provisions in subpart A of this part.

If a continuous opacity monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of this subpart.

If a site-specific monitoring plan includes a scrap inspection program for monitoring the scrap contaminant level

of furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of

the program in accordance with all applicable requirements in paragraph (p) of 63.1510.

If a site-specific monitoring plan includes a calculation method for monitoring the scrap contaminant level of

furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of the

program in accordance with all applicable requirements in paragraph (q) of this section.

[40 CFR 63.1510(p)(1) through (6)]

A scrap inspection program must include:

A proven method for collecting representative samples and measuring the oil and coatings content of scrap

samples;

A scrap inspector training program;

An established correlation between visual inspection and physical measurement of oil and coatings content of

scrap samples;

Periodic physical measurements of oil and coatings content of randomly-selected scrap samples and

comparison with visual inspection results;

A system for assuring that only acceptable scrap is charged to an affected group 1 furnace; and

Recordkeeping requirements to document conformance with plan requirements.

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 128
21

9

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(q)(1) through (3)]

The owner or operator of a group 1 furnace dedicated to processing a distinct type of furnace feed/charge

composed of scrap with a uniform composition (such as rejected product from a manufacturing process for which

the coating-to-scrap ratio can be documented) may include a program in the site-specific monitoring plan for

determining, monitoring, and certifying the scrap contaminant level using a calculation method rather than a

scrap inspection program. A scrap contaminant monitoring program using a calculation method must include:

Procedures for the characterization and documentation of the contaminant level of the scrap prior to the

performance test.

Limitations on the furnace feed/charge to scrap of the same composition as that used in the performance test. If

the performance test was conducted with a mixture of scrap and clean charge, limitations on the proportion of

scrap in the furnace feed/charge to no greater than the proportion used during the performance test.

Operating, monitoring, recordkeeping, and reporting requirements to ensure that no scrap with a contaminant

level higher than that used in the performance test is charged to the furnace.

10.

[40 CFR 63.1510(s)(1) through (3)]

An owner or operator of a secondary aluminum processing unit at a facility must include, within the OM&M plan

prepared in accordance with 63.1510(b), the following information:

(i) The identification of each emission unit in the secondary aluminum processing unit;

(ii) The specific control technology or pollution prevention measure to be used for each emission unit in the

secondary aluminum processing unit and the date of its installation or application;

(iii) The emission limit calculated for each secondary aluminum processing unit and performance test results

with supporting calculations demonstrating initial compliance with each applicable emission limit;

(iv) Information and data demonstrating compliance for each emission unit with all applicable design, equipment,

work practice or operational standards of this subpart; and

(v) The monitoring requirements applicable to each emission unit in a secondary aluminum processing unit and

the monitoring procedures for daily calculation of the 3-day, 24-hour rolling average using the procedure in

63.1510(t).

The SAPU compliance procedures within the OM&M plan may not contain any of the following provisions:

(i) Any averaging among emissions of differing pollutants;

(ii) The inclusion of any affected sources other than emission units in a secondary aluminum processing unit;

(iii) The inclusion of any emission unit while it is shutdown; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction in emission calculations.

To revise the SAPU compliance provisions within the OM&M plan prior to the end of the permit term, the owner

or operator must submit a request to the applicable permitting authority containing the information required by

paragraph (s)(1) of this section and obtain approval of the applicable permitting authority prior to implementing

any revisions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 129
21

10 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(t)(1) through (5)]

Except as provided in paragraph (u) of this section, the owner or operator must calculate and record the 3-day,

24-hour rolling average emissions of PM, HCl, and D/F for each secondary aluminum processing unit on a daily

basis. To calculate the 3-day, 24-hour rolling average, the owner or operator must:

Calculate and record the total weight of material charged to each emission unit in the secondary aluminum

processing unit for each 24-hour day of operation using the feed/charge weight information required in paragraph

(e) of this section. If the owner or operator chooses to comply on the basis of weight of aluminum produced by

the emission unit, rather than weight of material charged to the emission unit, all performance test emissions

results and all calculations must be conducted on the aluminum production weight basis.

Multiply the total feed/charge weight to the emission unit, or the weight of aluminum produced by the emission

unit, for each emission unit for the 24-hour period by the emission rate (in lb/ton of feed/charge) for that emission

unit (as determined during the performance test) to provide emissions for each emission unit for the 24-hour

period, in pounds.

Divide the total emissions for each SAPU for the 24-hour period by the total material charged to the SAPU, or

the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the

SAPU.

12.

Compute the 24-hour daily emission rate using Equation 4:

Eday~=~{sum from {i=1} to n (Ti x ERi)} OVER {sum from {i=1} to n Ti}

Where,

Eday = The daily PM, HCl, or D/F emission rate for the secondary aluminum processing unit for the

24-hour period;

Ti = The total amount of feed, or aluminum produced, for emission unit i for the 24-hour period (tons);

ERi = The measured emission rate for emission unit i as determined in the performance test (lb/ton or g/Mg

of feed/charge); and

n = The number of emission units in the secondary aluminum processing unit.

Calculate and record the 3-day, 24-hour rolling average for each pollutant each day by summing the daily

emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3.

[40 CFR 63.1510(u)]

As an alternative to the procedures of paragraph (t) of this section, an owner or operator may demonstrate,

through performance tests, that each individual emission unit within the secondary aluminum production unit is in

compliance with the applicable emission limits for the emission unit.

13.

[40 CFR 63.1517(a)(1) through (3)]

As required by 63.10(b), the owner or operator shall maintain files of all information (including all reports and

notifications) required by the general provisions and this subpart.

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 off site.

The owner or operator may retain records on microfilm, computer disks, magnetic tape, or microfiche; and

The owner or operator may report required information on paper or on a labeled computer disk using commonly

available and EPA-compatible computer software.

14.

Terms and Conditions for Emissions Units

Title V Final Permit Page 130
21

11 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1517(b)]

In addition to the general records required by

63.10(b), the owner or operator of a new or existing affected source (including an emission unit in a secondary

aluminum processing unit) must maintain records of:

For each group 1 furnace (with or without add-on air pollution control devices) or in-line fluxer, records of

15-minute block average weights of gaseous or liquid reactive flux injection, total reactive flux injection rate and

calculations (including records of the identity, composition, and weight of each addition of gaseous, liquid or

solid reactive flux), including records of any period the rate exceeds the compliant operating parameter value and

corrective action taken.

For each affected source and emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge,

records of feed/charge (or throughput) weights for each operating cycle or time period used in the performance

test.

Approved site-specific monitoring plan for a group 1 furnace without add-on air pollution control devices with

records documenting conformance with the plan.

Records of all charge materials for each thermal chip dryer, dross-only furnace, and group 1 melting/holding

furnaces without air pollution control devices processing only clean charge.

15.

Records of monthly inspections for proper unit labeling for each affected source and emission unit subject to

labeling requirements.

Records for any approved alternative monitoring or test procedure.

Current copy of all required plans, including any revisions, with records documenting conformance with the

applicable plan, including:

(i) Startup, shutdown, and malfunction plan;

(ii) For major sources, OM&M plan; and

(iii) Site-specific secondary aluminum processing unit emission plan (if applicable).

For each secondary aluminum processing unit, records of total charge weight, or if the owner or operator

chooses to comply on the basis of aluminum production, total aluminum produced for each 24-hour period and

calculations of 3-day, 24-hour rolling average emissions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 131
21

12 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.1515(b)(1) through (4), (9) and (10)]

Each owner or operator must submit a notification of compliance status report within 60 days after the

compliance dates specified in 63.1501. The notification must be signed by the responsible official who must

certify its accuracy. A complete notification of compliance status report must include the information specified

in paragraphs (a)(1) through (10) of 63.1515. The required information may be submitted in an operating permit

application, in an amendment to an operating permit application, in a separate submittal, or in any combination.

In a State with an approved operating permit program where delegation of authority under section 112(l) of the

CAA has not been requested or approved, the owner or operator must provide duplicate notification to the

applicable Regional Administrator. If an owner or operator submits the information specified in this section at

different times or in different submittals, later submittals may refer to earlier submittals instead of duplicating and

resubmitting the information previously submitted. A complete notification of compliance status report must

include:

All information required in 63.9(h). The owner or operator must provide a complete performance test report for

each affected source and emission unit for which a performance test is required. A complete performance test

report includes all data, associated measurements, and calculations (including visible emission and opacity

tests).

The approved site-specific test plan and performance evaluation test results for each continuous monitoring

system (including a continuous emission or opacity monitoring system).

Unit labeling as described in 63.1506(b), including process type or furnace classification and

operating requirements.

2.

The compliant operating parameter value or range established for each affected source or emission unit with

supporting documentation and a description of the procedure used to establish the value (e.g., lime injection

rate, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet temperature),

including the operating cycle or time period used in the performance test.

Approved OM&M plan (including site-specific monitoring plan for each group 1 furnace with no add-on air

pollution control device).

Startup, shutdown, and malfunction plan, with revisions.

[40 CFR 63.1516(a)(1) through (3)]

The owner or operator must develop and implement a written plan as described in 63.6(e)(3) that contains

specific procedures to be followed for operating and maintaining the source during periods of startup, shutdown,

and malfunction, and a program of corrective action for malfunctioning process and air pollution control

equipment used to comply with the standard. The owner or operator shall also keep records of each event as

required by 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 63.6(e)(3). In addition to the information required in

63.6(e)(3), the plan must include:

Procedures to determine and record the cause of the malfunction and the time the malfunction began and ended;

and

Corrective actions to be taken in the event of a malfunction of a process or control device, including procedures

for recording the actions taken to correct the malfunction or minimize emissions.

3.

Terms and Conditions for Emissions Units

Title V Final Permit Page 132
21

13 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

As required by 63.10(e)(3), the owner or operator must submit semiannual reports within 60 days after the end of

each 6-month period. Each report must contain the information specified in 63.10(c). When no deviations of

parameters have occurred, the owner or operator must submit a report stating that no excess emissions

occurred during the reporting period.

A report must be submitted if any of these conditions occur during a 6-month reporting period:

(i) An excursion of a compliant process or operating parameter value or range (e.g., lime injection rate or screw

feeder setting, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet

temperature, definition of acceptable scrap, or other approved operating parameter).

(ii) An action taken during a startup, shutdown, or malfunction was not consistent with the procedures in the plan

as described in 63.6(e)(3).

(iii) An affected source (including an emission unit in a secondary aluminum processing unit) was not operated

according to the requirements of this subpart.

(iv) A deviation from the 3-day, 24-hour rolling average emission limit for a secondary aluminum processing unit.

Each report must include this certification: For each group 1 melting/holding furnace without add-on air pollution

control devices and using pollution prevention measures that processes only clean charge material: "Each group

1 furnace without add-on air pollution control devices subject to emission limits in 63.1505(i)(2) processed only

clean charge during this reporting period."

The owner or operator must submit the results of any performance test conducted during the reporting period,

including one complete report documenting test methods and procedures, process operation, and monitoring

parameter ranges or values for each test method used for a particular type of emission point tested.

[40 CFR 63.1516(c)]

For the purpose of annual certifications of compliance required by 40 CFR part 70 or 71, the owner or operator

must certify continuing compliance based upon, but not limited to, the following conditions:

Any period of excess emissions, as defined in paragraph (b)(1) of 63.1516, that occurred during the year were

reported as required by this subpart; and

All monitoring, recordkeeping, and reporting requirements were met during the year.

4.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 133
21

14 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

1.0 pound per hour of particulate emissions

Applicable Compliance Method:

There are two possible sources of particulate emissions from this emissions unit: (1) combustion products from

natural gas firing, and (2) particulate emissions from the degassing operation, in relation to the chlorine

component.

Particulate emissions from gas firing may be calculated by using the emission factor of 1.9 lbs of

particulate/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

mmcf gas/day x 1.9 lbs/mmcf = (lb/day)/24 = lb/hr particulate emissions.

1.b

Particulate emissions from the degassing operation will be generated only during the production of alloy products

containing little or no magnesium. These alloys comprise no more than 10% of the maximum production rate of

540,000 lbs/day or 54,000 lbs/day.

The purpose for the chlorine component in the degassing process is to remove hydrogen from the metal.

Chlorine will chemically combine with hydrogen, and with magnesium and aluminum to form dross. The amount

of chloride components in the dross depends on the total volume of chlorine available less that amount which

combines with hydrogen. At the maximum production rates mentioned above, the chlorine component of the

degassing agent will be 72.4 lbs/day. As is shown in section A.V.7 below, 1.6 lbs/day of chlorine will be used to

form HCl leaving 70.8 lbs/day available for chloride components of dross. During the production of alloyed

aluminum products with little or no magnesium alloy, some percentage of the AlCl3 can be emitted as

particulates with the balance forming the chloride components of dross.

If we assume, however, that all of the AlCl3 generated in this case would be emitted as particulates and the

alloyed aluminum products with little or no magnesium comprise a maximum of 10% of the metal production, the

particulate emission rate at maximum production would be:

2 Al + 3 Cl2 --- 2 AlCl3

3 (35.5 x 2)/ 70.8 lbs/day x 10% = ( 2 (26) + 2 (3 x 35.5))/x

x = 8.8 lbs/day of AlCl3 particulate

or 0.37 lb/hr particulate emissions from the degassing operation.

Thus, the total particulate emission rate from this emissions unit is shown as follows:

lb/hr particulate emissions from gas firing + 0.37 lb/hr particulate emissions from degassing = total lb/hr

particulate emissions from this emissions unit.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 134
21

15 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

0.05 pound per hour of sulfur dioxide emissions

Applicable Compliance Method:

Sulfur dioxide emissions from gas firing may be calculated by using the emission factor of 0.6 lb of sulfur

dioxide/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and the monitoring

and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 0.6 lb/mmcf) / (hours of operation/day) = lb/hr of sulfur dioxide emissions.

If required, compliance with the above emission limitationt shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 6.

1.c

Emission Limitation:

0.24 pound per hour of organic compound emissions

Applicable Compliance Method:

Organic compound emissions from gas firing may be calculated by using the emission factor of 5.5 lbs of

organic compounds/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and

the monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 5.5 lb/mmcf) / (hours of operation/day) = lb/hr of organic compound emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 18, 25, or 25A, as appropriate.

1.d

Emission Limitation:

11.13 pounds per hour of nitrogen oxides emissions

Applicable Compliance Method:

Nitrogen oxides emissions from this emissions unit may be calculated by using the emission factor of 100 lbs of

nitrogen oxides/mmcf of natural gas from AP-42 Table 1.4-1, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 100 lb/mmcf) / (hours of operation/day) = lb/hr NOx emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 7.

1.e

Terms and Conditions for Emissions Units

Title V Final Permit Page 135
21

16 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

2.75 pounds per hour of carbon monoxide

Applicable Compliance Method:

Carbon monoxide emissions from this emissions unit may be calculated by using the emission factor of 84 lbs of

carbon monoxde/mmcf of natural gas from AP-42 Table 1.4-1, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 84 lb/mmcf) / (hours of operation/day) = lb/hr CO emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 10.

1.f

Emission Limitation:

0.33 mg per cubic meter of hydrogen chloride emissions

Applicable Compliance Method:

As stated in section A.V.2.b, the addition of chlorine as a component of the degassing agent is for the removal of

hydrogen from the molten aluminum. The inert argon component helps to extend the active agent chlorine

through the molten metal to improve the efficacy of the chlorine addition. Molten aluminum normally contains

0.25cc of hydrogen per 100 grams of aluminum. Chlorine is added to reduce the ratio to 0.15cc per 100 grams

of metal. This reduction generates HCl emissions as described below:

At the maximum production rate, the following amount of hydrogen is removed:

540,000 lbs/day x 453.7 gm/lb x 0.10cc H2/100 gms Al = 244,998 cc/day or 245 liters H2/day. This removal

results in the following maximum HCl emission rate:

H2 + Cl2 --- 2HCl

245 liters/day of H2 will stoichiometrically form

490 liters/day of HCl, and

490 liters/day x 1.64 g/liter (density HCl)= 803.6 gm/day = 1.77 lbs/day

1.g

NOTE: Based on the above, 245 liters/day Cl, or 1.62 lbs/day Cl, is used to remove the hydrogen from the metal

as follows: 245 liters/day Cl / 28.32 liters/cf = 8.65 cf/day x 0.183 lb/cf = 1.6 lbs/day. The remaining Cl

combines to form dross components or potential AlCl3 particulate as described in section A.V.2.b above.

Per Ohio EPA's policy for the control of toxic air emissions during new source review, the maximum acceptable

ground level concentration (MAGLC) is calculated as follows:

The threshold limit value (TLV) for HCl has been determined to be 7 mg/cm.

This unit is a batch type operation with 4 hours per batch and 6 batches/day, therefore, degassing requirements

are 2 hours per batch x 6 batches/day = 12 hours/day.

MAGLC = 4 TLV/x y (x = hrs/day, y = days/wk)

MAGLC = 4 (7 mg/cm)/(12 x 7) = 0.33 mg/cm

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 26.

Terms and Conditions for Emissions Units

Title V Final Permit Page 136
21

17 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(a)]

Prior to conducting a performance test required by this subpart, the owner or operator must prepare and submit a

site-specific test plan meeting the requirements in 63.7(c).

2.

[40 CFR 63.1511(b)]

Following approval of the site-specific test plan, the owner or operator must demonstrate initial compliance with

each applicable emission, equipment, work practice, or operational standard for each affected source and

emission unit, and report the results in the notification of compliance status report as described in 63.1515(b).

The owner or operator must conduct each performance test according to the requirements of the general

provisions in subpart A of this part and this subpart. Owners or operators of affected sources located at facilities

which are area sources are subject only to those performance testing requirements pertaining to D/F. Owners or

operators of sweat furnaces meeting the specifications of 63.1505(f)(1) are not required to conduct a performance

test.

The owner or operator must conduct each test while the affected source or emission unit is operating at the

highest production level with charge materials representative of the range of materials processed by the unit and,

if applicable, at the highest reactive fluxing rate.

3.

[40 CFR 63.1511(c)]

The owner or operator must use the following methods in appendix A to 40 CFR part 60 to determine compliance

with the applicable emission limits or standards:

Method 1 for sample and velocity traverses.

Method 2 for velocity and volumetric flow rate.

Method 3 for gas analysis.

Method 4 for moisture content of the stack gas.

Method 5 for the concentration of PM.

Method 9 for visible emission observations.

Method 26A for the concentration of HCl. Where a lime-injected fabric filter is used as the control device to

comply with the 90 percent reduction standard, the owner or operator must measure the fabric filter inlet

concentration of HCl at a point before lime is introduced to the system.

4.

[40 CFR 63.1511(d)]

The owner or operator may use an alternative test method, subject to approval by the Administrator.

5.

[40 CFR 63.1511(e)]

The owner or operator of new or existing affected sources and emission units located at secondary aluminum

production facilities that are major sources must conduct a performance test every 5 years following the initial

performance test.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 137
21

18 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(f)(1) through (6)]

With the approval of the permitting authority, a single representative or similar group 1 furnace or in-line fluxer

which is not controlled by an add-on control device may be tested to determine the emission rate of all like

affected sources at a facility provided that:

The tested emission unit must use identical feed/charge and flux materials in the same proportions as the

emission units that it represents;

The tested emission unit is subject to the same work practices and the emission units that it represents;

The tested emission unit is of the same design as the emission units that it represents;

The tested emission unit is tested under the highest load or capacity reasonably expected to occur for any of the

emission units that it represents;

At least one of each different style of emission unit at the facility is tested; and

All add-on control devices are tested.

7.

[40 CFR 63.1511(g)(1) through (4)]

The owner or operator of new or existing affected sources and emission units must establish a minimum or

maximum operating parameter value, or an operating parameter range for each parameter to be monitored as

required by 63.1510 that ensures compliance with the applicable emission limit or standard. To establish the

minimum or maximum value or range, the owner or operator must use the appropriate procedures in this section

and submit the information required by 63.1515(b)(4) in the notification of compliance status report. The owner or

operator may use existing data in addition to the results of performance tests to establish operating parameter

values for compliance monitoring provided each of the following conditions are met to the satisfaction of the

applicable permitting authority:

The complete emission test report(s) used as the basis of the parameter(s) is submitted.

The same test methods and procedures as required by Subpart RRR were used in the test.

The owner or operator certifies that no design or work practice changes have been made to the source, process,

or emission control equipment since the time of the report.

All process and control equipment operating parameters required to be monitored were monitored as required in

this subpart and documented in the test report.

8.

[40 CFR 63.1512(e)(2) and (3)]

In the site-specific monitoring plan required by 63.1510(o), the owner or operator of a group 1 furnace (including a

melting/holding furnaces) without add-on air pollution control devices must include data and information

demonstrating compliance with the applicable emission limits.

If the group 1 furnace processes only clean charge, the owner or operator must conduct emission tests to

simultaneously measure emissions of PM and HCl at the furnace exhaust outlet. A D/F test is not required.

Each test must be conducted while the group 1 furnace (including a melting/holding furnace) processes only

clean charge.

The owner or operator may choose to determine the rate of reactive flux addition to the group 1 furnace and

assume, for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added

to the group 1 furnace is emitted. Under these circumstances, the owner or operator is not required to conduct

an emission test for HCl.

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 138
21

19 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(h)(1) and (2)]

The owner or operator must conduct a performance test to measure emissions of HCl and PM. If the in-line

fluxer is equipped with an add-on control device, the emissions must be measured at the outlet of the control

device. If the in-line fluxer uses no reactive flux materials, emission tests for PM and HCl are not required.

The owner or operator may choose to determine the rate of reactive flux addition to the in-line fluxer and assume,

for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added to the

in-line fluxer is emitted. Under these circumstances, the owner or operator is not required to conduct an

emission test for HCl.

10.

[40 CFR 63.1512(j)(1) and (3)]

The owner or operator must conduct performance tests as described in paragraphs (j)(1) through (3) of this

section. The results of the performance tests are used to establish emission rates in lb/ton of feed/charge for

PM and HCl and g TEQ/Mg of feed/charge for D/F emissions from each emission unit. These emission rates

are used for compliance monitoring in the calculation of the 3-day, 24-hour rolling average emission rates using

the equation in 63.1510(t). A performance test is required for:

Each group 1 furnace processing only clean charge to measure emissions of PM and either:

(i) Emissions of HCl (for the emission limit); or

(ii) The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

Each in-line fluxer to measure emissions of PM and HCl.

11.

[40 CFR 63.1512(k)]

During the emission test(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format,

the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of

feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the

affected source or emission unit for each of the three test runs and calculate and record the total weight. An

owner or operator that chooses to demonstrate compliance on the basis of the aluminum production weight must

measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge

weight.

12.

Terms and Conditions for Emissions Units

Title V Final Permit Page 139
21

20 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(o)(1) through (3)]

The owner or operator must use these procedures to establish an operating parameter value or range for the total

reactive chlorine flux injection rate.

Continuously measure and record the weight of gaseous or liquid reactive flux injected for each 15 minute period

during the HCl and D/F tests, determine and record the 15-minute block average weights, and calculate and

record the total weight of the gaseous or liquid reactive flux for the 3 test runs;

Record the identity, composition, and total weight of each addition of solid reactive flux for the 3 test runs;

Determine the total reactive chlorine flux injection rate by adding the recorded measurement of the total weight of

chlorine in the gaseous or liquid reactive flux injected and the total weight of chlorine in the solid reactive flux

using this equation:

Wt = F1W1 + F2W2

Where,

Wt = Total chlorine usage, by weight;

F1 = Fraction of gaseous or liquid flux that is chlorine;

W1 = Weight of reactive flux gas injected;

F2 = Fraction of solid reactive chloride flux that is chlorine (e.g., F = 0.75 for magnesium chloride; and

W2 = Weight of solid reactive flux;

Divide the weight of total chlorine usage (Wt) for the 3 test runs by the recorded measurement of the total weight

of feed for the 3 test runs; and

If a solid reactive flux other than magnesium chloride is used, the owner or operator must derive the appropriate

proportion factor subject to approval by the applicable permitting authority.

13.

[40 CFR 63.1513(b)]

Use this equation to determine compliance with an emission limit for PM, HCl, and D/F:

E = {C x Q x K1} / P

Where,

E = Emission rate of PM, HCl, or D/F, kg/Mg (lb/ton) of feed;

C = Concentration of PM, HCl, or D/F, g/dscm (gr/dscf);

Q = Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr);

K1 = Conversion factor, 1 kg/1,000 g (1 lb/7,000 gr); and

P = Production rate, Mg/hr (ton/hr).

14.

Terms and Conditions for Emissions Units

Title V Final Permit Page 140
21

21 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1513(e)(1) and (2)]

Use the procedures in paragraphs (e)(1) and (2) to determine compliance with emission limits for a secondary

aluminum processing unit.

Use this equation to compute the mass-weighted PM emissions for a secondary aluminum processing unit.

Compliance is achieved if the mass-weighted emissions for the secondary aluminum processing unit (EcPM) is

less than or equal to the emission limit for the secondary aluminum processing unit (LcPM) calculated using

Equation 1 in 63.1505(k).

EcPM = {sum from {i=1} to n (EtiPM times Tti)} over {sum from {i=1} to n (Tti)}

Where,

EcPM = The mass-weighted PM emissions for the secondary aluminum processing unit;

EtiPM = Measured PM emissions for individual emission unit i;

Tti = The average feed rate for individual emission unit i during the operating cycle or performance test period; and

n = The number of emission units in the secondary aluminum processing unit.

Use this equation to compute the aluminum mass-weighted HCl emissions for the secondary aluminum

processing unit. Compliance is achieved if the mass-weighted emissions for the secondary aluminum

processing unit (EcHCl) is less than or equal to the emission limit for the secondary aluminum processing unit

(LcHCl) calculated using Equation 2 in 63.1505(k).

EcHCl = {sum from {i=1} to n (EtiHCl times Tti)} over {sum from {i=1} to n ( Tti)}

Where,

EcHCl = The mass-weighted HCl emissions for the secondary aluminum processing unit; and

EtiHCl = Measured HCl emissions for individual emission unit i.

As an alternative to using the equations in paragraphs (e)(1) and (2) of this section, the owner or operator may

demonstrate compliance for a secondary aluminum processing unit by demonstrating that each existing group 1

furnace is in compliance with the emission limits for a new group 1 furnace in 63.1505(i) and that each existing

in-line fluxer is in compliance with the emission limits for a new in-line fluxer in 63.1505(j).

15.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 141
1

1

Direct Chill Casting Pit No. 3 (P233)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 142
21

1

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Direct Chill Casting Pit No. 1 (P235)

Direct Chill Casting Pit No. 1

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

direct chill casting pit no. 1 OAC rule 3745-31-05(A)(3)

(PTI 17-838)

This emissions unit is limited to:

1.5 pounds per hour of particulate

emissions

0.05 pound per hour of sulfur dixoide

emissions

0.24 pound per hour of organic

compound emissions

11.13 pounds per hour of nitrogen

oxides emissions

2.75 pounds per hour of carbon

monoxide emissions

0.33 mg per cubic meter of hydrogen

chloride emissions

See section A.I.2.a.

471868 471868

OAC rule 3745-17-07(A) The emission limitations specified by

this rule are less stringent than the

emission limitations established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-17-11 The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 143
21

2

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a There shall be no visible emissions during charging, slagging, and pouring activities.

There shall be no visible emissions from the melting, holding, and homogenizing stacks.

2.b [40 CFR 63.1505(i)]

The owner or operator of a group 1 furnace must use the limits in this paragraph to determine the emission

standards for a SAPU.

0.40 kg of PM per Mg (0.80 lb of PM per ton) of feed/charge from a group 1 melting/holding furnace

processing only clean charge at a secondary aluminum production facility that is a major source; and

0.20 kg of HCl per Mg (0.40 lb of HCl per ton) of feed/charge or, if the furnace is equipped with an add-on air

pollution control device, 10 percent of the uncontrolled HCl emissions, by weight, for a group 1 furnace at a

secondary aluminum production facility that is a major source.

The owner or operator may determine the emission standards for a SAPU by applying the group 1 furnace

limits on the basis of the aluminum production weight in each group 1 furnace, rather than on the basis of

feed/charge.

2.c [40 CFR 63.1505(j)]

Except as provided in paragraph (j)(3) of 63.1505 for an in-line fluxer using no reactive flux material, the owner

or operator of an in-line fluxer must use the limits in this paragraph to determine the emission standards for a

SAPU.

0.02 kg of HCl per Mg (0.04 lb of HCl per ton) of feed/charge; and

0.005 kg of PM per Mg (0.01 lb of PM per ton) of feed/charge.

The owner or operator may determine the emission standards for a SAPU by applying the in-line fluxer limits

on the basis of the aluminum production weight in each in-line fluxer, rather than on the basis of feed/charge.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-18-06 The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

40 CFR Part 63.1505

(Subpart RRR)

471868 471868 See A.I.2.b through A.I.2.d below.

Terms and Conditions for Emissions Units

Title V Final Permit Page 144
21

3

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.d [40 CFR 63.1505(k)(1) through (3)]

On and after the date of approval of the operation, maintenance and monitoring (OM&M) plan, the owner or

operator must comply with the emission limits calculated using the equations for PM and HCl in paragraphs

(k)(1) and (k)(2) of 63.1505 for each secondary aluminum processing unit at a secondary aluminum

production facility that is a major source. The owner or operator must comply with the emission limit

calculated using the equation for D/F in paragraph (k)(3) of 63.1505 for each secondary aluminum processing

unit at a secondary aluminum production facility that is a major or area source.

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of PM in excess of:

LcPM = {sum from {i=1} to n (LtiPM times Tti)} over {sum from {i=1} to n (Tti)}

Where,

LtiPM = The PM emission limit for individual emission unit i in paragraph (i)(1) and (2) of 63.1505 for a group

1 furnace or in paragraph (j)(2) of 63.1505 for an in-line fluxer;

Tti = The feed/charge rate for individual emission unit I; and

LcPM = The PM emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the PM limit.

The owner or operator must not discharge or allow to be discharged to the atmosphere any 3-day, 24-hour

rolling average emissions of HCl in excess of:

LcHCl = {sum from {i=1} to n (LtiHCl times Tti)} over {sum from {i=1} to n ( Tti)}

Where,

LtiHCl = The HCl emission limit for individual emission unit i in paragraph (i)(4) of 63.1505 for a group 1

furnace or in paragraph (j)(1) of 63.1505 for an in-line fluxer; and

LcHCl = The HCl emission limit for the secondary aluminum processing unit.

NOTE: In-line fluxers using no reactive flux materials cannot be included in this calculation since they are

not subject to the HCl limit.

The owner or operator of a SAPU at a secondary aluminum production facility that is a major source may

demonstrate compliance with the emission limits of paragraphs (k)(1) through (3) of 63.1505 by

demonstrating that each emission unit within the SAPU is in compliance with the applicable emission limits

of paragraphs (i) and (j) of 63.1505.

II. Operational Restrictions

[40 CFR 63.1506(a)(1) and (2)]

On and after the date on which the initial performance test is conducted or required to be conducted, whichever

date is earlier, the owner or operator must operate all new and existing affected sources and control equipment

according to the requirements in this section.

The completion of the initial performance tests for SAPUs shall be considered to be the date of approval of the

OM&M plan by the permitting authority.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 145
21

4

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.1506(b)(1) and (2)]

The owner or operator must provide and maintain easily visible labels posted at each group 1 furnace, group 2

furnace, in-line fluxer and scrap dryer/delacquering kiln/decoating kiln that identifies the applicable emission

limits and means of compliance, including:

The type of affected source or emission unit (e.g., scrap dryer/delacquering kiln/decoating kiln, group 1 furnace,

group 2 furnace, in-line fluxer).

The applicable operational standard(s) and control method(s) (work practice or control device). This includes, but

is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux materials

and addition practices, and the applicable operating parameter ranges and requirements as incorporated in the

OM&M plan.

2.

[40 CFR 63.1506(d)(1) through (3)]

The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of

feed/charge must:

Except as provided in paragraph (d)(3) of 63.1506, install and operate a device that measures and records or

otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the

performance test; and

Operate each weight measurement system or other weight determination procedure in accordance with the

OM&M plan.

The owner or operator may chose to measure and record aluminum production weight from an affected source or

emission unit rather than feed/charge weight to an affected source or emission unit, provided that:

(i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission

units within a SAPU; and

(ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum

production weight rather than feed/charge weight.

3.

[40 CFR 63.1506(n)(1) through (3)]

The owner or operator of a group 1 furnace (including a group 1 furnace that is part of a secondary aluminum

processing unit) without add-on air pollution control devices must:

Maintain the total reactive chlorine flux injection rate for each operating cycle or time period used in the

performance test at or below the average rate established during the performance test.

Operate each furnace in accordance with the work practice/pollution prevention measures documented in the

OM&M plan and within the parameter values or ranges established in the OM&M plan.

Operate each group 1 melting/holding furnace subject to the emission standards in 63.1505(i)(2) using only clean

charge as the feedstock.

4.

[40 CFR 63.1506(p)]

When a process parameter or add-on air pollution control device operating parameter deviates from the value or

range established during the performance test and incorporated in the OM&M plan, the owner or operator must

initiate corrective action. Corrective action must restore operation of the affected source or emission unit

(including the process or control device) to its normal or usual mode of operation as expeditiously as practicable

in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must

include follow-up actions necessary to return the process or control device parameter level(s) to the value or

range of values established during the performance test and steps to prevent the likely recurrence of the cause of

a deviation.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 146
21

5

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

The permittee shall maintain records of the following information:

a. the natural gas usage for each day;

b. the production rate, in pounds of aluminum per day; and

c. the hours of operation.

2.

[40 CFR 63.1510(a)]

On and after the date the initial performance test is completed or required to be completed, whichever date is

earlier, the owner or operator of a new or existing affected source or emission unit must monitor all control

equipment and processes according to the requirements in this section. Monitoring requirements for each type

of affected source and emission unit are summarized in Table 3 to Subpart RRR.

3.

[40 CFR 63.1510(b)(1) through (8)]

The owner or operator must prepare and implement for each new or existing affected source and emission unit, a

written operation, maintenance, and monitoring (OM&M) plan. The owner or operator must submit the plan to

the applicable permitting authority for review and approval as part of the application for a part 70 or part 71 permit.

Any subsequent changes to the plan must be submitted to the applicable permitting authority for review and

approval. Pending approval by the applicable permitting authority of an initial or amended plan, the owner or

operator must comply with the provisions of the submitted plan. Each plan must contain the following

information:

Process and control device parameters to be monitored to determine compliance, along with established

operating levels or ranges, as applicable, for each process and control device.

A monitoring schedule for each affected source and emission unit.

Procedures for the proper operation and maintenance of each process unit and add-on control device used to

meet the applicable emission limits or standards in 63.1505.

4.

Terms and Conditions for Emissions Units

Title V Final Permit Page 147
21

6

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Procedures for the proper operation and maintenance of monitoring devices or systems used to determine

compliance, including:

(i) Calibration and certification of accuracy of each monitoring device, at least once every 6 months, according to

the manufacturer's instructions; and

(ii) Procedures for the quality control and quality assurance of continuous emission or opacity monitoring

systems as required by the general provisions in subpart A of this part.

Procedures for monitoring process and control device parameters, including procedures for annual inspections of

afterburners, and if applicable, the procedure to be used for determining charge/feed (or throughput) weight if a

measurement device is not used.

Corrective actions to be taken when process or operating parameters or add-on control device parameters

deviate from the value or range established in paragraph (b)(1) of 63.1510, including:

(i) Procedures to determine and record the cause of an deviation or excursion, and the time the deviation or

excursion began and ended; and

(ii) Procedures for recording the corrective action taken, the time corrective action was initiated, and the

time/date corrective action was completed.

A maintenance schedule for each process and control device that is consistent with the manufacturer's

instructions and recommendations for routine and long-term maintenance.

Documentation of the work practice and pollution prevention measures used to achieve compliance with the

applicable emission limits and a site-specific monitoring plan as required in paragraph (o) of 63.1510 for each

group 1 furnace not equipped with an add-on air pollution control device.

[40 CFR 63.1510(c)]

The owner or operator must inspect the labels for each group 1 furnace, group 2 furnace, in-line fluxer and scrap

dryer/delacquering kiln/decoating kiln at least once per calendar month to confirm that posted labels as required

by the operational standard in 63.1506(b) are intact and legible.

5.

[40 CFR 63.1510(e)(1) and (2)]

The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or

g/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the

total weight of feed/charge to, or the aluminum production from, the affected source or emission unit over the

same operating cycle or time period used in the performance test. Feed/charge or aluminum production within

SAPUs must be measured and recorded on an emission unit-by-emission unit basis. As an alternative to a

measurement device, the owner or operator may use a procedure acceptable to the applicable permitting

authority to determine the total weight of feed/charge or aluminum production to the affected source or emission

unit.

The accuracy of the weight measurement device or procedure must be +1 percent of the weight being measured.

The owner or operator may apply to the permitting agency for approval to use a device of alternative accuracy if

the required accuracy cannot be achieved as a result of equipment layout or charging practices. A device of

alternative accuracy will not be approved unless the owner or operator provides assurance through data and

information that the affected source will meet the relevant emission standard.

The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 148
21

7

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(j)(1) through (5)]

These requirements apply to the owner or operator of a group 1 furnace (with or without add-on air pollution

control devices) or in-line fluxer. The owner or operator must:

Install, calibrate, operate, and maintain a device to continuously measure and record the weight of gaseous or

liquid reactive flux injected to each affected source or emission unit.

(i) The monitoring system must record the weight for each 15-minute block period, during which reactive fluxing

occurs, over the same operating cycle or time period used in the performance test.

(ii) The accuracy of the weight measurement device must be +1 percent of the weight of the reactive component

of the flux being measured. The owner or operator may apply to the permitting authority for permission to use a

weight measurement device of alternative accuracy in cases where the reactive flux flow rates are so low as to

make the use of a weight measurement device of +1 percent impracticable. A device of alternative accuracy will

not be approved unless the owner or operator provides assurance through data and information that the affected

source will meet the relevant emission standards.

(iii) The owner or operator must verify the calibration of the weight measurement device in accordance with the

schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months.

Calculate and record the gaseous or liquid reactive flux injection rate (kg/Mg or lb/ton) for each operating cycle or

time period used in the performance test using the procedure in 63.1512(o).

Record, for each 15-minute block period during each operating cycle or time period used in the performance test

during which reactive fluxing occurs, the time, weight, and type of flux for each addition of:

(i) Gaseous or liquid reactive flux other than chlorine; and

(ii) Solid reactive flux.

7.

Calculate and record the total reactive flux injection rate for each operating cycle or time period used in the

performance test using the procedure in 63.1512(o).

The owner or operator of a group 1 furnace or in-line fluxer performing reactive fluxing may apply to the

Administrator for approval of an alternative method for monitoring and recording the total reactive flux addition rate

based on monitoring the weight or quantity of reactive flux per ton of feed/charge for each operating cycle or time

period used in the performance test. An alternative monitoring method will not be approved unless the owner or

operator provides assurance through data and information that the affected source will meet the relevant

emission standards on a continuous basis.

Terms and Conditions for Emissions Units

Title V Final Permit Page 149
21

8

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(o)(1) through (8)]

These requirements apply to the owner or operator of a group 1 furnace that is not equipped with an add-on air

pollution control device.

The owner or operator must develop, in consultation with the applicable permitting authority, a written

site-specific monitoring plan. The site-specific monitoring plan must be part of the OM&M plan that addresses

monitoring and compliance requirements for PM, HCl, and D/F emissions.

(i) The owner or operator of an existing affected source must submit the site-specific monitoring plan to the

applicable permitting authority for review at least 6 months prior to the compliance date.

(ii) The permitting authority will review and approve or disapprove a proposed plan, or request changes to a plan,

based on whether the plan contains sufficient provisions to ensure continuing compliance with applicable

emission limits and demonstrates, based on documented test results, the relationship between emissions of

PM, HCl, and D/F and the proposed monitoring parameters for each pollutant. Test data must establish the

highest level of PM, HCl, and D/F that will be emitted from the furnace. Subject to permitting agency approval of

the OM&M plan, this may be determined by conducting performance tests and monitoring operating parameters

while charging the furnace with feed/charge materials containing the highest anticipated levels of oils and

coatings and fluxing at the highest anticipated rate.

Each site-specific monitoring plan must document each work practice, equipment/design practice, pollution

prevention practice, or other measure used to meet the applicable emission standards.

Each site-specific monitoring plan must include provisions for unit labeling as required in paragraph (c) of

63.1510, feed/charge weight measurement (or production weight measurement) as required in paragraph (e) of

this section and flux weight measurement as required in paragraph

8.

Each site-specific monitoring plan for a melting/holding furnace subject to the clean charge emission standard in

63.1505(i)(3) must include these requirements:

(i) The owner or operator must record the type of feed/ charge (e.g., ingot, thermally dried chips, dried scrap,

etc.) for each operating cycle or time period used in the performance test; and

(ii) The owner or operator must submit a certification of compliance with the applicable operational standard for

clean charge materials in 63.1506(n)(3) for each 6-month reporting period. Each certification must contain the

information in 63.1516(b)(2)(iv).

If a continuous emission monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of the general provisions in subpart A of this part.

If a continuous opacity monitoring system is included in a site-specific monitoring plan, the plan must include

provisions for the installation, operation, and maintenance of the system to provide quality-assured

measurements in accordance with all applicable requirements of this subpart.

If a site-specific monitoring plan includes a scrap inspection program for monitoring the scrap contaminant level

of furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of

the program in accordance with all applicable requirements in paragraph (p) of 63.1510.

If a site-specific monitoring plan includes a calculation method for monitoring the scrap contaminant level of

furnace feed/charge materials, the plan must include provisions for the demonstration and implementation of the

program in accordance with all applicable requirements in paragraph (q) of this section.

Terms and Conditions for Emissions Units

Title V Final Permit Page 150
21

9

Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(p)(1) through (6)]

A scrap inspection program must include:

A proven method for collecting representative samples and measuring the oil and coatings content of scrap

samples;

A scrap inspector training program;

An established correlation between visual inspection and physical measurement of oil and coatings content of

scrap samples;

Periodic physical measurements of oil and coatings content of randomly-selected scrap samples and

comparison with visual inspection results;

A system for assuring that only acceptable scrap is charged to an affected group 1 furnace; and

Recordkeeping requirements to document conformance with plan requirements.

9.

[40 CFR 63.1510(q)(1) through (3)]

The owner or operator of a group 1 furnace dedicated to processing a distinct type of furnace feed/charge

composed of scrap with a uniform composition (such as rejected product from a manufacturing process for which

the coating-to-scrap ratio can be documented) may include a program in the site-specific monitoring plan for

determining, monitoring, and certifying the scrap contaminant level using a calculation method rather than a

scrap inspection program. A scrap contaminant monitoring program using a calculation method must include:

Procedures for the characterization and documentation of the contaminant level of the scrap prior to the

performance test.

Limitations on the furnace feed/charge to scrap of the same composition as that used in the performance test. If

the performance test was conducted with a mixture of scrap and clean charge, limitations on the proportion of

scrap in the furnace feed/charge to no greater than the proportion used during the performance test.

Operating, monitoring, recordkeeping, and reporting requirements to ensure that no scrap with a contaminant

level higher than that used in the performance test is charged to the furnace.

10.

Terms and Conditions for Emissions Units

Title V Final Permit Page 151
21

10 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.1510(s)(1) through (3)]

An owner or operator of a secondary aluminum processing unit at a facility must include, within the OM&M plan

prepared in accordance with 63.1510(b), the following information:

(i) The identification of each emission unit in the secondary aluminum processing unit;

(ii) The specific control technology or pollution prevention measure to be used for each emission unit in the

secondary aluminum processing unit and the date of its installation or application;

(iii) The emission limit calculated for each secondary aluminum processing unit and performance test results

with supporting calculations demonstrating initial compliance with each applicable emission limit;

(iv) Information and data demonstrating compliance for each emission unit with all applicable design, equipment,

work practice or operational standards of this subpart; and

(v) The monitoring requirements applicable to each emission unit in a secondary aluminum processing unit and

the monitoring procedures for daily calculation of the 3-day, 24-hour rolling average using the procedure in

63.1510(t).

The SAPU compliance procedures within the OM&M plan may not contain any of the following provisions:

(i) Any averaging among emissions of differing pollutants;

(ii) The inclusion of any affected sources other than emission units in a secondary aluminum processing unit;

(iii) The inclusion of any emission unit while it is shutdown; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction in emission calculations.

To revise the SAPU compliance provisions within the OM&M plan prior to the end of the permit term, the owner

or operator must submit a request to the applicable permitting authority containing the information required by

paragraph (s)(1) of this section and obtain approval of the applicable permitting authority prior to implementing

any revisions.

11.

[40 CFR 63.1510(t)(1) through (5)]

Except as provided in paragraph (u) of this section, the owner or operator must calculate and record the 3-day,

24-hour rolling average emissions of PM, HCl, and D/F for each secondary aluminum processing unit on a daily

basis. To calculate the 3-day, 24-hour rolling average, the owner or operator must:

Calculate and record the total weight of material charged to each emission unit in the secondary aluminum

processing unit for each 24-hour day of operation using the feed/charge weight information required in paragraph

(e) of this section. If the owner or operator chooses to comply on the basis of weight of aluminum produced by

the emission unit, rather than weight of material charged to the emission unit, all performance test emissions

results and all calculations must be conducted on the aluminum production weight basis.

Multiply the total feed/charge weight to the emission unit, or the weight of aluminum produced by the emission

unit, for each emission unit for the 24-hour period by the emission rate (in lb/ton of feed/charge) for that emission

unit (as determined during the performance test) to provide emissions for each emission unit for the 24-hour

period, in pounds.

Divide the total emissions for each SAPU for the 24-hour period by the total material charged to the SAPU, or

the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the

SAPU.

12.

Terms and Conditions for Emissions Units

Title V Final Permit Page 152
21

11 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Compute the 24-hour daily emission rate using Equation 4:

Eday~=~{sum from {i=1} to n (Ti x ERi)} OVER {sum from {i=1} to n Ti}

Where,

Eday = The daily PM, HCl, or D/F emission rate for the secondary aluminum processing unit for the

24-hour period;

Ti = The total amount of feed, or aluminum produced, for emission unit i for the 24-hour period (tons);

ERi = The measured emission rate for emission unit i as determined in the performance test (lb/ton or g/Mg

of feed/charge); and

n = The number of emission units in the secondary aluminum processing unit.

Calculate and record the 3-day, 24-hour rolling average for each pollutant each day by summing the daily

emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3.

[40 CFR 63.1510(u)]

As an alternative to the procedures of paragraph (t) of this section, an owner or operator may demonstrate,

through performance tests, that each individual emission unit within the secondary aluminum production unit is in

compliance with the applicable emission limits for the emission unit.

13.

[40 CFR 63.1517(a)(1) through (3)]

As required by 63.10(b), the owner or operator shall maintain files of all information (including all reports and

notifications) required by the general provisions and this subpart.

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 off site.

The owner or operator may retain records on microfilm, computer disks, magnetic tape, or microfiche; and

The owner or operator may report required information on paper or on a labeled computer disk using commonly

available and EPA-compatible computer software.

14.

[40 CFR 63.1517(b)]

In addition to the general records required by

63.10(b), the owner or operator of a new or existing affected source (including an emission unit in a secondary

aluminum processing unit) must maintain records of:

For each group 1 furnace (with or without add-on air pollution control devices) or in-line fluxer, records of

15-minute block average weights of gaseous or liquid reactive flux injection, total reactive flux injection rate and

calculations (including records of the identity, composition, and weight of each addition of gaseous, liquid or

solid reactive flux), including records of any period the rate exceeds the compliant operating parameter value and

corrective action taken.

For each affected source and emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge,

records of feed/charge (or throughput) weights for each operating cycle or time period used in the performance

test.

Approved site-specific monitoring plan for a group 1 furnace without add-on air pollution control devices with

records documenting conformance with the plan.

Records of all charge materials for each thermal chip dryer, dross-only furnace, and group 1 melting/holding

furnaces without air pollution control devices processing only clean charge.

15.

Terms and Conditions for Emissions Units

Title V Final Permit Page 153
21

12 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

Records of monthly inspections for proper unit labeling for each affected source and emission unit subject to

labeling requirements.

Records for any approved alternative monitoring or test procedure.

Current copy of all required plans, including any revisions, with records documenting conformance with the

applicable plan, including:

(i) Startup, shutdown, and malfunction plan;

(ii) For major sources, OM&M plan; and

(iii) Site-specific secondary aluminum processing unit emission plan (if applicable).

For each secondary aluminum processing unit, records of total charge weight, or if the owner or operator

chooses to comply on the basis of aluminum production, total aluminum produced for each 24-hour period and

calculations of 3-day, 24-hour rolling average emissions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

1.

[40 CFR 63.1515(b)(1) through (4), (9) and (10)]

Each owner or operator must submit a notification of compliance status report within 60 days after the

compliance dates specified in 63.1501. The notification must be signed by the responsible official who must

certify its accuracy. A complete notification of compliance status report must include the information specified

in paragraphs (a)(1) through (10) of 63.1515. The required information may be submitted in an operating permit

application, in an amendment to an operating permit application, in a separate submittal, or in any combination.

In a State with an approved operating permit program where delegation of authority under section 112(l) of the

CAA has not been requested or approved, the owner or operator must provide duplicate notification to the

applicable Regional Administrator. If an owner or operator submits the information specified in this section at

different times or in different submittals, later submittals may refer to earlier submittals instead of duplicating and

resubmitting the information previously submitted. A complete notification of compliance status report must

include:

All information required in 63.9(h). The owner or operator must provide a complete performance test report for

each affected source and emission unit for which a performance test is required. A complete performance test

report includes all data, associated measurements, and calculations (including visible emission and opacity

tests).

The approved site-specific test plan and performance evaluation test results for each continuous monitoring

system (including a continuous emission or opacity monitoring system).

Unit labeling as described in 63.1506(b), including process type or furnace classification and

operating requirements.

2.

The compliant operating parameter value or range established for each affected source or emission unit with

supporting documentation and a description of the procedure used to establish the value (e.g., lime injection

rate, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet temperature),

including the operating cycle or time period used in the performance test.

Approved OM&M plan (including site-specific monitoring plan for each group 1 furnace with no add-on air

pollution control device).

Startup, shutdown, and malfunction plan, with revisions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 154
21

13 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.1516(a)(1) through (3)]

The owner or operator must develop and implement a written plan as described in 63.6(e)(3) that contains

specific procedures to be followed for operating and maintaining the source during periods of startup, shutdown,

and malfunction, and a program of corrective action for malfunctioning process and air pollution control

equipment used to comply with the standard. The owner or operator shall also keep records of each event as

required by 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 63.6(e)(3). In addition to the information required in

63.6(e)(3), the plan must include:

Procedures to determine and record the cause of the malfunction and the time the malfunction began and ended;

and

Corrective actions to be taken in the event of a malfunction of a process or control device, including procedures

for recording the actions taken to correct the malfunction or minimize emissions.

3.

As required by 63.10(e)(3), the owner or operator must submit semiannual reports within 60 days after the end of

each 6-month period. Each report must contain the information specified in 63.10(c). When no deviations of

parameters have occurred, the owner or operator must submit a report stating that no excess emissions

occurred during the reporting period.

A report must be submitted if any of these conditions occur during a 6-month reporting period:

(i) An excursion of a compliant process or operating parameter value or range (e.g., lime injection rate or screw

feeder setting, total reactive chlorine flux injection rate, afterburner operating temperature, fabric filter inlet

temperature, definition of acceptable scrap, or other approved operating parameter).

(ii) An action taken during a startup, shutdown, or malfunction was not consistent with the procedures in the plan

as described in 63.6(e)(3).

(iii) An affected source (including an emission unit in a secondary aluminum processing unit) was not operated

according to the requirements of this subpart.

(iv) A deviation from the 3-day, 24-hour rolling average emission limit for a secondary aluminum processing unit.

Each report must include this certification: For each group 1 melting/holding furnace without add-on air pollution

control devices and using pollution prevention measures that processes only clean charge material: "Each group

1 furnace without add-on air pollution control devices subject to emission limits in 63.1505(i)(2) processed only

clean charge during this reporting period."

The owner or operator must submit the results of any performance test conducted during the reporting period,

including one complete report documenting test methods and procedures, process operation, and monitoring

parameter ranges or values for each test method used for a particular type of emission point tested.

[40 CFR 63.1516(c)]

For the purpose of annual certifications of compliance required by 40 CFR part 70 or 71, the owner or operator

must certify continuing compliance based upon, but not limited to, the following conditions:

Any period of excess emissions, as defined in paragraph (b)(1) of 63.1516, that occurred during the year were

reported as required by this subpart; and

All monitoring, recordkeeping, and reporting requirements were met during the year.

4.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 155
21

14 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.a

Emission Limitation:

1.5 pounds per hour of particulate emissions

Applicable Compliance Method:

There are two possible sources of particulate emissions from this emissions unit: (1) combustion products from

natural gas firing, and (2) particulate emissions from the degassing operation, in relation to the chlorine

component.

Particulate emissions from gas firing may be calculated by using the emission factor of 1.9 lbs of

particulate/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

mmcf gas/day x 1.9 lbs/mmcf = (lb/day)/24 = lb/hr particulate emissions.

1.b

Particulate emissions from the degassing operation will be generated only during the production of alloy products

containing little or no magnesium. These alloys comprise no more than 10% of the maximum production rate of

780,000 lbs/day or 78,000 lbs/day.

The purpose for the chlorine component in the degassing process is to remove hydrogen from the metal.

Chlorine will chemically combine with hydrogen, and with magnesium and aluminum to form dross. The amount

of chloride components in the dross depends on the total volume of chlorine available less that amount which

combines with hydrogen. At the maximum production rates mentioned above, the chlorine component of the

degassing agent will be 352.6 lbs/day. As is shown in section A.V.7 below, 3.4 lbs/day of chlorine will be used

to form HCl leaving 349.2 lbs/day available for chloride components of dross. During the production of alloyed

aluminum products with little or no magnesium alloy, some percentage of the AlCl3 can be emitted as

particulates with the balance forming the chloride components of dross.

If we assume, however, that all of the AlCl3 generated in this case would be emitted as particulates and the

alloyed aluminum products with little or no magnesium comprise a maximum of 10% of the metal production, the

particulate emission rate at maximum production would be:

2 Al + 3 Cl2 --- 2 AlCl3

3 (35.5 x 2)/ 349.2 lbs/day x 10% = ( 2 (26) + 2 (3 x 35.5))/x

x = 27.4 lbs/day of AlCl3 particulate

or 1.14 lbs/hr particulate emissions from the degassing operation.

Terms and Conditions for Emissions Units

Title V Final Permit Page 156
21

15 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Thus, the total particulate emission rate from this emissions unit is shown as follows:

lb/hr particulate emissions from gas firing + 1.14 lbs/hr particulate emissions from degassing = total lb/hr

particulate emissions from this emissions unit.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 5.

Emission Limitation:

0.05 pound per hour of sulfur dioxide emissions

Applicable Compliance Method:

Sulfur dioxide emissions from gas firing may be calculated by using the emission factor of 0.6 lb of sulfur

dioxide/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and the monitoring

and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 0.6 lb/mmcf) / (hours of operation/day) = lb/hr of sulfur dioxide emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 6.

1.c

Emission Limitation:

0.24 pound per hour of organic compound emissions

Applicable Compliance Method:

Organic compound emissions from gas firing may be calculated by using the emission factor of 5.5 lbs of

organic compounds/mmcf of natural gas from AP-42 Table 1.4-2, Supplement D, Fifth Edition, dated 7/98, and

the monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 5.5 lb/mmcf) / (hours of operation/day) = lb/hr of organic compound emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 18, 25, or 25A, as appropriate.

1.d

Emission Limitation:

11.13 pounds per hour of nitrogen oxides emissions

Applicable Compliance Method:

Nitrogen oxides emissions from this emissions unit may be calculated by using the emission factor of 100 lbs of

nitrogen oxides/mmcf of natural gas from AP-42 Table 1.4-1, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 100 lb/mmcf) / (hours of operation/day) = lb/hr NOx emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 7.

1.e

Terms and Conditions for Emissions Units

Title V Final Permit Page 157
21

16 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

2.75 pounds per hour of carbon monoxide

Applicable Compliance Method:

Carbon monoxide emissions from this emissions unit may be calculated by using the emission factor of 84 lbs of

carbon monoxde/mmcf of natural gas from AP-42 Table 1.4-1, Supplement D, Fifth Edition, dated 7/98, and the

monitoring and record keeping requirements specified in section A.III.2 above as follows:

(mmcf gas/day x 84 lb/mmcf) / (hours of operation/day) = lb/hr CO emissions.

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 10.

1.f

Emission Limitation:

0.33 mg per cubic meter of hydrogen chloride emissions

Applicable Compliance Method:

As stated in section A.V.2.b, the addition of chlorine as a component of the degassing agent is for the removal of

hydrogen from the molten aluminum. The inert argon component helps to extend the active agent chlorine

through the molten metal to improve the efficacy of the chlorine addition. Molten aluminum normally contains

0.25cc of hydrogen per 100 grams of aluminum. Chlorine is added to reduce the ratio to 0.15cc per 100 grams

of metal. This reduction generates HCl emissions as described below:

At the maximum production rate, the following amount of hydrogen is removed:

780,000 lbs/day x 453.7 gm/lb x 0.15cc H2/100 gms Al = 530,829 cc/day or 530 liters H2/day. This removal

results in the following maximum HCl emission rate:

H2 + Cl2 --- 2HCl

530 liters/day of H2 will stoichiometrically form

1060 liters/day of HCl, and

1060 liters/day x 1.64 g/liter (density HCl)= 1741.1 gm/day = 3.83 lbs/day

1.g

NOTE: Based on the above, 530 liters/day Cl, or 1.62 lbs/day Cl, is used to remove the hydrogen from the metal

as follows: 530 liters/day Cl / 28.32 liters/cf = 18.71 cf/day x 0.183 lb/cf = 3.4 lbs/day. The remaining Cl

combines to form dross components or potential AlCl3 particulate as described in section A.V.2.b above.

Per Ohio EPA's policy for the control of toxic air emissions during new source review, the maximum acceptable

ground level concentration (MAGLC) is calculated as follows:

The threshold limit value (TLV) for HCl has been determined to be 7 mg/cm.

This unit is a batch type operation with 4 hours per batch and 6 batches/day, therefore, degassing requirements

are 2 hours per batch x 6 batches/day = 12 hours/day.

MAGLC = 4 TLV/x y (x = hrs/day, y = days/wk)

MAGLC = 4 (7 mg/cm)/(12 x 7) = 0.33 mg/cm

If required, compliance with the above emission limitation shall be determined in accordance with 40 CFR Part

60, Appendix A, Methods 1 through 4 and 26.

Terms and Conditions for Emissions Units

Title V Final Permit Page 158
21

17 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(a)]

Prior to conducting a performance test required by this subpart, the owner or operator must prepare and submit a

site-specific test plan meeting the requirements in 63.7(c).

2.

[40 CFR 63.1511(b)]

Following approval of the site-specific test plan, the owner or operator must demonstrate initial compliance with

each applicable emission, equipment, work practice, or operational standard for each affected source and

emission unit, and report the results in the notification of compliance status report as described in 63.1515(b).

The owner or operator must conduct each performance test according to the requirements of the general

provisions in subpart A of this part and this subpart. Owners or operators of affected sources located at facilities

which are area sources are subject only to those performance testing requirements pertaining to D/F. Owners or

operators of sweat furnaces meeting the specifications of 63.1505(f)(1) are not required to conduct a performance

test.

The owner or operator must conduct each test while the affected source or emission unit is operating at the

highest production level with charge materials representative of the range of materials processed by the unit and,

if applicable, at the highest reactive fluxing rate.

3.

[40 CFR 63.1511(c)]

The owner or operator must use the following methods in appendix A to 40 CFR part 60 to determine compliance

with the applicable emission limits or standards:

Method 1 for sample and velocity traverses.

Method 2 for velocity and volumetric flow rate.

Method 3 for gas analysis.

Method 4 for moisture content of the stack gas.

Method 5 for the concentration of PM.

Method 9 for visible emission observations.

Method 26A for the concentration of HCl. Where a lime-injected fabric filter is used as the control device to

comply with the 90 percent reduction standard, the owner or operator must measure the fabric filter inlet

concentration of HCl at a point before lime is introduced to the system.

4.

[40 CFR 63.1511(d)]

The owner or operator may use an alternative test method, subject to approval by the Administrator.

5.

[40 CFR 63.1511(e)]

The owner or operator of new or existing affected sources and emission units located at secondary aluminum

production facilities that are major sources must conduct a performance test every 5 years following the initial

performance test.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 159
21

18 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1511(f)(1) through (6)]

With the approval of the permitting authority, a single representative or similar group 1 furnace or in-line fluxer

which is not controlled by an add-on control device may be tested to determine the emission rate of all like

affected sources at a facility provided that:

The tested emission unit must use identical feed/charge and flux materials in the same proportions as the

emission units that it represents;

The tested emission unit is subject to the same work practices and the emission units that it represents;

The tested emission unit is of the same design as the emission units that it represents;

The tested emission unit is tested under the highest load or capacity reasonably expected to occur for any of the

emission units that it represents;

At least one of each different style of emission unit at the facility is tested; and

All add-on control devices are tested.

7.

[40 CFR 63.1511(g)(1) through (4)]

The owner or operator of new or existing affected sources and emission units must establish a minimum or

maximum operating parameter value, or an operating parameter range for each parameter to be monitored as

required by 63.1510 that ensures compliance with the applicable emission limit or standard. To establish the

minimum or maximum value or range, the owner or operator must use the appropriate procedures in this section

and submit the information required by 63.1515(b)(4) in the notification of compliance status report. The owner or

operator may use existing data in addition to the results of performance tests to establish operating parameter

values for compliance monitoring provided each of the following conditions are met to the satisfaction of the

applicable permitting authority:

The complete emission test report(s) used as the basis of the parameter(s) is submitted.

The same test methods and procedures as required by Subpart RRR were used in the test.

The owner or operator certifies that no design or work practice changes have been made to the source, process,

or emission control equipment since the time of the report.

All process and control equipment operating parameters required to be monitored were monitored as required in

this subpart and documented in the test report.

8.

[40 CFR 63.1512(e)(2) and (3)]

In the site-specific monitoring plan required by 63.1510(o), the owner or operator of a group 1 furnace (including a

melting/holding furnaces) without add-on air pollution control devices must include data and information

demonstrating compliance with the applicable emission limits.

If the group 1 furnace processes only clean charge, the owner or operator must conduct emission tests to

simultaneously measure emissions of PM and HCl at the furnace exhaust outlet. A D/F test is not required.

Each test must be conducted while the group 1 furnace (including a melting/holding furnace) processes only

clean charge.

The owner or operator may choose to determine the rate of reactive flux addition to the group 1 furnace and

assume, for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added

to the group 1 furnace is emitted. Under these circumstances, the owner or operator is not required to conduct

an emission test for HCl.

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 160
21

19 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(h)(1) and (2)]

The owner or operator must conduct a performance test to measure emissions of HCl and PM. If the in-line

fluxer is equipped with an add-on control device, the emissions must be measured at the outlet of the control

device. If the in-line fluxer uses no reactive flux materials, emission tests for PM and HCl are not required.

The owner or operator may choose to determine the rate of reactive flux addition to the in-line fluxer and assume,

for the purposes of demonstrating compliance with the SAPU emission limit, that all reactive flux added to the

in-line fluxer is emitted. Under these circumstances, the owner or operator is not required to conduct an

emission test for HCl.

10.

[40 CFR 63.1512(j)(1) and (3)]

The owner or operator must conduct performance tests as described in paragraphs (j)(1) through (3) of this

section. The results of the performance tests are used to establish emission rates in lb/ton of feed/charge for

PM and HCl and g TEQ/Mg of feed/charge for D/F emissions from each emission unit. These emission rates

are used for compliance monitoring in the calculation of the 3-day, 24-hour rolling average emission rates using

the equation in 63.1510(t). A performance test is required for:

Each group 1 furnace processing only clean charge to measure emissions of PM and either:

(i) Emissions of HCl (for the emission limit); or

(ii) The mass flow rate of HCl at the inlet to and outlet from the control device (for the percent reduction standard).

Each in-line fluxer to measure emissions of PM and HCl.

11.

[40 CFR 63.1512(k)]

During the emission test(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format,

the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of

feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the

affected source or emission unit for each of the three test runs and calculate and record the total weight. An

owner or operator that chooses to demonstrate compliance on the basis of the aluminum production weight must

measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge

weight.

12.

Terms and Conditions for Emissions Units

Title V Final Permit Page 161
21

20 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1512(o)(1) through (3)]

The owner or operator must use these procedures to establish an operating parameter value or range for the total

reactive chlorine flux injection rate.

Continuously measure and record the weight of gaseous or liquid reactive flux injected for each 15 minute period

during the HCl and D/F tests, determine and record the 15-minute block average weights, and calculate and

record the total weight of the gaseous or liquid reactive flux for the 3 test runs;

Record the identity, composition, and total weight of each addition of solid reactive flux for the 3 test runs;

Determine the total reactive chlorine flux injection rate by adding the recorded measurement of the total weight of

chlorine in the gaseous or liquid reactive flux injected and the total weight of chlorine in the solid reactive flux

using this equation:

Wt = F1W1 + F2W2

Where,

Wt = Total chlorine usage, by weight;

F1 = Fraction of gaseous or liquid flux that is chlorine;

W1 = Weight of reactive flux gas injected;

F2 = Fraction of solid reactive chloride flux that is chlorine (e.g., F = 0.75 for magnesium chloride; and

W2 = Weight of solid reactive flux;

Divide the weight of total chlorine usage (Wt) for the 3 test runs by the recorded measurement of the total weight

of feed for the 3 test runs; and

If a solid reactive flux other than magnesium chloride is used, the owner or operator must derive the appropriate

proportion factor subject to approval by the applicable permitting authority.

13.

[40 CFR 63.1513(b)]

Use this equation to determine compliance with an emission limit for PM, HCl, and D/F:

E = {C x Q x K1} / P

Where,

E = Emission rate of PM, HCl, or D/F, kg/Mg (lb/ton) of feed;

C = Concentration of PM, HCl, or D/F, g/dscm (gr/dscf);

Q = Volumetric flow rate of exhaust gases, dscm/hr (dscf/hr);

K1 = Conversion factor, 1 kg/1,000 g (1 lb/7,000 gr); and

P = Production rate, Mg/hr (ton/hr).

14.

Terms and Conditions for Emissions Units

Title V Final Permit Page 162
21

21 Facility Name:

Facility ID:

Emissions Unit: Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.1513(e)(1) and (2)]

Use the procedures in paragraphs (e)(1) and (2) to determine compliance with emission limits for a secondary

aluminum processing unit.

Use this equation to compute the mass-weighted PM emissions for a secondary aluminum processing unit.

Compliance is achieved if the mass-weighted emissions for the secondary aluminum processing unit (EcPM) is

less than or equal to the emission limit for the secondary aluminum processing unit (LcPM) calculated using

Equation 1 in 63.1505(k).

EcPM = {sum from {i=1} to n (EtiPM times Tti)} over {sum from {i=1} to n (Tti)}

Where,

EcPM = The mass-weighted PM emissions for the secondary aluminum processing unit;

EtiPM = Measured PM emissions for individual emission unit i;

Tti = The average feed rate for individual emission unit i during the operating cycle or performance test period; and

n = The number of emission units in the secondary aluminum processing unit.

Use this equation to compute the aluminum mass-weighted HCl emissions for the secondary aluminum

processing unit. Compliance is achieved if the mass-weighted emissions for the secondary aluminum

processing unit (EcHCl) is less than or equal to the emission limit for the secondary aluminum processing unit

(LcHCl) calculated using Equation 2 in 63.1505(k).

EcHCl = {sum from {i=1} to n (EtiHCl times Tti)} over {sum from {i=1} to n ( Tti)}

Where,

EcHCl = The mass-weighted HCl emissions for the secondary aluminum processing unit; and

EtiHCl = Measured HCl emissions for individual emission unit i.

As an alternative to using the equations in paragraphs (e)(1) and (2) of this section, the owner or operator may

demonstrate compliance for a secondary aluminum processing unit by demonstrating that each existing group 1

furnace is in compliance with the emission limits for a new group 1 furnace in 63.1505(i) and that each existing

in-line fluxer is in compliance with the emission limits for a new in-line fluxer in 63.1505(j).

15.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 163
1

1

Direct Chill Casting Pit No. 1 (P235)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 164
5

1

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

SPL Vitrification #1 (P236)

Spent Potliner vitrification (permit 2 of 2)

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

spent potliner vitrification process

vented to the dry scrubber system

through the vitrification baghouse

OAC rule 3745-31-05(A)(3)

(PTI 17-1400 and 17-1588)

Particulate emissions shall not

exceed 0.0151 lb/hr and 0.066

ton/year.

Sulfur dioxide (SO2) emissions shall

not exceed 0.0073 lb/hr and 0.032

ton/year.

Volatile organic compound (VOC)

emissions shall not exceed 0.0641

lb/hr and 0.2808 ton/year.

Nitrogen oxides (NOx) emissions

shall not exceed 1.2098 lbs/hr and

5.2989 tons/year.

Carbon monoxide (CO) emissions

shall not exceed 0.2420 lb/hr and

1.06 tons/year.

Gaseous fluoride emissions shall not

exceed 0.2539 lb/hr and 1.11

tons/year.

See A.I.2.a below.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B) The emission limitation specified by

this rule is less stringent than the

emission limit established pursuant

to OAC rule 3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 165
5

2

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a All air pollutant emissions shall be vented to the control system for this emissions unit.

II. Operational Restrictions

The pressure drop across the vitrification baghouse shall be maintained within the range of 2 to 8 inches of water

while the emissions unit is in operation.

1.

The pressure drop across the dry scrubber shall be maintained within the range of 4 to 18 inches of water while

the emissions unit is in operation. The pressure drop range was determined from actual data and varies due to

ambient and flue gas temperatures.

2.

III. Monitoring and/or Record Keeping Requirements

The permittee shall properly operate and maintain equipment to monitor the pressure drop across the vitrification

baghouse and the dry scrubber system while the emissions unit is in operation. The monitoring equipment shall

be calibrated, operated, and maintained in accordance with the manufacturer's recommendations, instructions,

and operating manual(s). The permittee shall record the pressure drop across the baghouse and the dry

scrubber system on a once-per-shift basis.

1.

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit quarterly pressure drop deviation (excursion) reports that identify all periods of time

during which the pressure drop across the vitrification baghouse and the dry scrubber did not comply with the

allowable range specified in sections A.II.1 and A.II.2 above. These reports shall be submitted to the Ohio EPA,

Southeast District Office within 30 days of the end of the calendar quarter.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Director (the

appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year and shall cover

the previous 6-month period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-18-06(E)(2) The emission limitation specified by

this rule is less stringent than the

emission limit established pursuant

to OAC rule 3745-31-05(A)(3).

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 166
5

3

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Particulate emissions shall not exceed 0.0151 lb/hr and 0.066 ton/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(0.0151 lb/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.a

Emission Limitations:

Sulfur dioxide emissions shall not exceed 0.0073 lb/hr and 0.032 ton/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(0.0073 lb/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.b

Emission Limitations:

Volatile organic compound emissions shall not exceed 0.0641 lb/hr and 0.2808 ton/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(0.0641 lb/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.c

Emission Limitations:

Nitrogen oxides emissions shall not exceed 1.2098 lbs/hr and 5.2989 tons/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(1.2098 lbs/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 167
5

4

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Carbon monoxide emissions shall not exceed 0.2420 lb/hr and 1.06 tons/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(0.2420 lb/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.e

Emission Limitations:

Gaseous flouride emissions shall not exceed 0.2539 lb/hr and 1.11 tons/year.

Applicable Compliance Method:

Compliance with the hourly emission limitation shall be demonstrated based upon the methods and procedures

specified in section A.V.2.

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate

(0.2539 lb/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton.

Therefore, provided compliance is shown with the hourly limitation, compliance shall also be shown with the

annual emission limitation.

1.f

Emission Limitation:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. The emissions testing, as described in section 2, shall include a

demonstration of compliance with this limit.

1.g

Operational Restriction:

The pressure drop across the vitrification baghouse shall be maintained within the range of 2 to 8 inches of water

while the emissions unit is in operation.

Applicable Compliance Method:

Compliance shall be demonstrated based upon the monitoring and record keeping requirements specified in

section A.III.1.

1.h

Terms and Conditions for Emissions Units

Title V Final Permit Page 168
5

5

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Operational Restriction:

The pressure drop across the dry scrubber shall be maintained within the range of 4 to 18 inches of water while

the emissions unit is in operation.

Applicable Compliance Method:

Compliance shall be demonstrated based upon the monitoring and record keeping requirements specified in

section A.III.1.

1.i

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 60 days after the restart of this emissions unit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates, SO2, NOx, visible emissions, CO, VOC, and gaseous fluorides.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates:

for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A;

for SO2, Methods 1 through 4 and 6 of 40 CFR Part 60, Appendix A;

for NOx, Methods 1 through 4 and 7 of 40 CFR Part 60, Appendix A;

for visible emissions, Method 9 of 40 CFR Part 60, Appendix A;

for CO, Methods 1 through 4 and 10 of 40 CFR Part 60, Appendix A;

for VOC, Methods 1 through 4 and 18 or 25, as appropriate, of 40 CFR Part 60, Appendix A; and

for gaseous fluorides, Methods 1 through 4 and 13B of 40 CFR Part 60, Appendix A.

Alternative U.S. EPA-approved test methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

2.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 169
1

1

SPL Vitrification #1 (P236)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 170
4

1

Facility Name:

Facility ID:

Emissions Unit: Induction Furnace (P238)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

None

Induction Furnace (P238)

Casthouse Induction Furnace

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

coreless aluminum induction furnace OAC rule 3745-31-05(A)(3)

(PTI 06-06876)

Particulate emissions (PE) shall not

exceed 1.62 lbs/hr.

PE shall not exceed 7.1 tpy.

The requirements of this rule also

include compliance with the

requirements of OAC rule

3745-17-07(A) and 40 CFR Part 63,

Subpart RRR.

471868 471868

OAC rule 3745-17-07(A) Visible PE from any stack shall not

exceed 20% opacity as a 6-minute

average, except as provided by the

rule.

471868 471868

OAC rule 3745-17-11(B)(1) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

471868 40 CFR Part 63, Subpart RRR 471868 See sections A.II.1 and A.II.2.

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 171
4

2

Facility Name:

Facility ID:

Emissions Unit: Induction Furnace (P238)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

[40 CFR 63.1506(b)]

The permittee must provide and maintain easily visible labels posted at each group 1 furnace, group 2 furnace,

in-line fluxer and scrap dryer/delacquering kiln/decoating kiln that identifies the applicable emission limits and

means of compliance, including:

a. The type of affected source or emission unit (e.g., scrap dryer/delacquering kiln/decoating kiln, group 1

furnace, group 2 furnace, in-line fluxer).

b. The applicable operational standard(s) and control method(s) (work practice or control device). This includes,

but is not limited to, the type of charge to be used for a furnace (e.g., clean scrap only, all scrap, etc.), flux

materials and addition practices.

1.

[40 CFR 63.1506(o)]

The owner or operator of a new or existing group 2 furnace must:

a. Operate each furnace using only clean charge as the feedstock,

b. Operate each furnace using no reactive flux.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.1510(c)]

The permittee must inspect the labels for each group 1 furnace, group 2 furnace, in-line fluxer and scrap

dryer/delacquering kiln/decoating kiln at least once per calendar month to confirm that posted labels as required

by the operational standard in 40 CFR 63.1506(b) are intact and legible.

1.

[40 CFR 63.1510(r)]

The owner or operator must:

a. Record a description of the materials charged to the furnace, including any nonreactive, non-HAP

containing/non-hap generating fluxing materials or agents.

b. Submit a certification of compliance with the applicable operational standard for charge materials in Section

63.1506(o) for each 6-month reporting period. Each certification must contain the information in Section

63.1516(b)(2)(v).

2.

[40 CFR 63.1517(a)]

As required by 40 CFR 63.10(b), the permittee shall maintain files of all information (including all reports and

notifications) required by the general provisions and this subpart.

a. The permittee 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 off site.

b. The permittee may retain records on microfilm, computer disks, magnetic tape, or microfiche.

c. The permittee may report required information on paper or on a labeled computer disk using commonly

available and EPA-compatible computer software.

3.

[40 CFR 63.1517(b)]

In addition to the general records required by 40 CFR 63.10(b), the permittee of a new or existing affected source

(including an emissions unit in a secondary aluminum processing unit) must maintain records of all charge

materials and fluxing materials or agents for a group 2 furnace.

4.

Terms and Conditions for Emissions Units

Title V Final Permit Page 172
4

3

Facility Name:

Facility ID:

Emissions Unit: Induction Furnace (P238)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform weekly checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack serving this emissions unit. The presence

or absence of any visible emissions shall be noted in an operations log. If visible emissions are observed, the

permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

5.

IV. Reporting Requirements

[40 CFR 63.1515(b)]

Each permittee must submit a notification of compliance status report within 60 days after the compliance dates

specified in 40 CFR 63.1501. The notification must be signed by the responsible official who must certify its

accuracy. The required information may be submitted in an operating permit application, in an amendment to an

operating permit application, in a separate submittal, or in any combination. The permittee must provide

duplicate notification to the applicable Regional Administrator. If a permittee submits the information specified in

this section at different times or in different submittals, later submittals may refer to earlier submittals instead of

duplicating and resubmitting the information previously submitted. A complete notification of compliance status

report must include unit labeling as described in 40 CFR 63.1506(b), including process type or furnace

classification and operating requirements.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit and (b) describe any corrective

actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the Ohio EPA,

Southeast District Office by January 31 and July 31 of each year and shall cover the previous 6-month period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

PE shall not exceed 1.62 lbs/hr and 7.1 tpy.

Applicable Compliance Method:

Allowable emissions are derived from the limit of 0.40 lb PE/ton established in 40 CFR Part 63, Subpart RRR for

Group 1 furnaces receiving only clean charges, as no testing data is available for Group 2 furnaces. Emissions

are not expected to exceed limits established for Group 1, clean-charge only furnaces.

Emission tests also may be required in accordance with 40 CFR Part 60, Appendix A, Methods 1 through 5. No

emission testing is specifically required to demonstrate compliance with this limit but, if appropriate, may be

requested pursuant to OAC rule 3745-15-04(A).

1.a

Emission Limitation:

Visible PE from any stack shall not exceed 20% opacity as a 6-minute average, except as provided by the rule.

Applicable Compliance Method:

If required, compliance shall be demonstrated through visible particulate emission observations performed in

accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule

3745-17-03(B)(1).

1.b

Terms and Conditions for Emissions Units

Title V Final Permit Page 173
4

4

Facility Name:

Facility ID:

Emissions Unit: Induction Furnace (P238)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 174
1

1

Induction Furnace (P238)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 175
9

1

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Anode Baking Furnace-665 (P900)

Anode Baking Furnace-665

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

anode baking furnace 665 OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 19.3 pounds per hour.

471868 471868

40 CFR Part 63, Subpart LL [63.843(c)]

The owner or operator shall not

discharge or cause to be discharged

into the atmosphere any emissions

of total flouride (TF) or polycyclic

organic matter (POM) in excess of

the limits specified below from

emissions units P999 and P900,

combined:

Emissions of TF shall not exceed

0.20 lb/ton of green anode.

Emissions of POM shall not exceed

0.18 lb/ton of green anode.

471868 471868

OAC rule 3745-18-06(D)(2) Sulfur dioxide emissions shall not

exceed 141 pounds per hour.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 176
9

2

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [63.846(a),(c)]

The owner or operator of an existing anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section. The owner or operator may average TF and/or POM

emissions from anode bake furnaces and demonstrate compliance with the limits in Table 3 of 40 CFR Part

63, Subpart LL using the procedures described 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 Table 3 of 40 CFR Part 63, Subpart LL in

any one year; and

(2) To determine compliance with the applicable emission limit in Table 3 of 40 CFR Part 63, Subpart LL for

anode bake furnaces, the owner or operator 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 40 CFR Part 63, Subpart

LL, Secs. 63.847 and 63.849.

2.b [63.846(d)]

The owner or operator shall develop and submit an implementation plan for emission averaging to the

applicable regulatory authority for review and approval according to the following procedures and requirements:

(1) Deadlines. The owner or operator must submit the implementation plan no later than 6 months before the

date that the facility intends to comply with the emission averaging limits.

(2) Contents. The owner or operator shall include the following information in the implementation plan or in

the application for an operating permit for all emission sources to be included in an emissions average:

(i) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(ii) The assigned TF or POM emission limit for each averaging group of potlines or anode bake furnaces;

(iii) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(iv) The test plan for the measurement of TF or POM emissions in accordance with the requirements in Sec.

63.847(b);

(v) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(vi) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

(A) A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

Terms and Conditions for Emissions Units

Title V Final Permit Page 177
9

3

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

(B) A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

record keeping requirements; and a demonstration, to the satisfaction of the applicable regulatory authority,

that the proposed monitoring frequency is sufficient to represent control device operating conditions; and

(vii) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

(3) Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(i) Whether the content of the plan includes all of the information specified in this section; and

(ii) Whether the plan or permit application presents sufficient information to determine that compliance will be

achieved and maintained.

(4) Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(i) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(ii) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(iii) The inclusion of any potline or anode bake furnace while it is shut down; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by section A.IV.1.a.(2), in the emission calculations.

(5) Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(i) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(ii) To revise the plan prior to the end of the permit term, the owner or operator shall submit a request to the

applicable regulatory authority; and

(iii) The owner or operator may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

(6) Operation. While operating under an approved implementation plan, the owner or operator shall monitor

the operating parameters of each control system, keep records, and submit periodic reports as required for

each source subject to 40 CFR Part 63, Subpart LL and this permit.

II. Operational Restrictions

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 178
9

4

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

[63.848(c)]

TF and POM emissions from anode bake furnaces. Using the procedures in 40 CFR Part 63.847, section A.V of

this permit, and the approved test plan, the owner or operator shall monitor TF and POM emissions from each

anode bake furnace on an annual basis. The owner or operator 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 owner or operator must include all valid runs in the annual average.

1.

[63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in section A.III.8, the following monitoring devices shall be installed:

(1) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

(2) For dry coke scrubbers, devices for the measurement of coke flow and air flow;

(3) For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

(4) For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

(5) For wet roof scrubbers for secondary emission control:

(i) A device for the measurement of total water flow; and

(ii) The owner or operator shall inspect each control device at least once each operating day to ensure the

control device is operating properly and record the results of each inspection.

2.

[63.848(g)]

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.

3.

[63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

4.

[63.848(i)]

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.

5.

[63.848(j)]

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.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 179
9

5

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[63.848(k)]

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.

7.

[63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

8.

[63.850(e)(4)]

In addition to the general records required by Sec. 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; and

(iii) a copy of the startup, shutdown, and malfunction plan.

9.

IV. Reporting Requirements

[63.850(b), (c), (d)]

Notifications. The owner or operator shall submit the following written notifications:

(1) Performance test reports. The owner or operator shall report the results of the initial performance test.

Except as provided in paragraph (3) of this section, the owner or operator shall submit a summary of all

subsequent performance tests to the applicable regulatory authority on an annual basis.

(2) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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

permitting authority may review the plan upon request. In addition to the information required in Sec. 63.6(e)(3),

the plan shall include:

(i) Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

(ii) The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

1.

(3) Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 180
9

6

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[63.847(b)]

Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 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.

1.

[63.847(c)]

Initial performance test. Following approval of the site-specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for the anode bake

furnace within the 12 months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

[63.847(d)(4)]

For each anode bake furnace, the owner or operator 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 the

equations in paragraphs (e)(3) and (e)(4) of 40 CFR Part 63, Subpart LL, Section 63.847, the owner or operator

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 Secs. 63.843, 63.844, or 63.846

and this permit.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 181
9

7

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

(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 40 CFR Part 63, Subpart LL and this permit.

(2) 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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

3.

[63.849(a)]

The owner or operator 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 40 CFR Part 60 for sample and velocity traverses;

(2) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;

(3) Method 3 in appendix A to 40 CFR Part 60 for gas analysis;

(4) Method 13A or Method 13B in appendix A to 40 CFR Part 60, 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 40 CFR Part 60 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 40 CFR Part 63 Subpart LL 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 40 CFR Part 63 Subpart LL and Method 14 in appendix A to 40 CFR Part 60 or

an approved alternative method for the concentration of POM where emissions are sampled from roof monitors

not employing wet roof scrubbers.

4.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

5.

Emission Limitation:

19.3 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 182
9

8

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

0.20 lb of TF per ton of green anode from emissions units P999 and P900, combined

0.18 lb of POM per ton of green anode from emissions units P999 and P900, combined

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in sections A.V.1 through

A.V.4.

5.b

Emission Limitation:

141 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.c

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

5.d

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted approximately 1.5 years after permit issuance and within 12 months

prior to permit expiration.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates and sulfur dioxide.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate(s): for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A and for sulfur dioxide, Methods 1

through 4 and 6 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

d. The tests shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 183
9

9

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 184
1

1

Anode Baking Furnace-665 (P900)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 185
3

1

Facility Name:

Facility ID:

Emissions Unit: Alumina Ore Handling (P901)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall employ reasonably available control measures on the alumina ore handling system for

the purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance with

the permittee's permit application, the permittee shall maintain enclosures around the emissions unit and

vent emissions to 5 baghouses installed in parallel to ensure compliance. Nothing in this paragraph shall

prohibit the permittee from employing additional control measures to ensure compliance.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouses serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Alumina Ore Handling (P901)

Conveyor Alumina Ore Handling System

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina ore handling OAC rule 3745-17-08(B)(3) Particulate emissions shall not

exceed 0.030 grain per dry standard

cubic foot of exhaust gases or there

shall be no visible particulate

emissions, whichever is less

stringent.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 186
3

2

Facility Name:

Facility ID:

Emissions Unit: Alumina Ore Handling (P901)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouses serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

0.030 grain per dry standard cubic foot of exhaust gases

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the method and procedures specified in 40 CFR Part

60, Appendix A, Methods 1 through 5.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 187
3

3

Facility Name:

Facility ID:

Emissions Unit: Alumina Ore Handling (P901)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

no visible emissions

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR,

Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.b

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 188
1

1

Alumina Ore Handling (P901)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 189
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #1 (P902)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall employ reasonably available control measures on the Hartman barge unloader #1 for the

purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance with the

permittee's permit application, the permittee shall maintain enclosures around the emissions unit and vent

emissions to a baghouse to ensure compliance. Nothing in this paragraph shall prohibit the permittee from

employing additional control measures to ensure compliance.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Hartman Unloader #1 (P902)

Hartman Unloader #1

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman barge unloader #1 OAC rule 3745-17-08(B)(3) Particulate emissions shall not

exceed 0.030 grain per dry standard

cubic foot of exhaust gases or there

shall be no visible particulate

emissions, whichever is less

stringent.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 190
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #1 (P902)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

0.030 grain per dry standard cubic foot of exhaust gases

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the method and procedures specified in 40 CFR Part

60, Appendix A, Methods 1 through 5.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 191
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #1 (P902)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

no visible emissions

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR,

Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.b

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 192
1

1

Hartman Unloader #1 (P902)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 193
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #2 (P903)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall employ reasonably available control measures on the Hartman barge unloader #2 for the

purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance with the

permittee's permit application, the permittee shall maintain enclosures around the emissions unit and vent

emissions to a baghouse to ensure compliance. Nothing in this paragraph shall prohibit the permittee from

employing additional control measures to ensure compliance.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Hartman Unloader #2 (P903)

Hartman Unloader #2

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman barge unloader #2 OAC rule 3745-17-08(B)(3) Particulate emissions shall not

exceed 0.030 grain per dry standard

cubic foot of exhaust gases or there

shall be no visible particulate

emissions, whichever is less

stringent.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 194
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #2 (P903)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

0.030 grain per dry standard cubic foot of exhaust gases

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the method and procedures specified in 40 CFR Part

60, Appendix A, Methods 1 through 5.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 195
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #2 (P903)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

no visible emissions

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR,

Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.b

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 196
1

1

Hartman Unloader #2 (P903)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 197
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #3 (P904)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall employ reasonably available control measures on the Hartman barge unloader #3 for the

purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance with the

permittee's permit application, the permittee shall maintain enclosures around the emissions unit and vent

emissions to a baghouse to ensure compliance. Nothing in this paragraph shall prohibit the permittee from

employing additional control measures to ensure compliance.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Hartman Unloader #3 (P904)

Hartman Unloader #3

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman barge unloader #3 OAC rule 3745-17-08(B)(3) Particulate emissions shall not

exceed 0.030 grain per dry standard

cubic foot of exhaust gases or there

shall be no visible particulate

emissions, whichever is less

stringent.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 198
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #3 (P904)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

0.030 grain per dry standard cubic foot of exhaust gases

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the method and procedures specified in 40 CFR Part

60, Appendix A, Methods 1 through 5.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 199
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #3 (P904)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

no visible emissions

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR,

Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.b

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 200
1

1

Hartman Unloader #3 (P904)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 201
3

1

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #4 (P905)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall employ reasonably available control measures on the Hartman barge unloader #4 for the

purpose of ensuring compliance with the above-mentioned applicable requirements. In accordance with the

permittee's permit application, the permittee shall maintain enclosures around the emissions unit and vent

emissions to a baghouse to ensure compliance. Nothing in this paragraph shall prohibit the permittee from

employing additional control measures to ensure compliance.

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouse serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

Hartman Unloader #4 (P905)

Hartman Unloader #4

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Hartman barge unloader #4 OAC rule 3745-17-08(B)(3) Particulate emissions shall not

exceed 0.030 grain per dry standard

cubic foot of exhaust gases or there

shall be no visible particulate

emissions, whichever is less

stringent.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 202
3

2

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #4 (P905)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouse serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Director (the appropriate Ohio EPA

District Office or local air agency) by January 31 and July 31 of each year and shall cover the previous 6-month

period.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

0.030 grain per dry standard cubic foot of exhaust gases

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the method and procedures specified in 40 CFR Part

60, Appendix A, Methods 1 through 5.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 203
3

3

Facility Name:

Facility ID:

Emissions Unit: Hartman Unloader #4 (P905)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

no visible emissions

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22 as set forth in "Appendix on Test Methods" in 40 CFR,

Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996.

1.b

Emission Limitation:

20% opacity as a 3-minute average

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 204
1

1

Hartman Unloader #4 (P905)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 205
3

1

Facility Name:

Facility ID:

Emissions Unit: Bath Screen Feeder (P919)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 13.6 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows, and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Bath Screen Feeder (P919)

Bath Screen Feeder

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Bath Screen Feeder vented to a

baghouse.

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions shall not

exceed 13.6 pounds per hour, as

calculated from Table 1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 206
3

2

Facility Name:

Facility ID:

Emissions Unit: Bath Screen Feeder (P919)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack and for any visible fugitive particulate

emissions from the egress points (i.e., building windows, doors, roof monitors, etc.) serving this emissions unit.

The presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit, (b) identify all days during which

any visible fugitive particulate emissions were observed from the egress points (i.e., building windows, doors, roof

monitors, etc.) serving this emissions unit, and (c) describe any corrective actions taken to minimize or eliminate

the visible particulate and/or visible fugitive particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 207
3

3

Facility Name:

Facility ID:

Emissions Unit: Bath Screen Feeder (P919)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

Particulate emissions shall not exceed 13.6 pounds per hour.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(10).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 208
1

1

Bath Screen Feeder (P919)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 209
3

1

Facility Name:

Facility ID:

Emissions Unit: Bath Crusher (P920)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

reasonably available control measures (RACM). These measures shall include, but not be limited to, the

following:

All equipment associated with this emissions unit which generates fugitive dust shall be vented to the

baghouse, which shall achieve an outlet emission rate of not greater than 9.79 pounds of particulate

emissions per hour from the baghouse exhaust stack.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this equipment, including, but not limited to:

doorways, windows, and roof openings.

2.b Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-17-08.

Bath Crusher (P920)

Bath Crusher Hammer Mill

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Bath Crusher Hammer Mill vented to

a baghouse.

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See sections A.I.2.a and A.I.2.b.

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B) Particulate emissions shall not

exceed 9.79 pounds per hour, as

calculated from Figure II, curve P-1.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 210
3

2

Facility Name:

Facility ID:

Emissions Unit: Bath Crusher (P920)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the stack and for any visible fugitive particulate

emissions from the egress points (i.e., building windows, doors, roof monitors, etc.) serving this emissions unit.

The presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

1.

2. The above-mentioned daily checks shall be performed during representative, normal operating conditions.

IV. Reporting Requirements

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the stack serving this emissions unit, (b) identify all days during which

any visible fugitive particulate emissions were observed from the egress points (i.e., building windows, doors, roof

monitors, etc.) serving this emissions unit, and (c) describe any corrective actions taken to minimize or eliminate

the visible particulate and/or visible fugitive particulate emissions. These reports shall be submitted to the

Director (the appropriate Ohio EPA District Office or local air agency) by January 31 and July 31 of each year

and shall cover the previous 6-month period.

1.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitation for fugitive emissions from the material handling operation(s)

identified above shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test

Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix

existed on July 1, 1996, and the modifications listed in paragraphs (B)(3)(a) and (B)(3)(b) of OAC rule

3745-17-03.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 211
3

3

Facility Name:

Facility ID:

Emissions Unit: Bath Crusher (P920)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Applicable Compliance Method:

If required, compliance shall be determined through visible emissions observations performed in accordance with

40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

1.b

Emission Limitation:

Particulate emissions shall not exceed 9.79 pounds per hour.

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon emission testing conducted in accordance with 40

CFR Part 60, Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-03(B)(10).

Emission testing is not specifically required to demonstrate compliance with this emission limitation, but, if

appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.c

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 212
1

1

Bath Crusher (P920)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 213
6

1

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Scrap Carbon Crusher (P923)

Carbon Crusher

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Spent carbon anode crushing

operation (tumbler vibrator feeder,

Didon tumbler, vibrator bin, jaw

crusher, belt conveyor, cone crusher,

bucket elevator, covered chute to

conveyor or storage bin) with two

three-module baghouses.

(formerly P023)

OAC rule 3745-31-05(A)(3)

(PTI 06-06859 issued 11/5/2002)

The fabric filters shall achieve an

outlet emission rate of not greater

than 0.030 grain of particulate

emissions per dry standard cubic

foot of exhaust gases and no visible

particulate emissions from the

exhaust stacks.

Particulate emissions shall not

exceed 60.51 tons per year.

See sections A.I.2.a through A.I.2.e.

The requirements of this rule also

includes compliance with the

requirements of OAC rule

3745-17-07(B)(1).

471868 471868

OAC rule 3745-17-07(B)(1) Fugitive visible particulate emissions

shall not exceed 20% opacity as a

3-minute average.

471868 471868

OAC rule 3745-17-07(A) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-17-08(B) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 214
6

2

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a The material handling operation(s) that are covered by this permit and subject to the above-mentioned

requirements are listed below:

i. Load-in of spent anodes to tumbler feeder;

ii. Transfer to vibrator bin;

iii. Transfer jaw crusher to belt conveyor;

iv. Transfer belt conveyor to cone crusher;

v. Transfer to bucket elevator;

vi. Bucket elevator to chute; and

vii. Transfer to storage bin or covered belt conveyor.

2.b The permittee shall employ best available control measures for the above-identified material handling

opertion(s) for the purpose of ensuring compliance with the applicable emission limitations. In accordance

with the permit application, the following control measure(s) shall be performed in order to ensure compliance:

Material Handling Operations:

i. Load-in of spent anodes to tumbler feeder;

ii. Transfer to vibrator bin;

iii. Transfer jaw crusher to belt conveyor;

iv. Transfer belt conveyor to cone crusher;

v. Transfer to bucket elevator;

vi. Bucket elevator to chute; and

vii. Transfer to storage bin or covered belt conveyor.

Control Measures:

Use of baghouse dust collection systems with collection points located at each transfer point; and

Maintenance of full enclosure to prevent the escape of fugitive dust.

Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure

compliance.

2.c The permittee shall employ the dust collection system and associated baghouses whenever emissions unit

P023 is in operation.

2.d The permittee shall employ and properly maintain the lids and connecting piping or other comparable

equivalent control measures on the receiving bins at the baghouse hoppers, and the collected dust shall be

treated with a dust suppressant in sufficient quantities to minimize or eliminate any visible emissions of

fugitive dust during the handling of the collected material, if required.

2.e Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rules 3745-17-08 and 3745-31-05.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-11(B) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 215
6

3

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions

Particulate emissions from this emissions unit shall be captured and vented to the baghouses at a rate sufficient

to minimize or eliminate fugitive emissions inside the building.

1.

The pressure drop across each baghouse shall be maintained within the manufacturer's recommended range,

while the emissions unit is in operation, until a pressure drop range that is more representative of actual

operating conditions can be established during the emission testing required in section A.V.2. The appropriate

pressure drop range shall be determined and submitted in writing to the Ohio EPA, Southeast District Office

within one month after completion of the emission tests.

The permittee may petition the Ohio EPA, Southeast District Office for reestablishment of the pressure drop

range provided the permittee can demonstrate to the Ohio EPA, Southeast District Office's satisfaction that the

operating conditions upon which the pressure drop range was previously established are no longer applicable.

2.

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the baghouses serving this emissions unit. The

presence or absence of any visible emissions shall be noted in an operations log. If visible emissions are

observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

1.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible emissions shall

be noted in an operations log. If visible emissions are observed, the permittee shall also note the following in the

operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

2.

The permittee shall properly operate and maintain equipment to monitor the pressure drop across each

baghouse while the emissions unit is in operation. The monitoring equipment shall be installed, calibrated,

operated, and maintained in accordance with the manufacturer's recommendations, instructions, and operating

manual(s). The permittee shall record the pressure drop across the baghouse on a once-per-shift basis.

3.

IV. Reporting Requirements

The permittee shall submit quarterly deviation (excursion) reports that identify all periods of time during which the

pressure drop across each baghouse did not comply with the allowable range specified in section A.II.2.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 216
6

4

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit, and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

February 15 and August 15 of each year and shall cover the previous 6-month period.

2.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the baghouses serving this emissions unit and (b) describe any

corrective actions taken to eliminate the visible particulate emissions. These reports shall be submitted to the

Ohio EPA, Southeast District Office by February 15 and August 15 of each year and shall cover the previous

6-month period.

3.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

The fabric filters shall achieve an outlet emission rate of not greater than 0.030 grain of particulate emissions per

dry standard cubic foot of exhaust gases and no visible particulate emissions from the exhaust stack.

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.2.

1.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 217
6

5

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Particulate emissions shall not exceed 60.51 tons per year.

Applicable Compliance Method:

Compliance with the tons/yr emission limitation may be demonstrated by the following one-time calculations

using emission factors from AP-42, section 13.2.4.3 (01/95) and allowable grain loading of 0.030 gr/dscf:

Stack Emissions:

(0.030 gr particulate emissions/dscf) (22,000 acf/min) (60 min/hr) (8760 hr/yr) (1 lb/7000.0 gr) (1 ton/2000 lb) (2

baghouses) = 49.56 tons particulate emissions/yr

Fugitive Emissions:

From AP-42, 13.2.4.3 Equation 1:

E = k (0.0032) [((U/5)^1.3)/((M/2)^1.4)] lb particulate emissions/ton

k = particle size multiplier (0.74)

U = mean wind speed (4.4 mph)

M = material moisture content (0.025)

E = 1.02 lb particulate emissions/ton

Maximum throughput = 61,320 tons/yr

With 95% baghouse capture efficiency, fugitive particulate emissions =

(7 transfer points) (61,320 tons/yr) (1.02 lb particulate emissions/ton) (1 ton/2000 lb) (1 - 0.95) = 10.95 tons

particulate emissions/yr

Total particulate emissions = 49.56 tons particulate emissions/yr + 10.95 tons particulate emissions/yr = 60.51

tons particulate emissions/yr

1.b

Emission Limitation:

Fugitive visible particulate emissions shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the fugitive visible particulate emission limitation identified above shall be determined in

accordance with Test Method 9 as set forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of

Performance for New Stationary Sources"), as such Appendix existed on July 1, 1996, and the modifications

listed in paragraph (B)(3) of OAC rule 3745-17-03.

1.c

Terms and Conditions for Emissions Units

Title V Final Permit Page 218
6

6

Facility Name:

Facility ID:

Emissions Unit: Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 3 months of the effective date of this permit and every 2.5

years thereafter.

b. The emission testing shall be conducted to demonstrate compliance with the particulate emission

limitations.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate and the visible particulate emission rate for stack emissions: Methods 1 through 5 and Method 22 of 40

CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with prior approval from

the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity.

e. The pressure drop across each baghouse shall be monitored during each run of this emissions test to

establish the pressure drop range as specified in section A.II.2.

2.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 219
1

1

Scrap Carbon Crusher (P923)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 220
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 1-A (P955)

Pots 0-42, 1-A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

1A - consisting of pots 0-42 vented

through dry scrubber reactor #3 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e P955,

P956, P957, and P958).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 221
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 222
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 223
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 224
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 225
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 226
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 227
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 228
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 229
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 230
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 231
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 232
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 233
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 234
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 235
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 236
1

1

Pots 0-42, 1-A (P955)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 237
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 1A (P956)

Pots 43-85, 1A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

1A - consisting of pots 43-85 vented

through dry scrubber reactor #4 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P955,

P956, P957, and P958).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 238
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 239
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 240
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 241
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 242
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 243
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 244
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 245
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 246
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 247
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 248
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 249
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 250
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 251
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 252
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 253
1

1

Pots 43-85, 1A (P956)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 254
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 1-B (P957)

Pots 0-42, 1-B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

1B - consisting of pots 0-42 vented

through dry scrubber reactor #3 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P955,

P956, P957, and P958).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 255
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 256
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 257
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 258
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 259
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 260
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 261
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 262
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 263
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 264
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 265
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 266
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 267
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 268
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 269
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 270
1

1

Pots 0-42, 1-B (P957)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 271
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 1B (P958)

Pots 43-85, 1B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

1B - consisting of pots 43-85 vented

through dry scrubber reactor #4 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P955,

P956, P957, and P958).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 272
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 273
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 274
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 275
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 276
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 277
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 278
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 279
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 280
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 281
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 282
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 283
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 284
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 285
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 286
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 287
1

1

Pots 43-85, 1B (P958)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 288
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 2A (P959)

Pots 0-42, 2A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

1B - consisting of pots 0-42 vented

through dry scrubber reactor #3 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P959,

P960, P961, and P962).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 289
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 290
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 291
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 292
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 293
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 294
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 295
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 296
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 297
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 298
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 299
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 300
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 301
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 302
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 303
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 304
1

1

Pots 0-42, 2A (P959)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 305
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 2A (P960)

Pots 43-85, 2A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

2A - consisting of pots 43-85 vented

through dry scrubber reactor #4 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P959,

P960, P961, and P962).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 306
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 307
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 308
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 309
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 310
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 311
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 312
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 313
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 314
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 315
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 316
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 317
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 318
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 319
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 320
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 321
1

1

Pots 43-85, 2A (P960)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 322
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 2B (P961)

Pots 0-42, 2B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

2B - consisting of pots 0-42 vented

through dry scrubber reactor #3 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P959,

P960, P961, and P962).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 323
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 324
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 325
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 326
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 327
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 328
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 329
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 330
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 331
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 332
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 333
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 334
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 335
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 336
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 337
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 338
1

1

Pots 0-42, 2B (P961)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 339
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 2B (P962)

Pots 43-85, 2B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

2B - consisting of pots 43-85 vented

through dry scrubber reactor #4 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P959,

P960, P961, and P962).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 340
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 341
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 342
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 343
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 344
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 345
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 346
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 347
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 348
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 349
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 350
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 351
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 352
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 353
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 354
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 355
1

1

Pots 43-85, 2B (P962)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 356
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 3A (P963)

Pots 0-42, 3A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

3A - consisting of pots 0-42 vented

through dry scrubber reactor #2 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P963,

P964, P965, and P966).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 357
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 358
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 359
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 360
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 361
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 362
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 363
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 364
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 365
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 366
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 367
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 368
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 369
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 370
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 371
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 372
1

1

Pots 0-42, 3A (P963)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 373
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 3A (P964)

Pots 43-85, 3A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

3A - consisting of pots 43-85 vented

through dry scrubber reactor #5 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P963,

P964, P965, and P966).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 374
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 375
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 376
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 377
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 378
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 379
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 380
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 381
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 382
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 383
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 384
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 385
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 386
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 387
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 388
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 389
1

1

Pots 43-85, 3A (P964)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 390
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 3B (P965)

Pots 0-42, 3B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

3B - consisting of pots 0-42 vented

through dry scrubber reactor #2 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P963,

P964, P965, and P966).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 391
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 392
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 393
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 394
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 395
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 396
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 397
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 398
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 399
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 400
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 401
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 402
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 403
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 404
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 405
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 406
1

1

Pots 0-42, 3B (P965)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 407
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 3B (P966)

Pots 43-85, 3B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

3B - consisting of pots 43-85 vented

through dry scrubber reactor #5 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P963,

P964, P965, and P966).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 408
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 409
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 410
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 411
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 412
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 413
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 414
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 415
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 416
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 417
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 418
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 419
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 420
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 421
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 422
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 423
1

1

Pots 43-85, 3B (P966)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 424
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 4A (P967)

Pots 0-42, 4A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

4A - consisting of pots 0-42 vented

through dry scrubber reactor #2 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P967,

P968, P969, and P970).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 425
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 426
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 427
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 428
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 429
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 430
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 431
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 432
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 433
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 434
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 435
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 436
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 437
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 438
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 439
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 440
1

1

Pots 0-42, 4A (P967)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 441
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 4A (P968)

Pots 43-85, 4A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

4A - consisting of pots 43-85 vented

through dry scrubber reactor #5 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P967,

P968, P969, and P970).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 442
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 443
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 444
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 445
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 446
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 447
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 448
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 449
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 450
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 451
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 452
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 453
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 454
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 455
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 456
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 457
1

1

Pots 43-85, 4A (P968)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 458
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 4B (P969)

Pots 0-42, 4B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

4B - consisting of pots 0-42 vented

through dry scrubber reactor #2 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e P967,

P968, P969, and P970).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 459
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 460
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 461
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 462
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 463
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 464
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 465
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 466
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 467
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 468
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 469
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 470
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 471
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 472
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 473
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 474
1

1

Pots 0-42, 4B (P969)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 475
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 4B (P970)

Pots 43-85, 4B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

4B - consisting of pots 43-85 vented

through dry scrubber reactor #5 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P967,

P968, P969, and P970).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 476
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 477
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 478
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust) , charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 479
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 480
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 481
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 482
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 483
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 484
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 485
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 486
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 487
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 488
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 489
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 490
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 491
1

1

Pots 43-85, 4B (P970)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 492
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 5A (P971)

Pots 0-42, 5A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

5A - consisting of pots 0-42 vented

through dry scrubber reactor #1 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P971,

P972, P973, and P974).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 493
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 494
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 495
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 496
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 497
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 498
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 499
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 500
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 501
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 502
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 503
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 504
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 505
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 506
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 507
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 508
1

1

Pots 0-42, 5A (P971)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 509
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 5A (P972)

Pots 43-85, 5A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

5A - consisting of pots 43-85 vented

through dry scrubber reactor #6 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P971,

P972, P973, and P974).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 510
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 511
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 512
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 513
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 514
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 515
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 516
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 517
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 518
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 519
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 520
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 521
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 522
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 523
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 524
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 525
1

1

Pots 43-85, 5A (P972)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 526
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 5B (P973)

Pots 0-42, 5B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

5B - consisting of pots 0-42 vented

through dry scrubber reactor #1 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P971,

P972, P973, and P974).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 527
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 528
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 529
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 530
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 531
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 532
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 533
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 534
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 535
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 536
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 537
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 538
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 539
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitation shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 540
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 541
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 542
1

1

Pots 0-42, 5B (P973)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 543
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 5B (P974)

Pots 43-85, 5B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

5B - consisting of pots 43-85 vented

through dry scrubber reactor #6 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P971,

P972, P973, and P974).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 544
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 545
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 546
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 547
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 548
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 549
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 550
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 551
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 552
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 553
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 554
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 555
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 556
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 557
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 558
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 559
1

1

Pots 43-85, 5B (P974)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 560
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 6A (P975)

Pots 0-42, 6A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

6A - consisting of pots 0-42 vented

through dry scrubber reactor #1 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P975,

P976, P977, and P978).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 561
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 562
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 563
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 564
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 565
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 566
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 567
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 568
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 569
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 570
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 571
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 572
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 573
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 574
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 575
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 576
1

1

Pots 0-42, 6A (P975)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 577
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 6A (P976)

Pots 43-85, 6A

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

6A - consisting of pots 43-85 vented

through dry scrubber reactor #6 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P975,

P976, P977, and P978).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 578
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 579
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 580
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 581
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 582
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 583
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 584
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 585
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 586
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 587
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 588
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 589
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 590
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 591
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 592
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 593
1

1

Pots 43-85, 6A (P976)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 594
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 0-42, 6B (P977)

Pots 0-42, 6B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

6B - consisting of pots 0-42 vented

through dry scrubber reactor #1 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P975,

P976, P977, and P978).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 595
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 596
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 597
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 598
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 599
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 600
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 601
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 602
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 603
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 604
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 605
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 606
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 607
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 608
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 609
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 610
1

1

Pots 0-42, 6B (P977)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 611
16

1

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Pots 43-85, 6B (P978)

Pots 43-85, 6B

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

alumina reduction potline segment

6B - consisting of pots 43-85 vented

through dry scrubber reactor #6 to

the baghouses and then exhausting

through a single stack

40 CFR Part 63, Subpart LL

[40 CFR 63.843(a)]

The permittee shall not discharge or

cause to be discharged into the

atmosphere any emissions of total

flouride (TF) in excess of 1.5 kg/Mg

(3.0 lbs/ton) of aluminum produced

for each CWPB2 potline (i.e. P975,

P976, P977, and P978).

Any potline, other than a

reconstructed potline, that is

changed such that its applicable

subcategory also changes shall meet

the applicable emission limit in 40

CFR Part 63, Subpart LL for the

original subcategory or the new

subcategory, whichever is more

stringent.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(A)(3) Particulate emissions shall not

exceed 12.6 pounds per hour.

471868 471868

OAC rule 3745-18-06(E)(2) Sulfur dioxide emissions shall not

exceed 240 pounds per hour.

471868 471868

OAC rule 3745-17-07(B)(1) Visible particulate emissions of

fugitive dust shall not exceed 20%

opacity as a 3-minute average.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 612
16

2

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [40 CFR 63.846(b)]

The permittee of an existing potline or anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section.

The permittee may average TF emissions from potlines and demonstrate compliance with the limits in Table

1 of 40 CFR Part 63 Subpart LL using the following procedures:

i. Monthly average emissions of TF shall not exceed the applicable emission limit in Table 1 of 40 CFR Part

63 Subpart LL (for TF emissions) . 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.

ii. To determine compliance with the applicable emission limit in Table 1 of 40 CFR Part 63 Subpart LL for

TF emissions, the owner or operator 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 Secs. 63.847 and 63.849.

The owner or operator 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.

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

OAC rule 3745-17-08(B) The permittee shall employ

reasonably available control

measures that are sufficient to

minimize or eliminate visible

emissions of fugitive dust.

See section A.I.2.c.

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 613
16

3

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b [40 CFR 63.846(d)]

Implementation plan. The permittee shall develop and submit an implementation plan for emission averaging

to the applicable regulatory authority for review and approval according to the following procedures and

requirements:

i. The permittee must submit the implementation plan no later than 6 months before the date that the facility

intends to comply with the emission averaging limits.

ii. The permittee shall include the following information in the implementation plan or in the application for an

operating permit for all emission sources to be included in an emissions average:

(a) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(b) The assigned TF emission limit for each averaging group of potlines or anode bake furnaces;

(c) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(d) The test plan for the measurement of TF emissions in accordance with the requirements in Sec.

63.847(b);

(e) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(f) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

1. A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

2. A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

recordkeeping requirements; and a demonstration, to the satisfaction of

the applicable regulatory authority, that the proposed monitoring frequency is sufficient to represent control

device operating conditions; and

(g) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

iii. Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(a) Whether the content of the plan includes all of the information specified in this section; and

(b) Whether the plan or permit application presents sufficient information to determine that compliance will

be achieved and maintained.

Terms and Conditions for Emissions Units

Title V Final Permit Page 614
16

4

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

iv. Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(a) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(b) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(c) The inclusion of any potline or anode bake furnace while it is shut down; or

(d) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by Sec. 63.850(c), in the emission calculations.

v. Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(a) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(b) To revise the plan prior to the end of the permit term, the permittee shall submit a request to the

applicable regulatory authority; and

(c) The permittee may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

vi. Operation. While operating under an approved implementation plan, the permittee shall monitor the

operating parameters of each control system, keep records, and submit periodic reports as required for each

source subject to this permit.

2.c The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of the individual cells' moveable hoods, skirts, and doors in a manner that contains and captures,

to the extent possible with good engineering design and operation, the fumes released from tapping (except

for crucible cup compressed air exhaust), charging, carbon setting, and all other electrolytic reduction

activities; and

ii. all fugitive dust captured within the RACM area shall be vented to the dry scrubber reactor #3 and the

baghouses associated, in series, with this emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

II. Operational Restrictions

[40 CFR 63.847(e)(5)]

The permittee shall 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 section A.III.5.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 615
16

5

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

II. Operational Restrictions (continued)

[40 CFR 63.847(e)(6)]

The permittee shall 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.

2.

III. Monitoring and/or Record Keeping Requirements

[40 CFR 63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in paragraph (7) of this section, the following monitoring devices shall be installed:

a. For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

b. For dry coke scrubbers, devices for the measurement of coke flow and air flow;

c. For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

d. For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

e. For wet roof scrubbers for secondary emission control:

i. A device for the measurement of total water flow; and

ii. The owner or operator shall inspect each control device at least once each operating day to ensure the control

device is operating properly and record the results of each inspection.

1.

[40 CFR 63.848(g)]

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.

2.

[40 CFR 63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

3.

[40 CFR 63.848(i)]

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.

4.

[40 CFR 63.848(j)]

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.

5.

Terms and Conditions for Emissions Units

Title V Final Permit Page 616
16

6

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[40 CFR 63.848(k)]

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.

6.

[40 CFR 63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

7.

[40 CFR 63.848(m)]

Other control systems. An owner or operator 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.

8.

[40 CFR 63.850(e)]

Recordkeeping. The owner or operator shall maintain files of all information (including all reports and notifications)

required by Sec. 63.10(b) and by this subpart.

a. 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;

b. The owner or operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape,

or on microfiche;

c. The owner or operator may report required information on paper or on a labeled computer disc using

commonly available and compatible computer software; and

d. In addition to the general records required by Sec. 63.10(b), the owner or operator shall maintain records of

the following information:

i. Daily production rate of aluminum;

ii. A copy of the startup, shutdown, and malfunction plan;

iii. Records of design information for paste production plant capture systems;

iv. 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;

v. Records supporting a request for reduced sampling of potlines;

vi. 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;

vii. The current implementation plan for emission averaging and any subsequent amendments;

9.

Terms and Conditions for Emissions Units

Title V Final Permit Page 617
16

7

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

viii. 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 Sec. 63.848(f)(5)(ii), including

the results of each inspection;

ix. 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 Sec. 63.848(g), including the results of each

inspection;

x. For a potline equipped with an HF continuous emission monitor, records of information and data required by

Sec. 63.10(c);

xi. Records documenting the corrective actions taken when the limit(s) for an operating parameter established

under Sec. 63.847(h) were exceeded, when visible emissions indicating abnormal operation were observed from

a control device stack during a daily inspection required under Sec. 63.848(g), or when a problem was detected

during the daily inspection of a wet roof scrubber for potline secondary control required in Sec. 63.848(f)(5)(ii);

xii. 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.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible particulate emissions from the dry scrubber reactor/baghouse stack serving this

emissions unit. The presence or absence of any visible emissions shall be noted in an operations log. If visible

emissions are observed, the permittee shall also note the following in the operations log:

a. the color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to eliminate the visible emissions.

10.

The permittee shall perform daily checks, when the emissions unit is in operation and when the weather

conditions allow, for any visible fugitive particulate emissions from the egress points (i.e., building windows,

doors, roof monitors, etc.) serving this emissions unit. The presence or absence of any visible fugitive emissions

shall be noted in an operations log. If visible emissions are observed, the permittee shall also note the following

in the operations log:

a. the location and color of the emissions;

b. whether the emissions are representative of normal operations;

c. if the emissions are not representative of normal operations, the cause of the abnormal emissions;

d. the total duration of any visible emission incident; and

e. any corrective actions taken to minimize or eliminate the visible emissions.

If visible emissions are present, a visible emission incident has occurred. The observer does not have to

document the exact start and end times for the visible emission incident under item (d) above or continue the

daily check until the incident has ended. The observer may indicate that the visible emission incident was

continuous during the observation period (or, if known, continuous during the operation of the emissions unit).

With respect to the documentation of corrective actions, the observer may indicate that no corrective actions

were taken if the visible emissions were representative of normal operations, or specify the minor corrective

actions that were taken to ensure that the emissions unit continued to operate under normal conditions, or

specify the corrective actions that were taken to eliminate abnormal visible emissions.

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 618
16

8

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

The permittee shall maintain records of the following information for each month:

a. the average SO2 content (in percent sulfur) of the anodes for each shipment of anodes received;

b. the consumption rate of the anodes, in pounds of anodes consumed per pound of aluminum produced;

c. the amount of aluminum produced, in pounds;

d. the total hours of operation; and

e. the average hourly SO2 emission rate, i.e., (a X b X c) / d.

12.

IV. Reporting Requirements

[40 CFR 63.850(a)]

Notifications. The owner or operator shall submit the following written notifications:

a. Notification for an area source that subsequently increases its emissions such that the source is a major

source subject to the standard;

b. Notification that a source is subject to the standard, where the initial startup is before the effective date of the

standard;

c. 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;

d. 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 for which

an application for approval of construction or reconstruction is required;

e. Notification of initial performance test;

f. Notification of initial compliance status;

g. One-time notification for each affected source of the intent to use an HF continuous emission monitor; and

h. 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 Secs. 63.843, 63.844, and 63.846.

1.

[40 CFR 63.850(b)]

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 A.IV.1.f. Except as provided in paragraph 4. of this

section, the owner or operator shall submit a summary of all subsequent performance tests to the applicable

regulatory authority on an annual basis.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 619
16

9

Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

[40 CFR 63.850(c)]

Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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 Sec. 63.6(e)(3), the plan

shall include:

a. Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

b. The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

3.

[40 CFR 63.850(d)]

Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

4.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible

particulate emissions were observed from the dry scrubber reactor/baghouse stack serving this emissions unit

and (b) describe any corrective actions taken to eliminate the visible particulate emissions. These reports shall

be submitted to the Ohio EPA, Southeast District Office by January 31 and July 31 of each year and shall cover

the previous 6-month period.

5.

The permittee shall submit semiannual written reports that (a) identify all days during which any visible fugitive

particulate emissions were observed from the egress points (i.e., building windows, doors, roof monitors, etc.)

serving this emissions unit and (b) describe any corrective actions taken to minimize or eliminate the visible

fugitive particulate emissions. These reports shall be submitted to the Ohio EPA, Southeast District Office by

January 31 and July 31 of each year and shall cover the previous 6-month period.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 620
16

10 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[40 CFR 63.847(b)]

a. Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 63.7, the test plan shall include:

i. Procedures to ensure a minimum of three runs are performed annually for the primary control system for each

source;

ii. 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;

iii. 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;

iv. 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.

1.

[40 CFR 63.847(c)]

Initial performance test. Following approval of the site- specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for potlines within the 12

months prior to the compliance date, the results of that performance test may be used to determine initial

compliance.

2.

[40 CFR 63.847(d)]

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 CFR Part 63, Subpart A, the

approved test plan, and the procedures in this section.

TF emissions from potlines. For each potline, the owner or operator 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 the equation in

40 CFR 63.847(e)(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 Secs. 63.843, 63.844, or 63.846.

Previous control device tests. If the owner or operator 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.

Terms and Conditions for Emissions Units

Title V Final Permit Page 621
16

11 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[40 CFR 63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

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.

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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

4.

[40 CFR 63.848(a)]

TF emissions from potlines. Using the procedures in Sec. 63.847 and in the approved test plan, the owner or

operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner or

operator 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.

5.

[40 CFR 63.848(d)]

Similar potlines. As an alternative to monthly monitoring of TF or POM secondary emissions from each potline

using the test methods in Sec. 63.849, the owner or operator may perform monthly monitoring of TF or POM

secondary emissions from one potline using the test methods in Secs. 63.849 (a) or (b) 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 (a.) through (g.) 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.

a. 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 or new potlines in Secs. 63.843 or 63.844. An alternative method:

i. For TF emissions, must account for or include gaseous fluoride and cannot be based on measurement of

particulate matter or particulate fluoride alone; and

ii. For TF and POM emissions, must meet or exceed Method 14 criteria.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 622
16

12 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

b. An HF continuous emission monitoring system is an approved alternative for the monitoring of TF secondary

emissions.

c. An owner or operator 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.

d. 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.

e. The owner or operator shall submit the results required in paragraph (d.) of this section and all supporting

documentation to the applicable regulatory authority for review and approval.

f. 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 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.

g. 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 CFR 63.848(e)]

Reduced sampling frequency. The owner or operator 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.

a. In the request, the owner or operator 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 (7)(a)(i) or (7)(a)(ii) of this section.

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.

b. An approved alternative requirement must include a test schedule and the method to be used to measure

emissions for performance tests.

c. The owner or operator of a plant that has received approval of an alternative sampling frequency under Sec.

60.194 of this chapter is deemed to have approval of the alternative sampling frequency under this subpart.

7.

Terms and Conditions for Emissions Units

Title V Final Permit Page 623
16

13 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

d. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(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.

e. If emissions in excess of the applicable TF limit occur while performing quarterly sampling approved under

paragraph (7)(a)(ii) of this section, the owner or operator shall immediately return to the monthly sampling

schedule required by section A.V.5 until another request for an alternative sampling frequency is approved by the

applicable regulatory authority.

[40 CFR 63.849(a)]

The owner or operator shall use the following reference methods to determine compliance with the applicable

emission limits for TF and POM emissions:

a. Method 1 in appendix A to part 60 of this chapter for sample and velocity traverses;

b. Method 2 in appendix A to part 60 of this chapter for velocity and volumetric flow rate;

c. Method 3 in appendix A to part 60 of this chapter for gas analysis;

d. 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; and

e. 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.

8.

[40 CFR 63.849(d)]

For sampling using Method 14 in appendix A to part 60 of this chapter, the owner or operator shall install one

Method 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall

meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60 of this

chapter.

9.

[40 CFR 63.849(e)]

The owner or operator may use an alternative test method for TF emissions providing:

a. 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

measurements using the alternative method; or

b. 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 A.V.6.. The results from the alternative method

shall be based on simultaneous sampling using the alternative method and the following reference methods:

i. For TF, Methods 13 and 14 or Method 14A in appendix A to part 60 of this chapter.

10.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

11.

Terms and Conditions for Emissions Units

Title V Final Permit Page 624
16

14 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

Visible particulate emissions from any stack shall not exceed 20% opacity as a 6-minute average, except as

provided by the rule.

Visible particulate emissions of fugitive dust shall not exceed 20% opacity as a 3-minute average.

Applicable Compliance Method:

Compliance with the visible emission limitations shall be determined in accordance with Test Method 9 as set

forth in "Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary

Sources"), as such Appendix existed on July 1, 1996.

11.a

Emission Limitation:

12.6 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission test methods and procedures specified in section

A.V.12.

11.b

Emission Limitation:

240 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance may be demonstrated based on the monitoring and record keeping requirements specified in section

A.III.12. If required, the permittee shall demonstrate compliance with this emission limitation in accordance with

40 CFR Part 60, Appendix A, Method 6. Alternative U.S. EPA-approved test methods may be used with prior

approval from the Ohio EPA.

11.c

Emission Limitation:

total flouride in excess of 1.5 kg/Mg (3.0 lb/ton) of aluminum produced for each CWPB2 potline

Applicable Compliance Method:

Compliance shall be demonstrated based upon the requirements specified in sections A.V.1 through A.V.10.

11.d

Terms and Conditions for Emissions Units

Title V Final Permit Page 625
16

15 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 12 to 24 months after issuance of the permit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rate

for particulates.

c. The following test methods shall be employed to demonstrate compliance with the allowable mass emission

rates: for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test

methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

e. The permittee shall perform visible particulate emission observations in accordance with the procedures

specified in 40 CFR Part 60, Appendix A, Method 9 during each emission test run.

12.

Not later than 60 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office as required by 40 CFR 63.1515(a)(6). The "Intent to Test"

notification shall describe in detail the proposed test methods and procedures, the emissions unit operating

parameters, the time(s) and date(s) of the test(s), and the person(s) who will be conducting the test(s). Failure

to submit such notification for review and approval prior to the test(s) may result in the Ohio EPA, Southeast

District Office's refusal to accept the results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

Terms and Conditions for Emissions Units

Title V Final Permit Page 626
16

16 Facility Name:

Facility ID:

Emissions Unit: Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

VI. Miscellaneous Requirements

[40 CFR 63.851(a), 40 CFR 63.851(b)]

a. The applicable regulatory authority shall notify the owner or operator in writing of the need for additional time

to review the submissions in paragraphs (a)(i) through (a)(v) of this section or of approval or intent to deny

approval of the submissions in paragraphs (a)(i) through (a)(v) of this section within 60 calendar days after receipt

of sufficient information to evaluate the submission. The 60-day period begins after the owner or operator has

been notified that the submission is complete.

i. The test plan in Sec. 63.847(b);

ii. Request to change limits for operating parameters in Sec. 63.847(h)(3);

iii. Request for similar potline monitoring in Sec. 63.848(d)(5);

iv. Request for reduced sampling frequency in Sec. 63.848(e); and

v. Request for an alternative method in Sec. 63.849(e)(2).

b. The applicable regulatory authority shall notify the owner or operator in writing whether the submission is

complete within 30 calendar days of receipt of the original submission or within 30 days of receipt of any

supplementary information that is submitted. When a submission is incomplete, the applicable regulatory

authority shall specify the information needed to complete the submission and shall give the owner or operator

30 calendar days after receipt of the notification to provide the information.

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 627
1

1

Pots 43-85, 6B (P978)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 628
6

1

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

SPL Vitrification #2 (P979)

Spent Potliner vitrification (permit 1 of 2)

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

spent potliner mill

(sizing and handling operation vented

to a combination of nine baghouses

and bin vent filters)

OAC rule 3745-31-05(A)(3)

(PTI 17-1400)

Particulate emissions from the sizing

and handling operation shall not

exceed 0.010 gr/dscf, 1.55 pounds

per hour, and 6.76 tons per year.

Visible particulate emissions of

fugitive dust shall not exceed 10%

opacity as a 3-minute average.

See section A.I.2.c below.

471868 471868

OAC rule 3745-17-07(B)(1) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-17-08(B)(3) The control requirements specified by

this rule are less stringent than the

control requirements established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-17-07(A)(1) Visible particulate emissions from

the sizing and handling baghouses

shall not exceed 20% opacity as a

6-minute average, except as provided

by the rule.

471868 471868

OAC rule 3745-17-11(B) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 629
6

2

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a The material handling operation(s) that are covered by this permit are listed below:

sizing and handling operation:

handling

comminution mill

weigh hopper

transporter

blender

storage silo vents:

baghouse fines silo

sand silo

glass cullet silo

limestone silo #1

limestone silo #2

spent potliner silo

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

storage silo vents OAC rule 3745-31-05(A)(3)

(PTI 17-1400)

Particulate emissions from the

storage silo vents shall not exceed

0.010 gr/dscf or no visible particulate

emissions, whichever is least

restrictive, and 0.0005 ton per year.

See section A.I.2.c below.

471868 471868

OAC rule 3745-17-07(A)(1) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

OAC rule 3745-17-11(B) The emission limitation specified by

this rule is less stringent than the

emission limitation established

pursuant to OAC rule

3745-31-05(A)(3).

471868 471868

Terms and Conditions for Emissions Units

Title V Final Permit Page 630
6

3

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

2.b The permittee shall minimize or eliminate visible emissions of fugitive dust through the employment of

RACM. These measures shall include, but not be limited to, the following:

i. the use of a closed pneumatic system, baghouses, hood enclosures,

ii. unloading of delivery vehicles shall be stopped if visible emissions are noted; and

iii. all fugitive dust captured within the RACM area shall be vented to the baghouses associated, with this

emissions unit.

By employing the above-mentioned RACM, visible emissions of fugitive dust shall be minimized or eliminated

from any non-stack egress point from the building housing this emissions unit, including, but not limited to:

doorways, windows, and roof openings.

Nothing in this paragraph shall prohibit the permittee from employing other control measures to ensure

compliance.

2.c Implementation of the above-mentioned control measure(s) in accordance with the terms and conditions of

this permit is appropriate and sufficient to satisfy the requirements of OAC rule 3745-31-05(A)(3).

II. Operational Restrictions

A broken bag detector shall be maintained on all baghouses serving the spent potliner systems. These detectors

shall be maintained in accordance with manufacturers instructions.

1.

III. Monitoring and/or Record Keeping Requirements

The permittee shall perform daily checks for any visible particulate emissions from each of the material handling

operations identified above. The presence (and location) or absence of any visible emissions shall be noted in an

operations log. If any visible emissions are observed, corrective actions shall be taken to eliminate the visible

emissions and these actions shall also be noted in the operations log.

1.

The above-mentioned inspections (daily checks) shall be performed during representative, normal operating

conditions.

2.

The permittee shall maintain the following records for the broken bag detectors:

a. the dates and time of any alarm; and

b. the actions taken to correct the alarm situation.

3.

IV. Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify each day during which an inspection (daily

check) was not performed by the required frequency. These reports shall be submitted within 30 days after the

occurrence.

1.a

The permittee shall submit deviation (excursion) reports that identify each instance when a control measure, that

was to be performed as a result of an inspection (daily check), was not implemented. These reports shall be

submitted within 30 days after the occurrence.

1.b

The deviation reports shall be submitted in accordance with the reporting requirements of the General Terms and

Conditions of this permit.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Terms and Conditions for Emissions Units

Title V Final Permit Page 631
6

4

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

10% opacity as a 3-minute average for fugitive emissions from the sizing and handling operation.

Visible particulate emissions from the sizing and handling baghouses shall not exceed 20% opacity as a

6-minute average, except as provided by the rule.

Applicable Compliance Method:

Compliance shall be determined in accordance with Test Method 9 as set forth in "Appendix on Test Methods" in

40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as such Appendix existed on July 1,

1996.

1.a

Emission Limitation:

0.010 grain of particulate emissions per dry standard cubic foot of exhaust gases from the sizing and handling

operation

Applicable Compliance Method:

Compliance shall be demonstrated based upon the emission testing methods and procedures specified in 40

CFR Part 60, Appendix A, Methods 1 through 5, as required in section V.2 below.

1.b

Emission Limitation:

no visible particulate emissions from the storage silo vents

Applicable Compliance Method:

Compliance shall be demonstrated using Test Method 22-like visible emission observations. (Although Test

Method 22 applies to fugitive emissions units, the visible/no visible emissions observation technique of Test

Method 22 can be applied to ducted emissions, i.e., Test Method 22-like visible emission observations.)

1.c

Emission Limitation:

1.55 pounds per hour of particulate emissions from the sizing and handling operation

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the emission testing methods and procedures

specified in 40 CFR Part 60, Appendix A, Methods 1 through 5.

1.d

Emission Limitation:

6.76 tons per year of particulate emissions from the sizing and handling operation

Applicable Compliance Method:

The annual allowable was developed by multiplying the maximum hourly allowable particulate emission rate (1.55

lbs/hr) by the maximum annual hours of operation (8760 hours), and then dividing by 2000 lbs/ton. Therefore,

provided compliance is shown with the hourly limitation, compliance shall also be shown with the annual

emission limitation.

1.e

Terms and Conditions for Emissions Units

Title V Final Permit Page 632
6

5

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitation:

Particulate emissions from the storage silo vents shall not exceed 0.010 gr/dscf

Applicable Compliance Method:

If required, compliance shall be demonstrated based upon the emission testing methods and procedures

specified in 40 CFR Part 60, Appendix A, Methods 1 through 5.

1.f

Emission Limitation:

0.0005 ton per year of particulate emissions from the silo storage vents

Applicable Compliance Method:

Compliance shall be determined in accordance with the following equation to calculate the contributions of

baghouse fines, sand, glass cullet, limestone and spent potliner to the total particulate emissions from the

storage silo vents. (The emission factors used in this equation are derived from the equation contained in AP-42,

Section 13.2.4.3, dated January, 1995 for material handling.)

PE = EF x PR x CF x CE

where:

PE = particulate emissions, in tons per year;

EF = emission factor of 0.02 lb/ton for baghouse fines;

emission factor of 0.02 lb/ton for sand;

emission factor of 0.02 lb/ton for glass cullet;

emission factor of 0.02 lb/ton for limestone;

emission factor of 0.00003 lb/ton for spent potliner;

PR = production rate of 1753 tons per year for baghouse fines;

production rate of 2200 tons per year for sand;

production rate of 2200 tons per year for glass cullet;

production rate of 2200 tons per year for limestone;

production rate of 43,800 tons per year for spent potliner;

CF = conversion factor of 1 ton per 2000 lbs; and

CE = 99.9% control efficiency or 0.001.

As long as no visible particulate emissions are evident, compliance with the control efficiency is assumed.

1.g

Terms and Conditions for Emissions Units

Title V Final Permit Page 633
6

6

Facility Name:

Facility ID:

Emissions Unit: SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted within 60 days after the restart of this emissions unit.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates.

c. Test Methods 1 through 5 of 40 CFR Part 60, Appendix A shall be employed to demonstrate compliance with

the allowable mass emission rates.

Alternative U.S. EPA-approved test methods may be used with prior approval from the Ohio EPA.

d. The test(s) shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

2.

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 634
1

1

SPL Vitrification #2 (P979)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 635
9

1

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Anode Baking Furnace-661 (P996)

Anode Baking Furnace-661

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

anode baking furnace 661 OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 19.3 pounds per hour.

471868 471868

40 CFR Part 63, Subpart LL [63.843(c)]

The owner or operator shall not

discharge or cause to be discharged

into the atmosphere any emissions

of total flouride (TF) or polycyclic

organic matter (POM) in excess of

the limits specified below from

emissions units P996, P997, and

P998, combined:

Emissions of TF shall not exceed

0.20 lb/ton of green anode.

Emissions of POM shall not exceed

0.18 lb/ton of green anode.

471868 471868

OAC rule 3745-18-06(D)(2) Sulfur dioxide emissions shall not

exceed 141 pounds per hour.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 636
9

2

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [63.846(a),(c)]

The owner or operator of an existing anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section. The owner or operator may average TF and/or POM

emissions from anode bake furnaces and demonstrate compliance with the limits in Table 3 of 40 CFR Part

63, Subpart LL using the procedures described 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 Table 3 of 40 CFR Part 63, Subpart LL in

any one year; and

(2) To determine compliance with the applicable emission limit in Table 3 of 40 CFR Part 63, Subpart LL for

anode bake furnaces, the owner or operator 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 40 CFR Part 63, Subpart

LL, Secs. 63.847 and 63.849.

2.b [63.846(d)]

The owner or operator shall develop and submit an implementation plan for emission averaging to the

applicable regulatory authority for review and approval according to the following procedures and requirements:

(1) Deadlines. The owner or operator must submit the implementation plan no later than 6 months before the

date that the facility intends to comply with the emission averaging limits.

(2) Contents. The owner or operator shall include the following information in the implementation plan or in

the application for an operating permit for all emission sources to be included in an emissions average:

(i) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(ii) The assigned TF or POM emission limit for each averaging group of potlines or anode bake furnaces;

(iii) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(iv) The test plan for the measurement of TF or POM emissions in accordance with the requirements in Sec.

63.847(b);

(v) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(vi) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

(A) A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

Terms and Conditions for Emissions Units

Title V Final Permit Page 637
9

3

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

(B) A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

record keeping requirements; and a demonstration, to the satisfaction of the applicable regulatory authority,

that the proposed monitoring frequency is sufficient to represent control device operating conditions; and

(vii) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

(3) Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(i) Whether the content of the plan includes all of the information specified in this section; and

(ii) Whether the plan or permit application presents sufficient information to determine that compliance will be

achieved and maintained.

(4) Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(i) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(ii) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(iii) The inclusion of any potline or anode bake furnace while it is shut down; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by section A.IV.1.a.(2), in the emission calculations.

(5) Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(i) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(ii) To revise the plan prior to the end of the permit term, the owner or operator shall submit a request to the

applicable regulatory authority; and

(iii) The owner or operator may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

(6) Operation. While operating under an approved implementation plan, the owner or operator shall monitor

the operating parameters of each control system, keep records, and submit periodic reports as required for

each source subject to 40 CFR Part 63, Subpart LL and this permit.

II. Operational Restrictions

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 638
9

4

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

[63.848(c)]

TF and POM emissions from anode bake furnaces. Using the procedures in 40 CFR Part 63.847, section A.V of

this permit, and the approved test plan, the owner or operator shall monitor TF and POM emissions from each

anode bake furnace on an annual basis. The owner or operator 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 owner or operator must include all valid runs in the annual average.

1.

[63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in section A.III.8, the following monitoring devices shall be installed:

(1) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

(2) For dry coke scrubbers, devices for the measurement of coke flow and air flow;

(3) For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

(4) For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

(5) For wet roof scrubbers for secondary emission control:

(i) A device for the measurement of total water flow; and

(ii) The owner or operator shall inspect each control device at least once each operating day to ensure the

control device is operating properly and record the results of each inspection.

2.

[63.848(g)]

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.

3.

[63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

4.

[63.848(i)]

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.

5.

[63.848(j)]

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.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 639
9

5

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[63.848(k)]

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.

7.

[63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

8.

[63.850(e)(4)]

In addition to the general records required by Sec. 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; and

(iii) a copy of the startup, shutdown, and malfunction plan.

9.

IV. Reporting Requirements

[63.850(b), (c), (d)]

Notifications. The owner or operator shall submit the following written notifications:

(1) Performance test reports. The owner or operator shall report the results of the initial performance test.

Except as provided in paragraph (3) of this section, the owner or operator shall submit a summary of all

subsequent performance tests to the applicable regulatory authority on an annual basis.

(2) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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

permitting authority may review the plan upon request. In addition to the information required in Sec. 63.6(e)(3),

the plan shall include:

(i) Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

(ii) The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

1.

(3) Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 640
9

6

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[63.847(b)]

Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 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.

1.

[63.847(c)]

Initial performance test. Following approval of the site-specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for the anode bake

furnace within the 12 months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

[63.847(d)(4)]

For each anode bake furnace, the owner or operator 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 the

equations in paragraphs (e)(3) and (e)(4) of 40 CFR Part 63, Subpart LL, Section 63.847, the owner or operator

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 Secs. 63.843, 63.844, or 63.846

and this permit.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 641
9

7

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

(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 40 CFR Part 63, Subpart LL and this permit.

(2) 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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

3.

[63.849(a)]

The owner or operator 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 40 CFR Part 60 for sample and velocity traverses;

(2) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;

(3) Method 3 in appendix A to 40 CFR Part 60 for gas analysis;

(4) Method 13A or Method 13B in appendix A to 40 CFR Part 60, 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 40 CFR Part 60 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 40 CFR Part 63 Subpart LL 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 40 CFR Part 63 Subpart LL and Method 14 in appendix A to 40 CFR Part 60 or

an approved alternative method for the concentration of POM where emissions are sampled from roof monitors

not employing wet roof scrubbers.

4.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

5.

Emission Limitation:

19.3 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 642
9

8

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

0.20 lb of TF per ton of green anode from emissions units P996, P997, and P998, combined

0.18 lb of POM per ton of green anode from emissions units P996, P997, and P998, combined

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in sections A.V.1 through

A.V.4.

5.b

Emission Limitation:

141 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.c

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

5.d

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted approximately 1.5 years after permit issuance and within 12 months

prior to permit expiration.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates and sulfur dioxide.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate(s): for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A and for sulfur dioxide, Methods 1

through 4 and 6 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

d. The tests shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 643
9

9

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 644
1

1

Anode Baking Furnace-661 (P996)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 645
9

1

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Anode Baking Furnace-662 (P997)

Anode Baking Furnace-662

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

anode baking furnace 662 OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 19.3 pounds per hour.

471868 471868

40 CFR Part 63, Subpart LL [63.843(c)]

The owner or operator shall not

discharge or cause to be discharged

into the atmosphere any emissions

of total flouride (TF) or polycyclic

organic matter (POM) in excess of

the limits specified below from

emissions units P996, P997, and

P998, combined:

Emissions of TF shall not exceed

0.20 lb/ton of green anode.

Emissions of POM shall not exceed

0.18 lb/ton of green anode.

471868 471868

OAC rule 3745-18-06(D)(2) Sulfur dioxide emissions shall not

exceed 141 pounds per hour.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 646
9

2

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [63.846(a),(c)]

The owner or operator of an existing anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section. The owner or operator may average TF and/or POM

emissions from anode bake furnaces and demonstrate compliance with the limits in Table 3 of 40 CFR Part

63, Subpart LL using the procedures described 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 Table 3 of 40 CFR Part 63, Subpart LL in

any one year; and

(2) To determine compliance with the applicable emission limit in Table 3 of 40 CFR Part 63, Subpart LL for

anode bake furnaces, the owner or operator 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 40 CFR Part 63, Subpart

LL, Secs. 63.847 and 63.849.

2.b [63.846(d)]

The owner or operator shall develop and submit an implementation plan for emission averaging to the

applicable regulatory authority for review and approval according to the following procedures and requirements:

(1) Deadlines. The owner or operator must submit the implementation plan no later than 6 months before the

date that the facility intends to comply with the emission averaging limits.

(2) Contents. The owner or operator shall include the following information in the implementation plan or in

the application for an operating permit for all emission sources to be included in an emissions average:

(i) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(ii) The assigned TF or POM emission limit for each averaging group of potlines or anode bake furnaces;

(iii) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(iv) The test plan for the measurement of TF or POM emissions in accordance with the requirements in Sec.

63.847(b);

(v) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(vi) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

(A) A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

Terms and Conditions for Emissions Units

Title V Final Permit Page 647
9

3

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

(B) A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

record keeping requirements; and a demonstration, to the satisfaction of the applicable regulatory authority,

that the proposed monitoring frequency is sufficient to represent control device operating conditions; and

(vii) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

(3) Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(i) Whether the content of the plan includes all of the information specified in this section; and

(ii) Whether the plan or permit application presents sufficient information to determine that compliance will be

achieved and maintained.

(4) Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(i) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(ii) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(iii) The inclusion of any potline or anode bake furnace while it is shut down; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by section A.IV.1.a.(2), in the emission calculations.

(5) Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(i) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(ii) To revise the plan prior to the end of the permit term, the owner or operator shall submit a request to the

applicable regulatory authority; and

(iii) The owner or operator may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

(6) Operation. While operating under an approved implementation plan, the owner or operator shall monitor

the operating parameters of each control system, keep records, and submit periodic reports as required for

each source subject to 40 CFR Part 63, Subpart LL and this permit.

II. Operational Restrictions

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 648
9

4

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

[63.848(c)]

TF and POM emissions from anode bake furnaces. Using the procedures in 40 CFR Part 63.847, section A.V of

this permit, and the approved test plan, the owner or operator shall monitor TF and POM emissions from each

anode bake furnace on an annual basis. The owner or operator 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 owner or operator must include all valid runs in the annual average.

1.

[63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in section A.III.8, the following monitoring devices shall be installed:

(1) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

(2) For dry coke scrubbers, devices for the measurement of coke flow and air flow;

(3) For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

(4) For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

(5) For wet roof scrubbers for secondary emission control:

(i) A device for the measurement of total water flow; and

(ii) The owner or operator shall inspect each control device at least once each operating day to ensure the

control device is operating properly and record the results of each inspection.

2.

[63.848(g)]

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.

3.

[63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

4.

[63.848(i)]

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.

5.

[63.848(j)]

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.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 649
9

5

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[63.848(k)]

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.

7.

[63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

8.

[63.850(e)(4)]

In addition to the general records required by Sec. 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; and

(iii) a copy of the startup, shutdown, and malfunction plan.

9.

IV. Reporting Requirements

[63.850(b), (c), (d)]

Notifications. The owner or operator shall submit the following written notifications:

(1) Performance test reports. The owner or operator shall report the results of the initial performance test.

Except as provided in paragraph (3) of this section, the owner or operator shall submit a summary of all

subsequent performance tests to the applicable regulatory authority on an annual basis.

(2) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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

permitting authority may review the plan upon request. In addition to the information required in Sec. 63.6(e)(3),

the plan shall include:

(i) Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

(ii) The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

1.

(3) Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 650
9

6

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[63.847(b)]

Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 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.

1.

[63.847(c)]

Initial performance test. Following approval of the site-specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for the anode bake

furnace within the 12 months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

[63.847(d)(4)]

For each anode bake furnace, the owner or operator 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 the

equations in paragraphs (e)(3) and (e)(4) of 40 CFR Part 63, Subpart LL, Section 63.847, the owner or operator

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 Secs. 63.843, 63.844, or 63.846

and this permit.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 651
9

7

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

(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 40 CFR Part 63, Subpart LL and this permit.

(2) 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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

3.

[63.849(a)]

The owner or operator 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 40 CFR Part 60 for sample and velocity traverses;

(2) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;

(3) Method 3 in appendix A to 40 CFR Part 60 for gas analysis;

(4) Method 13A or Method 13B in appendix A to 40 CFR Part 60, 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 40 CFR Part 60 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 40 CFR Part 63 Subpart LL 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 40 CFR Part 63 Subpart LL and Method 14 in appendix A to 40 CFR Part 60 or

an approved alternative method for the concentration of POM where emissions are sampled from roof monitors

not employing wet roof scrubbers.

4.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

5.

Emission Limitation:

19.3 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 652
9

8

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

0.20 lb of TF per ton of green anode from emissions units P996, P997, and P998, combined

0.18 lb of POM per ton of green anode from emissions units P996, P997, and P998, combined

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in sections A.V.1 through

A.V.4.

5.b

Emission Limitation:

141 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.c

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

5.d

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted approximately 1.5 years after permit issuance and within 12 months

prior to permit expiration.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates and sulfur dioxide.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate(s): for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A and for sulfur dioxide, Methods 1

through 4 and 6 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

d. The tests shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 653
9

9

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 654
1

1

Anode Baking Furnace-662 (P997)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 655
9

1

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Anode Baking Furnace-663 (P998)

Anode Baking Furnace-663

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

anode baking furnace 663 OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 19.3 pounds per hour.

471868 471868

40 CFR Part 63, Subpart LL [63.843(c)]

The owner or operator shall not

discharge or cause to be discharged

into the atmosphere any emissions

of total flouride (TF) or polycyclic

organic matter (POM) in excess of

the limits specified below from

emissions units P996, P997, and

P998, combined:

Emissions of TF shall not exceed

0.20 lb/ton of green anode.

Emissions of POM shall not exceed

0.18 lb/ton of green anode.

471868 471868

OAC rule 3745-18-06(D)(2) Sulfur dioxide emissions shall not

exceed 141 pounds per hour.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 656
9

2

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [63.846(a),(c)]

The owner or operator of an existing anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section. The owner or operator may average TF and/or POM

emissions from anode bake furnaces and demonstrate compliance with the limits in Table 3 of 40 CFR Part

63, Subpart LL using the procedures described 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 Table 3 of 40 CFR Part 63, Subpart LL in

any one year; and

(2) To determine compliance with the applicable emission limit in Table 3 of 40 CFR Part 63, Subpart LL for

anode bake furnaces, the owner or operator 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 40 CFR Part 63, Subpart

LL, Secs. 63.847 and 63.849.

2.b [63.846(d)]

The owner or operator shall develop and submit an implementation plan for emission averaging to the

applicable regulatory authority for review and approval according to the following procedures and requirements:

(1) Deadlines. The owner or operator must submit the implementation plan no later than 6 months before the

date that the facility intends to comply with the emission averaging limits.

(2) Contents. The owner or operator shall include the following information in the implementation plan or in

the application for an operating permit for all emission sources to be included in an emissions average:

(i) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(ii) The assigned TF or POM emission limit for each averaging group of potlines or anode bake furnaces;

(iii) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(iv) The test plan for the measurement of TF or POM emissions in accordance with the requirements in Sec.

63.847(b);

(v) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(vi) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

(A) A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

Terms and Conditions for Emissions Units

Title V Final Permit Page 657
9

3

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

(B) A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

record keeping requirements; and a demonstration, to the satisfaction of the applicable regulatory authority,

that the proposed monitoring frequency is sufficient to represent control device operating conditions; and

(vii) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

(3) Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(i) Whether the content of the plan includes all of the information specified in this section; and

(ii) Whether the plan or permit application presents sufficient information to determine that compliance will be

achieved and maintained.

(4) Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(i) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(ii) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(iii) The inclusion of any potline or anode bake furnace while it is shut down; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by section A.IV.1.a.(2), in the emission calculations.

(5) Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(i) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(ii) To revise the plan prior to the end of the permit term, the owner or operator shall submit a request to the

applicable regulatory authority; and

(iii) The owner or operator may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

(6) Operation. While operating under an approved implementation plan, the owner or operator shall monitor

the operating parameters of each control system, keep records, and submit periodic reports as required for

each source subject to 40 CFR Part 63, Subpart LL and this permit.

II. Operational Restrictions

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 658
9

4

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

[63.848(c)]

TF and POM emissions from anode bake furnaces. Using the procedures in 40 CFR Part 63.847, section A.V of

this permit, and the approved test plan, the owner or operator shall monitor TF and POM emissions from each

anode bake furnace on an annual basis. The owner or operator 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 owner or operator must include all valid runs in the annual average.

1.

[63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in section A.III.8, the following monitoring devices shall be installed:

(1) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

(2) For dry coke scrubbers, devices for the measurement of coke flow and air flow;

(3) For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

(4) For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

(5) For wet roof scrubbers for secondary emission control:

(i) A device for the measurement of total water flow; and

(ii) The owner or operator shall inspect each control device at least once each operating day to ensure the

control device is operating properly and record the results of each inspection.

2.

[63.848(g)]

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.

3.

[63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

4.

[63.848(i)]

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.

5.

[63.848(j)]

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.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 659
9

5

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[63.848(k)]

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.

7.

[63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

8.

[63.850(e)(4)]

In addition to the general records required by Sec. 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; and

(iii) a copy of the startup, shutdown, and malfunction plan.

9.

IV. Reporting Requirements

[63.850(b), (c), (d)]

Notifications. The owner or operator shall submit the following written notifications:

(1) Performance test reports. The owner or operator shall report the results of the initial performance test.

Except as provided in paragraph (3) of this section, the owner or operator shall submit a summary of all

subsequent performance tests to the applicable regulatory authority on an annual basis.

(2) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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

permitting authority may review the plan upon request. In addition to the information required in Sec. 63.6(e)(3),

the plan shall include:

(i) Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

(ii) The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

1.

(3) Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 660
9

6

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[63.847(b)]

Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 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.

1.

[63.847(c)]

Initial performance test. Following approval of the site-specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for the anode bake

furnace within the 12 months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

[63.847(d)(4)]

For each anode bake furnace, the owner or operator 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 the

equations in paragraphs (e)(3) and (e)(4) of 40 CFR Part 63, Subpart LL, Section 63.847, the owner or operator

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 Secs. 63.843, 63.844, or 63.846

and this permit.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 661
9

7

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

(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 40 CFR Part 63, Subpart LL and this permit.

(2) 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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

3.

[63.849(a)]

The owner or operator 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 40 CFR Part 60 for sample and velocity traverses;

(2) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;

(3) Method 3 in appendix A to 40 CFR Part 60 for gas analysis;

(4) Method 13A or Method 13B in appendix A to 40 CFR Part 60, 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 40 CFR Part 60 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 40 CFR Part 63 Subpart LL 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 40 CFR Part 63 Subpart LL and Method 14 in appendix A to 40 CFR Part 60 or

an approved alternative method for the concentration of POM where emissions are sampled from roof monitors

not employing wet roof scrubbers.

4.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

5.

Emission Limitation:

19.3 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 662
9

8

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

0.20 lb of TF per ton of green anode from emissions units P996, P997, and P998, combined

0.18 lb of POM per ton of green anode from emissions units P996, P997, and P998, combined

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in sections A.V.1 through

A.V.4.

5.b

Emission Limitation:

141 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.c

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

5.d

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted approximately 1.5 years after permit issuance and within 12 months

prior to permit expiration.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates and sulfur dioxide.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate(s): for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A and for sulfur dioxide, Methods 1

through 4 and 6 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

d. The tests shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 663
9

9

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 664
1

1

Anode Baking Furnace-663 (P998)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 665
9

1

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

Anode Baking Furnace-664 (P999)

Anode Baking Furnace-664

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

anode baking furnace 664 OAC rule 3745-17-11(B)(1) Particulate emissions shall not

exceed 19.3 pounds per hour.

471868 471868

40 CFR Part 63, Subpart LL [63.843(c)]

The owner or operator shall not

discharge or cause to be discharged

into the atmosphere any emissions

of total flouride (TF) or polycyclic

organic matter (POM) in excess of

the limits specified below from

emissions units P999 and P900,

combined:

Emissions of TF shall not exceed

0.20 lb/ton of green anode.

Emissions of POM shall not exceed

0.18 lb/ton of green anode.

471868 471868

OAC rule 3745-18-06(D)(2) Sulfur dioxide emissions shall not

exceed 141 pounds per hour.

471868 471868

OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 666
9

2

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions

2.a [63.846(a),(c)]

The owner or operator of an existing anode bake furnace may demonstrate compliance by emission

averaging according to the procedures in this section. The owner or operator may average TF and/or POM

emissions from anode bake furnaces and demonstrate compliance with the limits in Table 3 of 40 CFR Part

63, Subpart LL using the procedures described 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 Table 3 of 40 CFR Part 63, Subpart LL in

any one year; and

(2) To determine compliance with the applicable emission limit in Table 3 of 40 CFR Part 63, Subpart LL for

anode bake furnaces, the owner or operator 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 40 CFR Part 63, Subpart

LL, Secs. 63.847 and 63.849.

2.b [63.846(d)]

The owner or operator shall develop and submit an implementation plan for emission averaging to the

applicable regulatory authority for review and approval according to the following procedures and requirements:

(1) Deadlines. The owner or operator must submit the implementation plan no later than 6 months before the

date that the facility intends to comply with the emission averaging limits.

(2) Contents. The owner or operator shall include the following information in the implementation plan or in

the application for an operating permit for all emission sources to be included in an emissions average:

(i) The identification of all emission sources (potlines or anode bake furnaces) in the average;

(ii) The assigned TF or POM emission limit for each averaging group of potlines or anode bake furnaces;

(iii) The specific control technology or pollution prevention measure to be used for each emission source in

the averaging group and the date of its installation or application. If the pollution prevention measure reduces

or eliminates emissions from multiple sources, the owner or operator must identify each source;

(iv) The test plan for the measurement of TF or POM emissions in accordance with the requirements in Sec.

63.847(b);

(v) The operating parameters to be monitored for each control system or device and a description of how the

operating limits will be determined;

(vi) If the owner or operator requests to monitor an alternative operating parameter pursuant to Sec. 63.848(l):

(A) A description of the parameter(s) to be monitored and an explanation of the criteria used to select the

parameter(s); and

Terms and Conditions for Emissions Units

Title V Final Permit Page 667
9

3

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

2. Additional Terms and Conditions (continued)

(B) A description of the methods and procedures that will be used to demonstrate that the parameter

indicates proper operation of the control device; the frequency and content of monitoring, reporting, and

record keeping requirements; and a demonstration, to the satisfaction of the applicable regulatory authority,

that the proposed monitoring frequency is sufficient to represent control device operating conditions; and

(vii) A demonstration that compliance with each of the applicable emission limit(s) will be achieved under

representative operating conditions.

(3) Approval criteria. Upon receipt, the regulatory authority shall review and approve or disapprove the plan or

permit application according to the following criteria:

(i) Whether the content of the plan includes all of the information specified in this section; and

(ii) Whether the plan or permit application presents sufficient information to determine that compliance will be

achieved and maintained.

(4) Prohibitions. The applicable regulatory authority shall not approve an implementation plan or permit

application containing any of the following provisions:

(i) Any averaging between emissions of differing pollutants or between differing sources. Emission averaging

shall not be allowed between TF and POM, and emission averaging shall not be allowed between potlines

and bake furnaces;

(ii) The inclusion of any emission source other than an existing potline or existing anode bake furnace or the

inclusion of any potline or anode bake plant not subject to the same operating permit;

(iii) The inclusion of any potline or anode bake furnace while it is shut down; or

(iv) The inclusion of any periods of startup, shutdown, or malfunction, as described in the startup, shutdown,

and malfunction plan required by section A.IV.1.a.(2), in the emission calculations.

(5) Term. Following review, the applicable regulatory authority shall approve the plan or permit application,

request changes, or request additional information. Once the applicable regulatory authority receives any

additional information requested, the applicable regulatory authority shall approve or disapprove the plan or

permit application within 120 days.

(i) The applicable regulatory authority shall approve the plan for the term of the operating permit;

(ii) To revise the plan prior to the end of the permit term, the owner or operator shall submit a request to the

applicable regulatory authority; and

(iii) The owner or operator may submit a request to the applicable regulatory authority to implement emission

averaging after the applicable compliance date.

(6) Operation. While operating under an approved implementation plan, the owner or operator shall monitor

the operating parameters of each control system, keep records, and submit periodic reports as required for

each source subject to 40 CFR Part 63, Subpart LL and this permit.

II. Operational Restrictions

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 668
9

4

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements

[63.848(c)]

TF and POM emissions from anode bake furnaces. Using the procedures in 40 CFR Part 63.847, section A.V of

this permit, and the approved test plan, the owner or operator shall monitor TF and POM emissions from each

anode bake furnace on an annual basis. The owner or operator 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 owner or operator must include all valid runs in the annual average.

1.

[63.848(f)]

Monitoring parameters for emission control devices. The owner or operator 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. Except as provided in section A.III.8, the following monitoring devices shall be installed:

(1) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow;

(2) For dry coke scrubbers, devices for the measurement of coke flow and air flow;

(3) For wet scrubbers as the primary control system, devices for the measurement of water flow and air flow;

(4) For electrostatic precipitators, devices for the measurement of voltage and secondary current; and

(5) For wet roof scrubbers for secondary emission control:

(i) A device for the measurement of total water flow; and

(ii) The owner or operator shall inspect each control device at least once each operating day to ensure the

control device is operating properly and record the results of each inspection.

2.

[63.848(g)]

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.

3.

[63.848(h)]

Corrective action. If a monitoring device for a primary control device measures an operating parameter outside the

limit(s) established pursuant to Sec. 63.847(h), 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.

4.

[63.848(i)]

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.

5.

[63.848(j)]

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.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 669
9

5

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

III. Monitoring and/or Record Keeping Requirements (continued)

[63.848(k)]

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.

7.

[63.848(l)]

Alternative operating parameters. The owner or operator may monitor alternative control device operating

parameters subject to prior written approval by the applicable regulatory authority.

8.

[63.850(e)(4)]

In addition to the general records required by Sec. 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; and

(iii) a copy of the startup, shutdown, and malfunction plan.

9.

IV. Reporting Requirements

[63.850(b), (c), (d)]

Notifications. The owner or operator shall submit the following written notifications:

(1) Performance test reports. The owner or operator shall report the results of the initial performance test.

Except as provided in paragraph (3) of this section, the owner or operator shall submit a summary of all

subsequent performance tests to the applicable regulatory authority on an annual basis.

(2) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a

written plan as described in Sec. 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

permitting authority may review the plan upon request. In addition to the information required in Sec. 63.6(e)(3),

the plan shall include:

(i) Procedures, including corrective actions, to be followed if a monitoring device measures an operating

parameter outside the limit(s) established under Sec. 63.847(h), 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 Sec. 63.848(g), or if a problem is detected during the daily inspection of a wet roof

scrubber for potline secondary emission control required in Sec. 63.848(f)(5)(ii); and

(ii) The owner or operator shall also keep records of each event as required by Sec. 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 Sec. 63.6(e)(3)(iv).

1.

(3) Excess emissions report. As required by Sec. 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 Sec. 63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required

as a result of excess emissions.

Terms and Conditions for Emissions Units

Title V Final Permit Page 670
9

6

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements

[63.847(b)]

Test plan. The owner or operator shall prepare a site-specific test plan prior to the initial performance test

according to the requirements of Sec. 63.7(c) of this part. The test plan must include procedures for conducting

the initial performance test and for subsequent performance tests required in Sec. 63.848 for emission

monitoring. In addition to the information required by Sec. 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.

1.

[63.847(c)]

Initial performance test. Following approval of the site-specific test plan, the owner or operator shall conduct an

initial performance test during the first month following the compliance date in accordance with the procedures in

this section. If a performance test has been conducted on the primary control system for the anode bake

furnace within the 12 months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

[63.847(d)(4)]

For each anode bake furnace, the owner or operator 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 the

equations in paragraphs (e)(3) and (e)(4) of 40 CFR Part 63, Subpart LL, Section 63.847, the owner or operator

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 Secs. 63.843, 63.844, or 63.846

and this permit.

2.

Terms and Conditions for Emissions Units

Title V Final Permit Page 671
9

7

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

[63.847(h)]

Selection of monitoring parameters. The owner or operator shall determine the operating limits and monitoring

frequency for each control device that is to be monitored as required in Sec. 63.848(f).

(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 40 CFR Part 63, Subpart LL and this permit.

(2) 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 change the

applicable limit(s). The redetermined limits shall become effective upon approval by the applicable regulatory

authority.

3.

[63.849(a)]

The owner or operator 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 40 CFR Part 60 for sample and velocity traverses;

(2) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric flow rate;

(3) Method 3 in appendix A to 40 CFR Part 60 for gas analysis;

(4) Method 13A or Method 13B in appendix A to 40 CFR Part 60, 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 40 CFR Part 60 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 40 CFR Part 63 Subpart LL 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 40 CFR Part 63 Subpart LL and Method 14 in appendix A to 40 CFR Part 60 or

an approved alternative method for the concentration of POM where emissions are sampled from roof monitors

not employing wet roof scrubbers.

4.

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

5.

Emission Limitation:

19.3 pounds per hour of particulate emissions

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.a

Terms and Conditions for Emissions Units

Title V Final Permit Page 672
9

8

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Emission Limitations:

0.20 lb of TF per ton of green anode from emissions units P999 and P900, combined

0.18 lb of POM per ton of green anode from emissions units P999 and P900, combined

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in sections A.V.1 through

A.V.4.

5.b

Emission Limitation:

141 pounds per hour of sulfur dioxide

Applicable Compliance Method:

Compliance shall be demonstrated based upon the methods and procedures specified in section A.V.6.

5.c

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

5.d

The permittee shall conduct, or have conducted, emission testing for this emissions unit in accordance with the

following requirements:

a. The emission testing shall be conducted approximately 1.5 years after permit issuance and within 12 months

prior to permit expiration.

b. The emission testing shall be conducted to demonstrate compliance with the allowable mass emission rates

for particulates and sulfur dioxide.

c. The following test method(s) shall be employed to demonstrate compliance with the allowable mass emission

rate(s): for particulates, Methods 1 through 5 of 40 CFR Part 60, Appendix A and for sulfur dioxide, Methods 1

through 4 and 6 of 40 CFR Part 60, Appendix A. Alternative U.S. EPA-approved test methods may be used with

prior approval from the Ohio EPA.

d. The tests shall be conducted while the emissions unit is operating at or near its maximum capacity, unless

otherwise specified or approved by the Ohio EPA, Southeast District Office.

6.

Terms and Conditions for Emissions Units

Title V Final Permit Page 673
9

9

Facility Name:

Facility ID:

Emissions Unit: Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

V. Testing Requirements (continued)

Not later than 30 days prior to the proposed test date(s), the permittee shall submit an "Intent to Test"

notification to the Ohio EPA, Southeast District Office. The "Intent to Test" notification shall describe in detail

the proposed test methods and procedures, the emissions unit operating parameters, the time(s) and date(s) of

the test(s), and the person(s) who will be conducting the test(s). Failure to submit such notification for review

and approval prior to the test(s) may result in the Ohio EPA, Southeast District Office's refusal to accept the

results of the emission test(s).

Personnel from the Ohio EPA, Southeast District Office shall be permitted to witness the test(s), examine the

testing equipment, and acquire data and information necessary to ensure that the operation of the emissions unit

and the testing procedures provide a valid characterization of the emissions from the emissions unit and/or the

performance of the control equipment.

A comprehensive written report on the results of the emission test(s) shall be signed by the person or persons

responsible for the tests and submitted to the Ohio EPA, Southeast District Office within 30 days following

completion of the test(s). The permittee may request additional time for the submittal of the written report, where

warranted, with prior approval from the Ohio EPA, Southeast District Office.

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 674
1

1

Anode Baking Furnace-664 (P999)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 675
2

1

Facility Name:

Facility ID:

Emissions Unit: Paint Booth Bld 212 (R001)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Part III - Terms and Conditions for Emissions Units

2. Additional Terms and Conditions

2.a The permittee shall not employ any photochemically reactive material in this emissions unit.

Note: The definition of "photochemically reactive material" is stated in OAC rule 3745-21-01(C)(5).

II. Operational Restrictions

The permittee shall employ a spray booth filter having a design control efficiency for particulates greater than

98% during any operation of this emissions unit.

1.

III. Monitoring and/or Record Keeping Requirements

The permittee shall collect and record for each day for the coating operation the company identification for each

coating, thinner, and cleanup material employed and a statement as to whether or not each is a

"photochemically reactive material".

1.

The permittee shall maintain daily records that document any time periods when the spray booth filter system

was not in service when the emissions unit was in operation.

2.

IV. Reporting Requirements

The permittee shall submit deviation (excursion) reports that identify all periods of time when a photochemically

reactive material was employed in this emissions unit. These reports shall be submitted within 30 days after the

occurrence.

1.

Paint Booth Bld 212 (R001)

Paint Shop (Building 212) Paint Booth 

A.

I. Applicable Emissions Limitations and/or Control Requirements

1.

State and Federally Enforceable Section

Emissions Unit ID:

Activity Description:

The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

Building 224 Spray Booth (R001) OAC rule 3745-17-07(A) Visible particulate emissions from

any stack shall not exceed 20%

opacity as a 6-minute average,

except as provided by the rule.

471868 471868

OAC rule 3745-17-11(B) 0.551 pound per hour of particulate

emissions

471868 471868

OAC rule 3745-21-07(G)(2) none

See A.I.2.a below.

471868 471868

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 676
2

2

Facility Name:

Facility ID:

Emissions Unit: Paint Booth Bld 212 (R001)

Ormet Primary Aluminum Corp. 

06-56-00-0001

IV. Reporting Requirements (continued)

The permittee shall notify the Director (the Ohio EPA, Southeast District Office) in writing of any daily record

showing that the spray booth filter system was not in service when the emissions unit was in operation. The

notification shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southeast

District Office) within 30 days after the event occurs.

2.

V. Testing Requirements

Compliance with the emission limitations in section A.I.1 of these terms and conditions shall be determined in

accordance with the following methods:

1.

Emission Limitation:

20% opacity as a 6-minute average

Applicable Compliance Method:

Compliance with the visible emission limit shall be determined in accordance with Test Method 9 as set forth in

"Appendix on Test Methods" in 40 CFR, Part 60 ("Standards of Performance for New Stationary Sources"), as

such Appendix existed on July 1, 1996. No visible emission testing is specifically required to demonstrate

compliance with this limit but, if appropriate, may be requested pursuant to OAC rule 3745-15-04(A).

1.a

Emission Limitation:

0.551 lb/hr of particulate emissions

Applicable Compliance Method:

To determine the actual worst case particulate emission rate, the following equation shall be used:

E = (M) * (1-TE) * (1-CE)

where:

E = particulate emission rate (lbs/hr)

M = maximum coating solids usage rate (lbs/hr)

TE = transfer efficiency, which is the ratio of the amount of coating solids deposited on the coated part to the

amount of coating solids used

CE = control efficiency of the control equipment - If more than one piece of control equipment is used in series,

the equation should be multiplied by additional (1-CE) terms for each additional piece of equipment.

If required, the permittee shall demonstrate compliance with this emission limitation in accordance with the

methods and procedures specified in OAC rule 3745-17-03(B)(10).

1.b

VI. Miscellaneous Requirements

None

Terms and Conditions for Emissions Units

Title V Final Permit Page 677
1

1

Paint Booth Bld 212 (R001)

Ormet Primary Aluminum Corp. 

06-56-00-0001

Facility Name:

Facility ID:

Emissions Unit:

B. State Enforceable Section

I. Applicable Emissions Limitations and/or Control Requirements

1. The specific operation(s), property, and/or equipment which constitute this emissions unit are listed in

the following table along with the applicable rules and/or requirements and with the applicable

emissions limitations and/or control measures. Emissions from this unit shall not exceed the listed

Applicable Emissions

Limitations/Control

Measures

Applicable Rules/

Requirements

Operations, Property,

and/or Equipment

2. Additional Terms and Conditions

None

II. Operational Restrictions

None

III. Monitoring and/or Record Keeping Requirements

None

IV. Reporting Requirements

None

V. Testing Requirements

None

VI. Miscellaneous Requirements

None

limitations, and the listed control measures shall be employed. Additional applicable emissions

limitations and/or control measures (if any) may be specified in narrative form following the table.

Terms and Conditions for Emissions Units

Title V Final Permit Page 678
1 1

Facility Name: Ormet Primary Aluminum Corp. 

Facility ID: 06-56-00-0001

*****************************************************

THIS IS THE LAST PAGE OF THE PERMIT

*****************************************************

Specific Facility Terms and Conditions

Title V Final Permit

Page 679