17 July 2009 

Mr. Chris LaLone, P.E. 

NYSDEC - Region 6 

Division of Air Resources 

317 Washington Street 

Watertown, New York 13601 

RE: Alcoa, Response to NYSDEC 6 February 2009 Comments 

Massena Modernization, Title V Permit Modification 

Dear Mr. LaLone: 

In response to your comments dated 6 February 2009, please find two enclosed 

copies of the revised Title V Permit Modification application elements for the 

Alcoa Massena Modernization project. Specific enclosures include the 

following: 

• Application introductory text (Sections 1 – 4); and 

• Appendix 1 – Applicability Assessment Supporting Documentation 

including Appendices A (Emission Unit Matrix), B (PSD Applicability 

Supporting Calculations), and C (Non-attainment NSR Applicability 

Support Calculations). 

The enclosed documents address your comments and questions on Appendix B 

– PSD Applicability Supporting Calculations and Appendix C – Non-attainment 

NSR Applicability Support Calculations. In addition, you will find some 

additional changes presented in a third section, Design/Calculation Updates. 

Your comments and questions along with Alcoa responses and design updates 

are presented as follows: 

Appendix B - PSD Applicability Supporting Calculations: 

1. Table B1-3 - There is a statement that furnace 4 emission factors are higher than 

furnace 8 and thus used for the prior actual emissions calculations. I would prefer to see 

Alcoa use the lower emission factors in this case since they will give the largest potential 

emissions increase for the project (i.e. future actuals - prior actuals) which in this 

instance would prove the most conservative. 

Furnace PM emission factors assume normal operations for 90% of the time and 

worst case operations for 10% of the time. Furnace 4 emission factors were 

chosen because they are the most representative of normal and worst case 

operations and the most recent testing (Fall 2007 SMACT testing) was only 

conducted on furnace 4. Furnace 4 emission factors were not used because they 

were higher than furnace 8 emission factors, but because they are more current 

and representative of both furnace 4 and furnace 8 emissions.
17 July 2009 

Mr. Christopher LaLone 

Page No. 2 

2. Table B1-5 - For the 2006 emissions calculations the total TF emission factor is based 

on the average of actual tested emissions for the year. However, the PMACT TF limit 

was exceeded for a portion of 2006. The TF emission factor should be recalculated to use 

actual TF emissions for those months that the TF emission limit was met and the 

PMACT limit of 2.4 lb/TAP for the months the facility was in violation of the standard. 

When I made this calculation I came up with a 2006 total TF emission factor of 2.33 

lb/TAP rather than the value of 2.59 lb/TAP used in the calculations. 

The TF emission factor was recalculated to use actual TF emissions for those 

months that the TF emission limit was met and the PMACT limit of 2.4 lb/TAP 

for the months the facility was in violation of the standard. The TF emission 

factor for the roof monitor was calculated to be 2.33 lb/TAP and the total 

(primary + secondary) emission factor became 2.36 lb/TAP. This change of the 

TF emission factor converted the prior actual for the East Plant soderberg 

potline from 264,990 lb/yr to 252,668 lb/yr. The project net emissions increase 

remains below the PSD TF significance threshold of 3 ton/yr. 

3. Table B1-8 - The emission factor for TF used in this table is 1.15 lb/TAP. However 

the PMACT standard for new potlines is 1.2 lb/TAP. By using the 1.15 lb/TAP to 

calculate future TF emissions is Alcoa proposing to meet a TF limit more restrictive 

than the PMACT limit? Using 1.2 lb TF/TAP gives a future TF emission of 4 tpy 

higher than calculated. 

Alcoa respectfully requests that the 1.15 lb of TF/TAP emission rate be made a 

permit condition as an annual average rate in order to ensure that TF emissions 

are below the PSD significance threshold, with the PMACT standard of 1.2 

lb/TAP as a monthly standard. 

4. Table B1-8 - In calculating the future SO2 emissions it appears there is an error in 

calculating the percentage of SO2 though the A-398’s and the roof monitors. When I 

run those calculations I get 5,482,357 lb/yr through A-398’s and 111,885 lb/yr through 

the roof monitors. Using these numbers the Total SO2 emitted becomes 440,826 lb/yr or 

26,293 lb/yr more than calculated in this table. 

The descriptions of these values were inadvertently not updated. The 

description states “98% through A-398’s” and “2% through monitor,” but the 

actual fume capture percent for the new East Plant potline is expected to be 

98.5% as shown near the top of the page. The West Plant prebake potline has a 

fume capture of 98.0%. The table values are correct and the descriptions have 

been updated. 

5. Table B1-13 - One of the emission sources listed in this table is #19 homogenizing 

furnace. However, there is no indication of what the 2006 & 2007 actual emissions from 

#19 homogenizing furnace were? 

The only sources changing in the emission unit A-00001 are homogenizing 

furnaces #16, #17 and #18, which will be removed. Homogenizing furnace #19 

will remain unchanged. Furnace #17 did not operate in 2006-2007, so only 

emissions from furnaces #16 and #18 will be used in the netting analysis. The 
17 July 2009 

Mr. Christopher LaLone 

Page No. 3 

table was changed to only summarize emissions from sources that are changing 

(furnaces #16, #17 and #18 - removed) for use in the netting analysis. Reference 

to furnace #19 was removed from the table and the calculations remain 

unchanged. 

6. Table B1-14 - I believe the calculations at the bottom of this table are incorrectly 

labeled and should be Emission unit A-00003, Process HM1 (not Emission unit A00001, Process HMO). 

The incorrect emission unit label has been changed to identify unit A-00003, 

Process HM1. 

7. Table B1-21 - It doesn’t seem accurate to subtract particulate fluoride from A-398 

and roof monitor particulate to come up with a total particulate emission rate from the 

potline. Particulate fluoride should be counted both as fluoride and particulate much as 

lead particulate would be counted as both a particulate and a HAP. The particulate 

impact on an area is not diminished simply because a portion of the particulate is 

fluoride. 

The total particulate emission rate was changed to be equal to the sum of the A398 and roof monitor particulate emission rates. The average 2006-2007 

emission rate changed from 1.848 lb/ton aluminum to 2.176 lb/ton aluminum. 

As a result, the 2006-2007 average particulate potroom emission changed from 

262,411 lb/yr to 308,987 lb/yr. The project net emissions increase for PM, PM10, and PM-2.5 remain negative values and, therefore, well below their 

respective PSD significance thresholds. 

8. Table B1-22, 23, 24, 26 & 27 - All of these tables refer to the value “%S in reacted 

aluminum” - I assume this is meant to be “...alumina”? 

Yes, it is meant to be alumina. 

9. Table B1-24 - Why was the Al2O3 feed rate doubled for the calculation of future SO2 

emissions? Is Alcoa going to be doubling its use of Al2O3 in the West Plant potline? 

The injection rate of Al2O3 will be doubled into the bake furnace dry scrubber 

to account for doubled throughput of the bake furnace. This does not indicate a 

doubling of the Al2O3 use in the West Plant potline. 

10. Table B1-25 - Same comment as #7 above for particulate calculations. Also, note (1) 

states the process weight emission limit was used to calculate PM emissions but for this 

table it appears that the average PM emission rate for 2006 - 2007 was used to calculate 

PM emissions. 

The total particulate emission rate was changed to be equal to the sum of the A398 and roof monitor particulate emission rates. The maximum emission rate 

between 2006 and 2007 (2006) changed from 1.963 lb/ton aluminum to 2.232 

lb/ton aluminum. As a result, the 2006-2007 maximum particulate potroom 

emission changed from 283,302 lb/yr to 322,124 lb/yr. The project net 
17 July 2009 

Mr. Christopher LaLone 

Page No. 4 

emissions increase for PM, PM-10, and PM-2.5 remain negative values and, 

therefore, well below their respective PSD significance thresholds. The 

maximum PM emission rate between 2006 - 2007 was used to calculate PM 

emissions. The process weight note was removed. 

11. Table B1-28 - Same comment as #7 above for particulate calculations. 

The calculations were changed and the 2006-2007 average total particulate 

emission factor is currently being used without subtracting the total fluoride 

emission factor. The emission factor used for the annual particulate calculation 

changed from 0.246 lb/ton (green carbon) to 0.248 lb/ton (green carbon). As a 

result, the 2006-2007 average particulate baking furnace emission changed from 

20,840 lb/yr to 20,980 lb/yr. The project net emissions increase for PM, PM-10, 

and PM-2.5 remain negative values and, therefore, well below their respective 

PSD significance thresholds. 

12. Table B1-30 - Same comment as #7 above for particulate calculations. 

The calculations were changed and the 2006-2007 average total particulate 

emission factor is currently being used without subtracting the total fluoride 

emission factor. The emission factor used for the annual particulate calculation 

changed from 0.246 lb/ton (green carbon) to 0.248 lb/ton (green carbon). As a 

result, the 2006-2007 average particulate baking furnace emission changed from 

44,804 lb/yr to 45,105 lb/yr. The project net emissions increase for PM, PM-10, 

and PM-2.5 remain negative values and, therefore, well below their respective 

PSD significance thresholds. 

13. Table B1-31 - What is note (4) referencing? 

The reference originally stated “Emission factor based on Method 5 Emission 

Testing,” but the reference was inadvertently removed from the final draft. It 

was added as note (2). 

14. Table B1-32 - My understanding is that it has been decided not to add a fourth paste 

mixer to Emission Unit S-00003. However, a new anode former(s) will be added to the 

emission unit. How does the anode former change these calculations? 

Alcoa has opted to include the fourth paste mixer in the application and 

associated calculations in the event that it proceeds with installation. Emissions 

are based on throughput of paste and are independent of the addition of a 

fourth paste mixer. In respect to the anode formers, information from two 

anode former vendors indicates that Alcoa will not have to increase the volume 

of air captured from the new formers versus the existing former and therefore 

there will be no increase in emissions from the installation of the new formers. 

15. Table B1-35 - This table has columns for a Method A and Method B emission rate. 

What is the distinction between the two methods? 
17 July 2009 

Mr. Christopher LaLone 

Page No. 5 

Columns in the spreadsheet were hidden. The revised table shows these 

columns.Method A is based on an ERP and baghouse control efficiency. (ERP 

lb/hr x (1-efficiency) Method B is based on a flow design and projected outlet 

grain loading of 0.017 gr/dscf. (flow design dscfm x projected outlet gr/dscf x 

60 min/hr ÷ 7000 gr/lb) Projected emissions were based on the worst case 

between the two methods. 

Appendix C - Non-Attainment NSR Applicability Supporting Calculations: 

1. Table C1-2 - In the table for prior COS MAP calculations the coke in sulfur content 

is assumed to be 3% but there is a note next to it saying the allowable level is 2.5% 

sulfur. There is no permit limit restricting coke sulfur content at the East Plant to 2.5% 

sulfur. Is the note incorrect or should 2.5% sulfur have been used in the COS 

calculation. At 2.5% the COS prior MAP would be 172.7 tpy instead of the 203 tpy 

using 3% sulfur in coke. 

The note was erased. The calculation is correct with the assumed sulfur content 

of 3%. 

2. Table C1-2 - Was the propane combustion a result of pots set up solely to bake anodes 

in a superstructure that wasn’t producing aluminum? 

Propane combustion is a result of baking cathodes, which is an ongoing 

requirement of soderberg operations. 

3. Table C1-2 - In the prior VOC MAP calculations there is a large quantity of methane 

emissions along with ethane and propane emissions. This is the first time I have ever 

heard of generation of any of these pollutants from a potline. Is this a common pollutant 

from HSS pots - I assume that the emissions of these pollutants are generated during 

baking of the anodes in place. Since the test data was from 2002, while still producing 

anodes from paste, is it practical to assume that the THC emissions would be as high 

during 2006 & 2007 when the HSS pots operated most of the time with briquettes? 

Methane and ethane generation is common from HSS pots. Due to the slow 

baking, PAH compounds are broken down and not fully combusted. THC 

emissions are not expected to be different based on the switch from paste to 

briquettes. 

4. Table C1-3 - In the future MAP COS calculations 3% sulfur in coke was used and 

2.76% sulfur in baked anodes was used. A sulfur in coke content of 2.5% and sulfur in 

baked anodes content of 2.3% should have been used since the new pre-bake potline will 

be using anodes from the West Plant which has a 2.5% sulfur in coke permit limit. Also, 

the COS control is stated as 25% rather than the 34% used for COS control for the 

current East Plant pots. Since the same control equipment will be used 34% COS 

control seems to be more appropriate. Using 2.5% sulfur in coke and 34% COS control 

the future COS MAP becomes 177.4 tpy. 

Since there is no permit limit restricting coke sulfur content at the East Plant to 

2.5% sulfur, Alcoa left the sulfur in coke content at 3% and sulfur in baked 
17 July 2009 

Mr. Christopher LaLone 

Page No. 6 

anodes at 2.76%to accommodate the possibility of using anodes that may have 

sulfur contents above 2.5%. The percent fume capture for the new East Plant 

potline is expected to be 98.5%, not 98%. This change was also made. Alcoa left 

the control efficiency at 25% to be conservative and account for increased 

loading of the control device. As a result of the percent fume capture change 

from 98% to 98.5%, the COS MAP changed from 240.7 tpy to 240.3 tpy. Part 231 

applicability remains unchanged. 

5. Table C1-5 - One of the emission sources listed in this table is #19 homogenizing 

furnace. However, there is no indication of what the 2006 & 2007 actual emissions from 

#19 homogenizing furnace were? 

The only sources changing in the emission unit A-00001 are homogenizing 

furnaces #16, #17 and #18, which will be removed. Homogenizing furnace #19 

will remain unchanged. Furnace #17 did not operate in 2006-2007, so only 

emissions from furnaces #16 and #18 will be used in the netting analysis. The 

table was changed to only summarize emissions from sources that are changing 

(furnaces #16, #17 and #18 - removed) for use in the netting analysis. Reference 

to furnace #19 was removed from the table and the calculations remain 

unchanged. 

6. Table C1-6 - I believe the process ID for the new homogenizing furnaces is incorrectly 

labeled throughout this table as HMO when it should be HM1. The maximum fuel 

usage capacity for the new MH1 furnaces is listed as 0 MMCF/yr. My calculation 

shows this value should be 1331 MMCF/yr. 

The labeling was changed and the maximum fuel usage for the new MH1 

furnaces is 1331 MMCF/yr. The cell was not linked in the original calculations, 

so the calculated emission rates remain unchanged. 

7. Table C1-9 - The second table on this page should be labeled Prior and Future MAP 

Anode Baking Furnace Emissions. 

The label was changed. 

8. Table C1-10 - Why is the potential West Plant green anode maximum production for 

Emission Unit S-00003 different than listed for the same parameter on Table C1-9 for 

Emission Unit S-00002 and Table C1-11 for Emission Unit S-00005? Shouldn’t they 

all be the same? 

The cell in table C1-10 with the potential West Plant green anode maximum 

production was not linked. The change was made and the Prior MAP green mill 

VOC emission rate changed from 4,335 lb/yr to 4,210 lb/yr and the future MAP 

green mill VOC emission rate changed from 5,780 lb/yr to 5,613 lb/yr. Part 231 

applicability remains unchanged. 

9. Table C1-10 - A fourth paste mixer is not planned to be added to the green mill but a 

new anode former(s) is - how does this change the future VOC MAP calculations? 
17 July 2009 

Mr. Christopher LaLone 

Page No. 7 

Alcoa has opted to include the fourth paste mixer in the application and 

associated calculations in the event that it proceeds with installation. Emissions 

are based on throughput of paste and are independent of the addition of a 

fourth paste mixer. In respect to the anode formers, information from two 

anode former vendors indicates that Alcoa will not have to increase the volume 

of air captured from the new formers versus the existing former and therefore 

there will be no increase in emissions from the installation of the new formers. 

Design/Calculation Updates: 

Anode Cooling: 

Table B1-9: The capture efficiency (Y) for anode cooling was changed from 50% 

to 95%based on design information. This change lowered the TF projected 

future actual emissions from 8.2 TPY to 1.1 TPY. The project net emissions 

increase remains below the PSD TF significance threshold of 3 lb/yr. 

SO2 Emissions: 

In 2006 and 2007 there was spent or “unused” carbon that was removed from 

the East Potline without being consumed as either spent anodes or waste 

carbon. This carbon removal was not accounted for in the initial calculation 

submittal. The East Plant potline calculations have been revised based on this 

information and the net emissions increase for SO2 has increased from 4.1 TPY 

to 10 TPY, still well below the applicable threshold of 40 TPY. 

PM Emissions: 

Potline PM emissions were revised with a new calculation approach for PM 10 

and PM 2.5 with condensables. The West Plant potline prior actual and future 

projected emissions, as well as the modernized East Plant future emissions, 

were calculated with adapted data from Alcoa’s South Carolina pre-bake 

potline that contained condensable PM emissions for a pre-bake potline. The 

soderberg potline emissions for the East Plant actual emissions are calculated 

using 2008 emission test results and 06-07 average PM roof vent emission rates 

to determine PM 2.5 with condensables, while PM 10, which was not tested in 

2008, was calculated by applying the AP-42 “Percent Cumulative Mass” values 

to the PM number, and then adding in condensables by assuming the percent 

condensables of the total PM measured on the roof vent in 2008 is the same 

percent for the control device. 

Thank you for your on-going assistance with this matter. If you have any 

questions or comments, please do not hesitate to contact Mr. Jordan Parent, 

Alcoa at (315) 764 - 4737, or the undersigned at (585) 387 – 0510. 

Sincerely, 
17 July 2009 

Mr. Christopher LaLone 

Page No. 8 

Gary M. Keating 

Partner 

Enclosure 

cc: Dr. Dobbs, Alcoa 

 Mr. Lenney, Alcoa 

Mr. Parent, Alcoa 
Alcoa Massena Modernization Project 

Attainment and Nonattainment Air Pollutant New Source Review 

Determination of Applicability

Alcoa Primary Metals 

Massena Plants 

Park Avenue East, PO Box 150

Massena, New York 13662

September 2008 

Revised October 2008 

Revised July 2009

Delivering sustainable solutions in a more competitive world 
Delivering sustainable solutions in a more competitive world 

Attainment and Nonattainment Air Pollutant New Source Review 

Determination of Applicability

Alcoa Primary Metals 

Massena Plants 

Park Avenue East, PO Box 150

Massena, New York 13662 

Prepared by: 

ERM 

1159 Pittsford-Victor Road 

Suite 200 

Pittsford, New York 14534
ERM i ALCOA 

TABLE OF CONTENTS

1.0 INTRODUCTION.........................................................................................................................1

1.1 PROJECT INTRODUCTION...........................................................................................1 

1.2 ATTAINMENT STATUS .................................................................................................1 

1.3 DOCUMENT ORGANIZATION ....................................................................................2 

2.0 ALUMINUM MANUFACTURING OPERATION ..................................................................3 

2.1 PRIMARY ALUMINUM MANUFACTURING BACKGROUND ...............................3 

2.2 ALCOA MASSENA EMISSION UNITS ........................................................................7 

3.0 PREVENTION OF SIGNIFICANT DETERIORATION........................................................10 

3.1 SINGLE SOURCE DETERMINATION .......................................................................11 

3.2 PROJECT BOUNDRY ...................................................................................................12 

3.3 BASELINE ACTUAL EMISSIONS ...............................................................................16 

3.4 PROJECTED ACTUAL/ALLOWABLE EMISSIONS...................................................18 

3.5 PSD APPLICABILITY DETERMINATION .................................................................19 

4.0 NONATTAIMENT NEW SOURCE REVIEW (NSR) APPLICABILITY...................23

4.1 SOURCE PROJECT DEFINITION AND EMISSION UNIT MAP ANALYSIS........24 

4.2 PEP AND SIGNIFICANT SOURCE PROJECT EVALUATION................................25 

4.3 SIGNIFICANT NET EMISSIONS EVALUATION......................................................25 

TABLES 

TABLE 1 – POLLUTANT AND NSR STATUS...........................................................................2 

TABLE 2 – EMISSIONS UNITS AND MODERNIZATION .....................................................7 

TABLE 3 – PROJECT BOUNDARY EMISSION UNITS (SOURCES) ...................................13 

TABLE 4 – TWENTY-FOUR MONTH AVERAGE BASELINE ACTUAL EMISSIONS ......17 

TABLE 5 – PROJECTED ACTUAL EMISSIONS ADJUSTMENTS FOR EXISTING 

EMISSIONS UNITS.................................................................................................19 

TABLE 6 – PSD SIGNIFICANT EMISSIONS INCREASE EVALUATION ...........................21 

TABLE 7 - PSD SIGNIFICANT NET EMISSIONS INCREASE EVALUATION...................22 

TABLE 8 – MAP SUMMARY AND SOURCE PROJECT DEFINITION ...............................24 

TABLE 9 – PEP AND SIGNIFICANT SOURCE PROJECT EVALUATION..........................25 

TABLE 10 – PART 231-2 SIGNIFICANT NET EMISSIONS INCREASE EVALUATION ...26 
ERM ii ALCOA 

FIGURES 

FIGURE 1 – CURRENT EAST PLANT SODERBERG CELL ....................................................5 

FIGURE 2 – CURRENT EAST PLANT FUME COLLECTION SYSTEM ................................5 

FIGURE 3 – WEST PLANT PREBAKE REDUCTION CELL.....................................................6 

FIGURE 4 – WEST PLANT FUME COLLECTION SYSTEM ...................................................6 

FIGURE 5 – EAST PLANT EMISSION UNIT PROCESS FLOW .............................................9 

FIGURE 6 – WEST PLANT EMISSION UNIT PROCESS FLOW ............................................9 

APPENDIX A – EMISSION UNIT MATRIX 

APPENDIX B – PSD APPLICABILITY SUPPORTING CALCULATIONS 

APPENDIX C – NON-ATTAINMENT NSR SUPPORTING CALCULATIONS 
ERM ALCOA 1

1.0 INTRODUCTION 

1.1 PROJECT INTRODUCTION 

Alcoa is proposing to modernize their Massena East and West aluminum smelter 

facilities. The modernization would bring significant environmental benefits, provide a 

cleaner and safer working environment for Alcoa employees, and retain at least 900 jobs. 

The improvements include: 

 replacing the Soderberg potline at Massena East with a modern technology pre-bake 

potline; 

 increasing the recent throughput of the anode manufacturing facility at Massena 

West to supply the needs of the new potline at Massena East as well as the existing 

potline at Massena West, by taking advantage of historic production capacity. 

Modernization activities are proposed at both the Massena East and Massena West 

Facilities, which are located approximately ten miles apart. The Massena West Plant is 

located adjacent to the Massena Power Canal in the Village of Massena. The Massena 

East Plant is located approximately ten miles east of the Massena West Plant in 

Rooseveltown. 

1.2 ATTAINMENT STATUS AND NEW SOURCE REVIEW POLLUTANT STATUS 

Massena, New York is located in an attainment area for all pollutants. New York State, 

however, is located in the Northeastern U.S. Ozone Transport Region. As a result, 

emissions of ozone precursor pollutants, Volatile Organic Compounds (VOC) and 

Nitrogen Oxides (NOx), are regulated in Massena as if it were a “moderate” 

nonattainment area for ozone. NOx is regulated as both an attainment and a 

nonattainment pollutant. VOC is regulated as only a nonattainment pollutant. 

New and modified emission sources at facilities which are classified as “major” for 

attainment and nonattainment pollutants are regulated under the Federal Prevention of 

Significant Deterioration (PSD), and State Nonattainment New Source Review 

(Nonattainment NSR) programs, respectively. The Alcoa Massena East and West Plants 

are considered major facilities under both the attainment and nonattainment programs. 

The PSD program is codified under 40 Code of Federal Regulations (CFR) Part 52.21 and 

is currently implemented in New York by the U.S. Environmental Protection Agency 

(USEPA). The Nonattainment NSR Program is codified under 6 New York Code of 

Rules and Regulation (NYCRR) Part 231-2, and is implemented by the New York State 

Department of Environmental Conservation (NYSDEC). 

A list of pollutants emitted from Alcoa Massena operations is presented in the following 

table along with NSR program applicability. 
ERM ALCOA 2

Table 1 - Pollutant and NSR Status 

Pollutant NSR Program Applicability

Particulate (PM) Attainment 

PM10 Attainment 

PM2.5 Attainment 

NOX Attainment/Nonattainment 

VOC Nonattainment 

CO Attainment 

SO2 Attainment 

Fluoride (Particulate) Attainment (as Total Fluoride) no NAAQS 

HF 

Attainment (added to particulate as Fluoride as element of 

Total Fluoride) no NAAQS 

POM 

Depending on physical state it could be an element of 

measured (PM, PM10, PM2.5, and VOC) 

Carbonyl Sulfide (COS) Not subject directly, element of VOC 

HCl Not subject 

Cl2 Not subject 

Benzene Not subject directly, element of VOC 

Toluene Not subject directly, element of VOC 

Ethyl Benzene Not subject directly, element of VOC 

Xylene Not subject directly, element of VOC 

Styrene Not subject directly, element of VOC 

Be Not subject directly, element of PM, PM10, PM2.5 

Cd Not subject directly, element of PM, PM10, PM2.5 

Mn Not subject directly, element of PM, PM10, PM2.5 

Ni Not subject directly, element of PM, PM10, PM2.5 

1.3 DOCUMENT ORGANIZATION 

The remainder of this document is organized into three major sections. Section 2 

provides an overview of aluminum manufacturing operations, and explains proposed 

changes at the Massena East and West Plants. Section 3 presents a description of PSD 

program applicability and explains the basis of baseline and projected future actual 

emissions estimates necessary to determine PSD program applicability. Section 4 

presents a description of Nonattainment NSR program applicability and explains the 

basis of emissions estimates necessary to determine nonattainment NSR applicability in 

New York State. Both Sections 3 and 4 are supported by detailed emissions calculations 

referenced in Appendices. 
ERM ALCOA 3

2.0 ALUMINUM MANUFACTURING OPERATIONS 

2.1 PRIMARY ALUMINUM MANUFACTURING BACKGROUND 

Much of the following technical description is an excerpt from the Background Report, 

AP-42 Section 12.1, Primary Aluminum dated November 12, 1998 prepared for the 

USEPA by Pacific Environmental Services, Inc., and available at www.epa.gov/ttn/chief.

The Hall-Heroult process is used to produce aluminum metal by electrolytic reduction 

of alumina that takes place in shallow rectangular cells, or "pots," which are steel shells 

lined with carbon. Carbon electrodes extending into the pot serve as the anodes and 

the carbon lining as the cathode. Electrical resistance to the current passing between 

the electrodes generates heat that maintains the cell operating temperature. Molten 

cryolite (Na3AlF6) functions as both the electrolyte and the solvent for the alumina. The 

electrolytic reduction of Al2O3 by the carbon from the electrode occurs as follows: 

2Al2O3 + 3C → 4Al + 3CO2

The carbon required for this reaction comes from the electrode, which requires from 0.5 

kg to 0.6 kg (1.1 to 1.3 lb) of carbon per kilogram (2.2 lb) of metal. Carbon anodes are 

continuously depleted by the reaction. In the electrolytic reduction of alumina, the 

carbon anodes are lowered into the cell and are consumed at a rate of about 2.57 cm (1 

in) per day. In theory, only 0.33 kg (0.73 lb) of carbon is required per kg of aluminum. 

Potline off gases contain 200 to 500 ppmv carbon monoxide, accounting for the 

difference between theoretical and actual carbon consumption. Molten cryolite 

functions as both the electrolyte and the solvent for the alumina. Pure cryolite has a 

melting temperature of 1010 OC (1850 OF). The electrolyte contains fluorospar (CaF2), 

some AlF3, and lithium in some instances, which along with the dissolved alumina, 

reduces the melt temperature sufficiently to permit the cells to operate between 940 and 

980 OC (1725 and 1795 OF). Aluminum is deposited at the cathode, where it remains as 

molten metal below the surface of the cryolite bath. Aluminum metal is tapped every 24 

to 48 hours beneath the cryolite cover using a vacuum siphon. The aluminum is then 

transferred to a reverberatory holding furnace where it is alloyed, fluxed and degassed 

to remove trace impurities. From the holding furnace, the aluminum is cast for on- or 

off-site fabrication of aluminum products. 

Material conveyance operations are employed to unload, transport and deliver raw 

materials to the process operations. At the East Plant, these operations are addressed 

by emission unit (EU) ULDG01. At the West Plant, they are addressed by EU S00004. 

Two major types of aluminum reduction cells are used in electrolytic reduction: 

prebaked (PB) anode cell, and Soderberg anode cell. Most of the aluminum produced 

in the U.S. is processed using the prebaked anode cell process. The current Massena 

East Plant operates Soderberg anode cells (EU POT001), and the Massena West Plant 

operates prebake anode cells (EU S00001). The East Plant modernization project is 

largely focused on replacing the East Plant Soderberg pots with prebake pots. Prebake 

technology offers significant environmental and energy related benefits as compared to 

Soderberg technology. 
ERM ALCOA 4

Both aluminum cell configurations require a "paste" (petroleum coke mixed with a 

pitch binder). Paste preparation includes the crushing, grinding, and screening of coke 

and cleaned spent anodes (butts) and blending the coke with a pitch binder in a steam 

jacketed mixer. For Soderberg anodes, the thick paste mixture is either added directly 

to the anode casings while the paste is still hot, or it is cooled into briquettes and then 

added to the anode casings, which are baked in the aluminum reduction cell. In 

contrast, prebaked (green) anodes are produced and baked as an ancillary operation at 

a reduction plant. During PB anode manufacturing, the paste mixture is molded into 

self supporting green anode blocks (EU S00003) that are baked in a direct-fired ring 

furnace (EU S00002). Direct-fired ring furnaces use pitch and tars to isolate and seal off 

the green anode blocks from the atmosphere during a 28-day baking process. After 

baking, steel rods are inserted into the PB anode and sealed with molten iron. These 

rods become the electrical connections to the PB anode. Prebaked anode cells are 

preferred over Soderberg cells because they are electrically more efficient and emit 

fewer volatile organic compounds. Volatile organic vapors from the pitch paste are 

emitted during anode baking. Due to cell configuration and operations, it is possible to 

achieve substantially higher fume collection efficiencies with prebake cells as compared 

to Soderberg cells. A PB cell operation, however, does require a separate anode and 

rodding facility, not needed by Soderberg aluminum reduction cells. 

Future East Plant anodes will be produced at the existing West Plant anode furnace. 

Figures 1 through 3 below illustrate Soderberg and Prebake pot technology. Figures 2 

and 4 illustrate their respective fume capture system configurations. The nature of the 

Soderberg pot design makes fume capture more challenging than with a PB pot. Alcoa 

anticipates an increase in East Plant fume capture efficiency from 93 to 98.5% as a result 

of the change from Soderberg to prebake reduction cells at the East Plant. 
Figure 1 – Current East Plant Soderberg Cell 

Figure 2 – Crust Breaking of an East Plant pot prior to an alumina ore addition 

ERM ALCOA 5
Figure 3 – West Plant Prebake Cell 

Figure 4 – West Plant Prebake Crust Breaking and Alumina Ore Feeding is Internal to 

the Pot Superstructure - Thus Improving Fume Capture 

ERM ALCOA 6
ERM ALCOA 7

Following smelting, molten aluminum is transferred to reverberatory melting/holding 

furnaces where it is alloyed, fluxed and degassed to remove trace impurities. This may 

occur at both the East and West Plants. East Plant emissions sources involved with this 

operation are addressed by EU EWCST1. West Plant sources are associated with EUs 

M00001 (furnaces which either do not flux, or which use only salt fluxes), and M00002 

(in-line filter box gas fluxing units). From the holding furnaces, the aluminum is cast 

and treated in a series of pre-heat and homogenizing heat treat furnaces located at the 

West Plant (EU A00001). 

In addition to the above primary aluminum manufacturing operations, the West Plant 

processes recycled aluminum chips and castings. The recycled aluminum process 

invokes regulatory requirements for secondary aluminum manufacturing. Recycled 

aluminum is added to the reverberatory melting/holding furnaces along with molten 

aluminum. 

2.2 ALCOA MASSENA EMISSIONS UNITS 

The following table presents each Alcoa Massena East and West Plant emissions unit 

using its NYSDEC Title V Permit nomenclature, along with a commentary on the affect 

of the modernization project. A full emissions unit matrix identifying emission units, 

processes, sources, controls, and points is attached for both the East and West Plants as 

Appendix A, Table A1. 

Table 2 - Emissions Units and Modernization Impact 

Title V 

Emission 

Unit ID 

Description Modernization Impact 

East Plant 

A-NOD01 Anode Pin Room Shut Down - Emissions included in Pot Room 

B-OIL01 Boilers No change - Not included in PSD/Nonattainment NSR 

C-RSH01 Crusher Building Shut Down - Not operated since 2000. No credit taken for 

prior actual emissions. 

D-ROS01 Dross Storage Room No change - Not included in PSD/Nonattainment NSR 

D-ROS02 Dross Cooling No change - Not included in PSD/Nonattainment NSR 

C-ARB01 Carbon Plant Shut Down - emissions considered in netting analysis 

E-WCST1 Cast House Shut Down except Homogenizing furnace, process HMO, 

emissions considered in netting analysis 

P-OT001 Potline Shut Down – Capacity replaced by new pre-bake pot line 

P-AINO1 Paint Shop No change - Not included in PSD/Nonattainment NSR 

P-ARTW1 Parts Washers No change - Not included in PSD/Nonattainment NSR 

0-CRUCE Cruce Augering Addition of Cruce Auger – New Equipment, Increased capacity

U-LDG01 Unloading and Transfer Changes to include some increased utilization, equipment 

elimination, and new bath filling, bath storage, and AlFl3 

Filling Station. 

W-WTR01 Wastewater Treatment No change - Not included in PSD/Nonattainment NSR 

P-DIG01 Cathode Digging Shut Down – emissions considered in netting anlysis 
ERM ALCOA 8

Table 2 - Emissions Units and Modernization Impact (continued) 

Title V 

Emission 

Unit ID 

Description Modernization Impact 

West Plant 

A-00001 Homogenizing and Heat 

Treat Furnaces 

Some sources will not change. Three homogenizing 

furnaces will be removed. 

A-00002 Insignificant Shop 

Combustion Sources 

No change - Not included in PSD/Nonattainment NSR 

A-00003 Homogenizing Heat Treat 

and melting/holding 

Furnaces with associated 

filterboxes 

Seven homogenizing furnaces and three melting/holding 

furnaces with gas fired filterbox fluxing units will be 

added. 

B-00001 Boilers Increase in load demand 

C-00001 Chip Dryer #1 No change - Not included in PSD/Nonattainment NSR 

C-00002 Chip Dryer #2 No change - Not included in PSD/Nonattainment NSR 

D-00001 Miscellaneous metal 

finishing and skim/dross 

cooling 

Skim and Dross cooling will have increased throughput 

F-00001 Miscellaneous fugitive 

sources 

No change - Not included in PSD/Nonattainment NSR 

M-00001 Melting/Holding Furnaces 

with no gas fluxing (salt 

only) 

No change – Not included in PSD/Nonattainment NSR 

M-00002 In-line filter box gas fluxing 

units 

No change – Not included in PSD/Nonattainment NSR 

P-00001 Parts Washers No change - Not included in PSD/Nonattainment NSR 

S-00001 Pre-bake Potline Increased throughput 

S-00002 Anode Bake furnaces Increased throughput 

S-00003 Paste Production Plant 

(Green Mill) 

Adjustment to paste production process will be necessary 

to accommodate increased paste production need. 

S-00004 Material Handling 

Operations 

Some sources will have increased throughput, others will 

not change. 

S-00005 Coal Tar Pitch Unloading 

and Storage 

Increased throughput 

S-00006 Smelting and anode 

Fugitives (not including 

potline) 

Some sources will have increased throughput, others will 

not change. Emissions contained within respective 

buildings. 

W-00001 Wastewater Treatment No change - Not included in PSD/Nonattainment NSR 

Figures 5 and 6 on the following page present a general process flow by Emission Unit 

for the East and West Plants, respectively. 
9

Figure 5 - East Plant Emission Unit Process Flow Figure 6 - West Plant Emission Unit Process Flow 

S00006 

Smelting and anode Fugitives (not 

including potline) 

S00005 

Coal Tar Pitch 

Unloading 

and Storage 

S00004 

Material Handling Operations 

S00003 

Paste 

Production 

Plant 

(Green Mill) 

S00002 

Anode bake 

furnaces 

S00001 

Pre-Bake 

Potline M00002 

In-line filter box ga

fluxing units 

M00001 

Melting/Holding 

Furnaces 

C00002 

Chip Dryer #2 

C00001 

Chip Dryer #1 

D00001 

Misc. metal finishin

and skim/dross coo

B00001 

Boilers

W00

Waste

Treatm

P00001 

Parts 

Washers 

F00001 

Misc. Fugitive 

sources 

Supporting Operation

A00003 

Melting/Holding 

Furnaces 

A00003 

In-line filter box ga

fluxing units 

ANOD01 

Anode Pin 

Room 

PDIG01 

Cathode 

Digging 

ULDG01 

Unloading 

and Transfer 

POT001 

Potline 

EWCST1 

Cast House 

CARB01 

Carbon Plant 

DROS02 

Dross Cooling 

DROS01 

Dross Storage 

Room 

CRSH01 

Crusher Building 

PARTW1 

Parts 

Washers 

WWTR01 

Wastewater 

Treatment 

PAIN01 

Paint Shop 

BOIL01 

Boilers 

Supporting Operations 

Key: Red- Shut Down Blue- No Change Orange- Affected b

ERM 
ERM ALCOA 10

3.0 PSD APPLICABILITY 

As discussed in Table 1 above, pollutants associated with the Alcoa Massena 

Operations which are regulated under the PSD permitting program are PM, PM10, 

PM2.5, NOx, SO2, CO, and Total Fluorides (TF). The PSD permitting program is 

currently being implemented in New York by the USEPA consistent with regulations 

codified at 40 CFR 52.21 and which include the option to use a comparison of baseline 

actual emissions to projected future actual emissions to determine program 

applicability. The Alcoa East and West Plants are each deemed major stationary 

sources under the PSD program since existing emissions of one or more attainment 

pollutants exceed the pollutants’ respective major source thresholds. PSD permitting 

obligations apply at major stationary sources which undergo major modifications. 

Under 40 CFR Part 52.21(b)(2)(i), a Major Modification means: 

any physical change in or change in the method of operation of a major stationary source that 

would result in: a significant emissions increase (as defined in paragraph (b)(40) of this section) of 

a regulated NSR pollutant (as defined in paragraph (b)(50) of this section); and a significant net 

emissions increase of that pollutant from the major stationary source. 

There are a number of complex steps necessary to determine if the Massena 

Modernization Project is a “major modification” under the PSD program. The steps 

are presented in summary form as follows. Additional details are provided as 

necessary in the following sections and emissions estimates are supported by detailed 

emission calculations in Appendix B. The applicability steps include: 

 Assessing if the East and West Plants are considered a single source under the PSD 

program; 

 Defining the project boundary by determining which emission units (the federal 

reference to emissions unit generally refers to emission sources, not NYSDEC Title V 

emission units) are affected by the modernization project. Emissions units affected 

are those which are either new units, modified units, or existing units with emissions 

that are directly or indirectly affected by upstream or downstream changes; 

 Determining the baseline period for establishing baseline actual emissions; 

 Calculating baseline actual annual emissions for each PSD regulated pollutant, for 

each emission unit (source) during the baseline period determined to be within the 

project boundary; 

 Calculating future actual or allowable emissions for new sources, or for existing 

sources, which are either directly changed by the modernization project, or indirectly 

affected by upstream or downstream changes (debottlenecked). Both the directly 

and indirectly affected existing source projected emissions may be adjusted 

downward to exclude emissions that the source was capable of accommodating 

prior to the change (demand growth emissions). New units were considered at their 

PTE while modified and replacement emissions units are eligible for projections of 

future actual emissions in this analysis. 

 Subtracting baseline actual emissions of each pollutant from the projected 

actual/allowable emissions of that pollutant (following its demand growth 
ERM ALCOA 11

adjustments), and comparing the difference (in tons per year) to the PSD significance 

threshold for the respective pollutant. 

 For each pollutant emission which exceeds its respective significance threshold, 

adding any emission increases and subtracting any emissions decreases that are 

contemporaneous with the project (within the last five years) to determine the net 

emissions increase. 

 Comparing the net emissions increase to the pollutant specific significance 

thresholds to determine if there is a significant net emissions increase. 

 Each pollutant with significant net emissions increase is subject to the PSD 

permitting program for all contributing sources that are within the project boundary. 

Details regarding each of the above referenced applicability steps are presented in the 

following sections. 

3.1 SINGLE SOURCE DETERMINATION 

The East and West Plants have historically been managed as two distinct and separate 

operating entities. The West Plant has always been owned and operated by Alcoa Inc. 

The East Plant was previously owned and operated by the former Reynolds Metals 

Company. In 2000, Alcoa Inc. acquired the Reynolds Metals Company. Following the 

acquisition, the East Plant continues to be operated by the Reynolds Metals Company, 

now a wholly owned subsidiary of Alcoa. Up until the Massena modernization project, 

the East and West Plants will operate under separate Title V Operating Permits. 

Pending USEPA’s concurrence with the non-applicability determination for PSD, the 

East and West Plants will continue to operate under separate Title V Operating Permits. 

Following modernization, the East Plant will become dependent on West Plant 

operations for raw material (pre-baked anodes), and for metal product processing 

capacity in the West Plant cast house. Consistent with guidance provided in the 11 

October 2000 correspondence from Mr. Steven C. Riva, Chief Permitting Section Air 

Programs Branch (USEPA Region 2) to Mr. John T. Higgins, P.E., NYSDEC - Director 

Bureau of Application Review and Permitting Division, regarding the proposed St. 

Lawrence Cement, Greenport Project, source determinations are rooted in the 

stationary source definition of 40 CFR Part 52.21 and must: 

 belong to the same industrial grouping [the “Major Group” (i.e., which have the 

same first two digit code) as described in the Standard Industrial Classification 

Manual, 1972, as amended by the 1977 Supplement], 

 located on one or more contiguous or adjacent properties, and 

 be under the control of the same person (or persons under common control). 

Both the East and West Plants are clearly under the same industrial grouping with a 

Standard Industrial Classification code of 3334 – Primary Aluminum. Likewise the 

plants are clearly under the common control of Alcoa Inc. 

The question of contiguous or adjacent properties is more involved. EPA has noted 

that whether or not two facilities are adjacent depends on the “common sense” notion 

of a source and the functional inter-relationship of the facilities and is not simply a 

matter of the physical distance between the two facilities. The physical distance 
ERM ALCOA 12

between the East and West Plants (approximately 10 miles) is within the range of 

distances considered to be adjacent by previous USEPA source determinations. For 

example, in the 20 April 1999 correspondence from Richard R. Long, USEPA Region 8 - 

Director Air and Radiation Program, regarding the American Soda Commercial Mine 

(Piceance facility) and processing plant (Parachute facility), EPA determined that the 

two facilities were considered adjacent although they are located approximately 35 to 

40 miles apart. In many previous USEPA determinations, two facilities although 

separated by distance, are connected by a pipeline or dedicated conveyance, but this is 

not the case in all determinations. For example, in a 13 March 1998 correspondence 

from Cheryl L. Newton, USEPA Region 5 – Chief Permits and Grants Section, regarding 

the Acme Steel Company (Acme) facilities located in Chicago and Riverdale, Illinois, 

USEPA made a single source determination because of interdependency of the two 

facilities based on materials being transported between the two via commercial rail line. 

Based on the anticipated interdependency of the East and West Plants, Alcoa has 

concluded that they meet the “common sense” notion of a source given the functional 

inter-relationship of the facilities. Therefore, for the purpose of PSD applicability 

assessment, the East and West Plants are viewed as a single source following the 

modernization project. 

3.2 PROJECT BOUNDARY 

The first step in characterizing emissions from the modernization project is defining the 

project boundary. The Massena operations affected by the modernization are 

represented above in Table 2, and Figure 5. Affected emissions units (sources) that are 

included in the project boundary for the purpose of PSD applicability include those 

which will be: 

 new installations; 

 directly modified existing units (sources); 

 units (sources) that have an increase in emissions resulting from the removal of an 

upstream or downstream production constraints resulting from the project (debottlenecked units); and

 units (sources) which will be permanently shut-down (emissions will be included in 

the netting analysis). 

The following table presents those emission units (by their NYSDEC Title V source 

identifiers) which are affected by the modernization either directly or indirectly, along 

with a characterization of how the unit is viewed from a PSD applicability point of 

view. 
ERM ALCOA 13

Table 3 - Project Boundary Emissions Units (Sources) 

Title V PSD Applicability 

Unit ID 

Title V Unit 

Description 

Source ID 

(PSD Emission 

Unit) 

Source Description 

Characterization 

EAST PLANT 

A-NOD01 Anode Pin 

Room 

01580 Channel Cooling Area Shutdown - Include in netting 

via potline emissions 

C-RSH01 Crusher 

Building 

00182 00282 Crushing operations Shutdown since 2000 - no 

netting 

00122 9.8 mmBTU/hr HTM burner 

(nat gas) 

Shutdown - Include in netting 

00122 9.8 mmBTU/hr HTM burner 

(#6 fuel oil) 

Shutdown since 2000 – no 

netting 

00522 2000 ton petroleum coke storage 

silo 

Shutdown - Include in netting 

00622 2000 ton petroleum coke storage 

silo 

Shutdown - Include in netting 

01022 Anode Ball Mill Shutdown - Include in netting 

01222 Misc. Handling Shutdown - Include in netting 

01322 Eight carbon paste mixers Shutdown - Include in netting 

01422 Coal tar pitch scales exhaust Shutdown - Include in netting 

C-ARB01 

 

 

 

 

 

 

 

 

Carbon Plant 

 

 

 

 

 

 

 

 

00322 00422 120,000 Gallon Coal Tar Pitch 

Tank Coal Tar Pitch Unloading 

Shutdown - Include in netting 

P-DIG01 Cathode 

Digging 

46185 Cathode Digging Process Shutdown - Include in netting 

05152/05354/05556 Electrolytic Reduction Pot Line Remove Soderberg. Emissions 

are used in netting. 

PS001 Electrolytic Reduction Pot Line New PSD Unit 

PS002 Pot Room Roof Vents Associated with the new PreBake Line 

P-OT001 

 

 

 

 

Potline 

 

 

 

 

AC001 Anode Cooling New PSD Unit 

01320 Cruce Lid Cleaning No change 

01420 Cruce Augering No change 

0-CRUCE Cruce Augering 

01520 Cruce Augering New PSD Unit 

0125A Alumina unloading hopper, 

elevator, and transfer point 

Debottlenecked 

0125B Alumina/Coke conveyance Shut down 

0125C Alumina/coke conveyance Shut down 

0125D Alumina/coke conveyance Shut down 

00325 Alumina/coke conveyance Debottlenecked 

0125A Alumina/coke conveyance Debottlenecked 

0125B Alumina/coke conveyance Debottlenecked 

00325 Ore Gallery Coke/Briquette 

Conveying 

Debottlenecked 

00126 Bath Filling Area New PSD Unit 

00127 Bath Filling Area New PSD Unit 

00128 Bath Filling Area New PSD Unit 

00129 Bath Filling Area New PSD Unit 

00130 Transfer Pt New PSD Unit 

00131 Bath Storage Silo Transfer Point New PSD Unit 

U-LDG01 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Unloading and 

Transfer 

00132 Aluminum Fluoride Filling 

Area 

New PSD Unit 
ERM ALCOA 14

Table 3 - Project Boundary Emissions Units (Sources)(continued) 

Title V 

Unit ID 

Title V Unit 

Description 

Source ID 

(PSD Emission 

Unit) 

Source Description PSD Applicability 

WEST PLANT

AI014 6500 Ton Press Pre-Heat No change 

AI15A 6500 Ton Press Pre-Heat No change 

AI15B 5300 Ton Press Pre-Heat No change 

AI026 Homogenized Heat Treat 

Furnace 

Shutdown – Include in netting 

AI027 Homogenized Heat Treat 

Furnace 

Shutdown – Include in netting 

AI043 Homogenized Heat Treat 

Furnace 

Shutdown – Include in netting 

AI046 Homogenized Heat Treat 

Furnace 

No change 

AFC1A Heat Treat Furnace No change 

AFC1B Heat Treat Furnace No change 

AFC1C Heat Treat Furnace No change 

AFC1D Heat Treat Furnace No change 

AFC1E Heat Treat Furnace No change 

AF01A Heat Treat Furnace No change 

AF01B Heat Treat Furnace No change 

AF01C Heat Treat Furnace No change 

AF01D Heat Treat Furnace No change 

AF01E Heat Treat Furnace No change 

AF075 Heat Treat Furnace No change 

AF076 Heat Treat Furnace No change 

AF74A Heat Treat Furnace No change 

AF74B Heat Treat Furnace No change 

AF014 Heat Treat Furnace #13 No change 

AF015 Heat Treat Furnace #14 No change 

AF02A Heat Treat Furnace #15 No change 

AF02B Heat Treat Furnace #16 No change 

AF78A Heat Treat Furnace #17 No change 

A-00001 Homogenizing 

and Heat Treat 

Furnaces 

AF78B Heat Treat Furnace #18 No change 

AI047 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI048 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI049 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI050 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI051 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI052 Homogenized Heat Treat 

Furnace 

New PSD Unit 

AI053 Homogenized Heat Treat 

Furnace 

New PSD Unit 

M004A Molten Aluminum Melting and 

Holding Furnaces 

New PSD Unit 

M004B Molten Aluminum Melting and 

Holding Furnaces 

New PSD Unit 

M004C Molten Aluminum Melting and 

Holding Furnaces 

New PSD Unit 

M004D In-Line Filterbox Fluxing Units New PSD Unit 

A-00003 Homogenizing 

Furnaces, 

Melting/Holding 

Furnaces with 

associated gas 

fired Filterbox 

Fluxing Units 

M004E In-Line Filterbox Fluxing Units New PSD Unit 
ERM ALCOA 15

Table 3 - Project Boundary Emissions Units (Sources)(continued) 

Title V 

Unit ID 

Title V Unit 

Description 

Source ID 

(PSD Emission 

Unit) 

Source Description PSD Applicability 

Characterization 

A-00003 Cont. M004F In-Line Filterbox Fluxing Units New PSD Unit 

B0001 Boiler burning natural gas or 

No. 6 Fuel Oil 

Debottlenecked 

B0002 Boiler burning natural gas or 

No. 6 Fuel Oil 

Debottlenecked 

B0003 Boiler burning natural gas or 

No. 6 Fuel Oil 

Debottlenecked 

B-00001 Boilers 

B0004 Boiler burning natural gas or 

No. 6 Fuel Oil 

Debottlenecked 

D-00001 Miscellaneous point 

sources 

DI116 Skim and Dross Area Increased Throughput 

M001E In-Line Filterbox Fluxing Units No change 

M0036 In-Line Filterbox Fluxing Units No change 

M003E In-Line Filterbox Fluxing Units No change 

M-00002 In-line filter box gas 

fluxing units 

M024E In-Line Filterbox Fluxing Units No change 

S-00001 Pre-bake Potline SS198 Electrolytic reduction pot line Increased Throughput 

S-00002 Anode Bake 

furnaces 

SS078 Anode Baking Furnace Increased Throughput 

S-00003 Paste Production 

Plant (Green Mill) 

SS099 Paste Production Plant Modified - Process change 

SS415 Small Induction Furnaces Debottlenecked 

SS483 Electric Welder Shutdown since 2000 - no 

netting 

SS495 Packed Coke Drilling Operation Debottlenecked 

SS490 Alumina Loading and 

Unloading 

Debottlenecked 

423AB Spent Anode Rough Cleaning Debottlenecked 

423AA Bath Handling, Crushing and 

Crucible Digging Operations 

Debottlenecked 

SS441 Transfer Pt. For 2 Alumina belt 

conveyors (Build 441) 

No change 

SS438 Butt Crushing Debottlenecked 

SS449 See Process Description Debottlenecked 

SS486 Storage Tank 440a And 440b 

Fluidizer For Alumina 

No change 

SS492 Truck Hopper Unloading No change 

SS443 Transfer Pt 441C No change 

SS446 Alumina Transfer Pt. 446A No change 

SS447 Alumina Transfer Pt. 446B No change 

SS448 Alumina Transfer Pt. 446C No change 

S-00004 Material Handling 

Operations 

SS402 Pot Digging/Spent Potlining 

Operations 

Debottlenecked 
ERM ALCOA 16

Table 3 - Project Boundary Emissions Units (Sources)(continued) 

Title V 

Unit ID 

Title V Unit 

Description 

Source ID 

(PSD Emission 

Unit) 

Source Description PSD Applicability 

Characterization 

SS088 Tar Pitch Storage Tank Debottlenecked 

SS089 Tar Pitch Storage Tank Debottlenecked 

SSFP2 Pitch Recirculating Pumps Debottlenecked 

SS073 Rail Car Unloading Station Debottlenecked 

SS077 Rail Car Unloading Station Debottlenecked 

S-00005 Coal Tar Pitch 

Unloading and 

Storage 

SSFP1 Pitch Recirculating Pumps Debottlenecked 

SSFA1 Coke Unloading Operations Debottlenecked 

SSFA2 Coke Handling and Storage 

Operations 

Debottlenecked 

SSFA3 Clamshell Bucket Operations Debottlenecked 

SSFAC Fugitives from passive anode 

cooling 

No change 

S-00006 Smelting and anode 

Fugitives (not 

including potline) 

SSFSM Seam Mix Operations No change 

3.3 BASELINE ACTUAL EMISSIONS 

Baseline actual emissions are determined using the provisions of 31 December 2002, 

NSR reform rule. Specifically, consistent with 40 CFR 52.21 (48) Baseline actual 

emissions means:

The rate of emissions, in tons per year, of a regulated NSR pollutant, as determined in accordance with 

paragraphs (b)(48)(i) through (iv) of this section. 

(i ) For any existing electric utility steam generating unit... 

(ii) For an existing emissions unit (other than an electric utility steam generating unit), baseline actual 

emissions means the average rate, in tons per year, at which the emissions unit actually emitted the pollutant 

during any consecutive 24-month period selected by the owner or operator within the 10-year period immediately 

preceding either the date the owner or operator begins actual construction of the project, or the date a complete 

permit application is received by the reviewing authority for a permit required either under this section or under 

a plan approved by the Administrator, whichever is earlier, except that the 10-year period shall not include any 

period earlier than November 15, 1990. 

(a) The average rate shall include fugitive emissions to the extent quantifiable, and emissions associated 

with startups, shutdowns, and malfunctions. 

(b) The average rate shall be adjusted downward to exclude any noncompliant emissions that occurred while 

the source was operating above an emission limitation that was legally enforceable during the consecutive 24- 

month period. 

 (c) The average rate shall be adjusted downward to exclude any emissions that would have exceeded an 

emission limitation with which the major stationary source must currently comply, had such major 

stationary source been required to comply with such limitations during the consecutive 24-month period. 

However, if an emission limitation is part of a maximum achievable control technology standard that the 

Administrator proposed or promulgated under part 63 of this chapter, the baseline actual emissions need only 

be adjusted if the State has taken credit for such emissions reductions in an attainment demonstration or 

maintenance plan consistent with the requirements of § 51.165(a)(3)(ii)(G). 

(d) For a regulated NSR pollutant, when a project involves multiple emissions units, only one consecutive 

24-month period must be used to determine the baseline actual emissions for the emissions units being 

changed. A different consecutive 24-month period can be used for each regulated NSR pollutant. 

(e) The average rate shall not be based on any consecutive 24-month period for which there is inadequate 

information for determining annual emissions, in tons per year, and for adjusting this amount if required by 

paragraphs (b)(48)(ii)(b) and (c) of this section. 

(iii) For a new emissions unit, the baseline actual emissions for purposes of determining the emissions increase 

that will result from the initial construction and operation of such unit shall equal zero; and thereafter, for all 

other purposes, shall equal the unit’s potential to emit....
ERM ALCOA 17

Alcoa has opted to use the average rate, in tons per year, from the prior two calendar 

years operation. The average actual emission rate for the two prior years is 

representative of actual operations of the last five years. Although the above referenced 

actual emission definition allows for the use of any consecutive 24 month period in the 

last 10 years, Alcoa has opted to limit its look back to five years to be consistent with 

the anticipated revisions to NYSDEC’s NSR rule (Part 231) anticipated early in 2009. 

NYSDEC’s draft rule currently limits the look back period for all sources (both utility 

and non-utility) to five years. Likewise, although the above referenced federal 

definition allows the use of different baseline periods for different pollutants, Alcoa has 

opted to use a single baseline period for all pollutants to be consistent with NYSDEC’s 

anticipated rule revisions. 

Table 4 –Twenty-four Month Average Baseline Actual Emissions 

Combined East and West Plant, Average Actual Emissions (tons/year)

Year NOx SO2 TF PM PM10 PM2.5 CO 

03-04 163 2,051 170 1,011 367 204 28,147 

04-05 171 2,540 188 1,297 471 262 30,333 

05-06 220 3,019 202 1,414 513 285 34,101 

06-07 268 2,955 193 1,425 521 291 36,474 

RED = Highest Value 

 = selected Baseline Actual Emission 

Baseline actual emissions supporting calculations for the selected baseline period are 

provided for reference in Appendix B, Table B1. Please note that baseline NOx 

emissions for 2006/2007 are based on the East Plant allowable emissions cap of 99 tons 

per year. Based on emission testing of the Soderberg potline in June and September of 

2008, the NOx emissions rate has been determined to be greater than previous actual 

emissions estimates. Therefore baseline emissions from the Soderber potline are based 

on allowable emissions instead of actual emissions (because the allowable emission is 

the lesser of the two). 
ERM ALCOA 18

3.4 PROJECTED ACTUAL/ALLOWABLE EMISSIONS 

Developing post modernization project actual emissions is a two step process. First 

projected actual emissions are determined based on anticipated maximum production 

and anticipated maximum (often permitted) emission levels. Second, the projected 

actual emissions from existing units are adjusted (emissions from new units are not 

adjusted) to account for emissions which are unrelated to the modernization project 

and which could have been accommodated by the source prior to the change. For 

reference, the 40 CFR Part 52.21(b) definition of projected annual emissions is provided 

as follows: 

(41)(i) Projected actual emissions means the maximum annual rate, in tons per year, at which an existing 

emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years (12-month period) 

following the date the unit resumes regular operation after the project, or in any one of the 10 years following 

that date, if the project involves increasing the emissions unit’s design capacity or its potential to emit that 

regulated NSR pollutant and full utilization of the unit would result in a significant emissions increase or a 

significant net emissions increase at the major stationary source. 

(ii) In determining the projected actual emissions under paragraph (b)(41)(i) of this section (before beginning 

actual construction), the owner or operator of the major stationary source: 

(a) Shall consider all relevant information, including but not limited to, historical operational data, the 

company’s own representations, the company’s expected business activity and the company’s highest 

projections of business activity, the company’s filings with the State or Federal regulatory authorities, 

and compliance plans under the approved State Implementation Plan; and 

(b) Shall include fugitive emissions to the extent quantifiable and emissions associated with startups, 

shutdowns, and malfunctions; and 

(c) Shall exclude, in calculating any increase in emissions that results from he particular project, that 

portion of the unit’s emissions following the project that an existing unit could have accommodated 

during the consecutive 24-month period used to establish the baseline actual emissions under paragraph 

(b)(48) of this section and that are also unrelated to the particular project, including any increased 

utilization due to product demand growth; or 

(d) In lieu of using the method set out in paragraphs (a)(41)(ii)(a) through (c) of this section, may elect to 

use the emissions unit’s potential to emit, in tons per year, as defined under paragraph (b)(4) of this 

section.

For each debottlenecked emissions unit, ALCOA has determined the emissions increase 

consistent with the actual to projected future actual emissions methodology required by 

the current PSD regulations. EPA provided a review of the current program 

requirements regarding the determination of emissions increases associated with 

debottlenecked emissions points in the September 14, 2006 Federal Register in the 

preamble to its proposed regulation concerning aggregation and debottlenecking. As 

EPA noted in the preamble (71 fr 54238): 

“The actual-to-projected-actual test in the 2002 rules for existing emissions units 

applies not only to the unit(s) undergoing the change but also to any other 

existing emissions unit(s) at the source that experiences a change in emissions 

related to the project. Thus, the current EPA rules permit emissions increases 

from debottlenecked units (and any other unit that increases its utilization as a 

result of the project) to be calculated using an ‘‘actual-to projected-actual’’ test.7 

We believe this represents a fair reading of our current regulatory text for 

‘‘projected actual emissions’’ found at 40 CFR .21(b)(41).8” 

The preamble makes clear that in projecting future actual emissions for debottlenecked 

emissions points, emissions projections may be adjusted for any emissions increases 
ERM ALCOA 19

that the unit could have accommodated in the baseline period which are unrelated to 

the change. 

Following the development of projected actual emissions for each emission unit being 

affected either directly or indirectly (debottlenecked) by the modernization project, 

Alcoa has adjusted the projected actual emissions to exclude those emissions that the 

unit could have accommodated to meet a particular level of demand (demand growth). 

Additionally, debottlenecked emission increases were adjusted, where appropriate, to 

account for emissions already authorized by pre-existing permit terms. A summary of 

debottlenecked or modified emission unit adjustments is provided in the following 

table. Note that this table only includes those Title V emission units with PSD 

pollutants. Each Title V emission unit includes one or more PSD emission units 

(sources). 

Table 5 - Projected Actual Adjustment Approach for Existing Emission Units (Sources) 

Title V Unit 

ID 

Unit Description Projected Actual Adjustment Approach - to account for Emissions that could have 

been accommodated before modernization due to demand growth, or pre-existing air 

quality permit terms

West Plant 

B-00001 Boilers The maximum heat demand between 2003 and 2007 (2005) was used to calculate 

combustion emissions from firing natural gas and No. 6 fuel oil as if one or the other had 

been used to generate the entire heat demand. Both fuels are permitted to be used by all 

boilers. No. 6 fuel oil produced the highest emissions for all of PSD pollutants. 

S-00001 Pre-bake Potline Percent sulfur in coke was increased to the allowable 2.5% based on State -BACT 

required by Title V Permit Condition No. 208. The maximum previous annual 

aluminum production, 12 months of production from September 2007 through August 

2008, was used to represent demand growth production capacity based on current 

operations. TF emissions were adjusted to reflect maximum annual average lb/ton 

emission rate using 2007 data. 

S-00002 Anode Bake 

Furnaces 

Maximum projected production of the West Plant anode bake furnaces of 182,243 tons of 

green anode production per year was used as the anode demand is not limited to the 

anodes that are used at the West plant. 

S-00003 Paste Production 

Plant 

 (Green Mill) 

The highest ratio of annual hours of operation to green anodes produced from 2005 to 

2007 (2006) was used to determine pre-modernization production capacity assuming 

8,760 hours of operation. 

S-00004 Material 

Handling 

Operations 

Changed annual days of operation to 365 and left hours of operation per day the same to 

account for the increase in aluminum production to capacity. 

Supporting calculations quantifying projected actual adjustments are included in 

Appendix B, Table B2. 

3.5 PSD APPLICABILITY DETERMINATION 

As discussed above, there are a number of complex steps necessary to determine if the 

Massena Modernization Project is a “major modification” under the PSD program. A 

“major modification is any physical change or change in the method of operation of a 

major stationary source (facility) that would result in a significant emissions increase of 

a regulated PSD pollutant, and a significant net emissions increase of that pollutant 

from the major stationary source. Consistent with the NSR reform rule, PSD 

applicability is determined by an actual to projected actual test. As described in the 

preceding sections, the actual to projected actual test consists of the following steps: 

Step 1: Significant Emission Increase Evaluation 
ERM ALCOA 20

Including the following sub-steps: 

 Calculate baseline actual annual emissions for each PSD regulated pollutant, for each 

emission unit (source) during the baseline period determined to be within the project 

boundary; 

 Calculate future actual or allowable emissions for new units and for those units 

which are either directly changed by the modernization project, or indirectly affected 

by upstream or downstream changes (debottlenecked). For existing sources that are 

directly and indirectly changed, projected emissions may be adjusted downward to 

exclude emissions that the unit was capable of accommodating prior to the change 

(demand growth emissions and permit accommodation). Projected emissions from 

new sources are not adjusted. 

 Subtract prior actual emissions of each pollutant from the projected actual/allowable 

emissions of that pollutant (following its demand growth and permit 

accommodation adjustments). Compare the difference (tons per year) to the PSD 

significance threshold for the respective pollutant. 

Step 2: Significant Net Emissions Increase Evaluation 

 For each pollutant emission which exceeds its respective significance threshold, add 

any emission increases and subtract any emissions decreases that are 

contemporaneous with the project (within the last five years) to determine the net 

emissions increase. 

 Compare the net emissions increase to the pollutant specific significance thresholds 

to determine if there is a significant net emissions increase. 

 Each pollutant with significant net emissions increase is subject to the PSD 

permitting program for all contributing sources that are within the project boundary. 

The following table provides a summary of the Step 1 Significant Emission Increase 

Evaluation. Supporting calculations are provided in Appendix B, Table B2. Please note 

that if the significant increase evaluation for an existing emission unit produced an 

emission decrease (a negative emissions increase), the emissions increase for that unit is 

counted as 0 or as no emissions increase. This occurred in a few occasions where the 

demand growth/permit accommodation adjustments resulted in a projected actual 

emission which was less than the baseline actual emission for the subject unit. 

Additionally, some projected actual values are dependent of the incorporation of 

federally enforceable permit terms into the modified Alcoa Title V Permits. 
ERM ALCOA 21

Table 6 – PSD Significant Emissions Increase Evaluation 

Unit ID Description Emission Type (TPY) NOx SO2 TF PM PM10 PM2.5 CO 

East Plant 

Baseline Actual 

Projected Future Actual 47.9 207.3 92.0 263.9 153.0 73.9 14,484.1 

Demand Growth Adjustment 

P-OT001 Pre-bake Potline 

Unit Emissions Increase 47.9 207.3 92.0 263.9 153.0 73.9 14,484.1 

Baseline Actual 

Projected Future Actual 1.1 

Demand Growth Adjustment 

P-OT001 Anode Cooling 

Unit Emissions Increase 1.1 

Baseline Actual 

Projected Future Actual 49.9 25.4 7.5 

Demand Growth Adjustment 

0-CRUCE Cruce Augering 

Unit Emissions Increase 49.9 25.4 7.5 

Baseline Actual 10.6 5.4 1.6 

Projected Future Actual 84.6 43.1 12.7 

Demand Growth Adjustment 

U-LDG01 

 

Unloading and 

Transfer Operations 

 

Unit Emissions Increase 74.0 37.8 11.1 

West Plant 

Baseline Actual 

Projected Future Actual 65.2 0.6 7.7 14.5 14.5 14.5 83.0 

Demand Growth Adjustment 

A-00003 Homogenizing and 

Melting/Holding 

Furnaces with 

Filterboxes Unit Emissions Increase 65.2 0.6 7.7 14.5 14.5 14.5 83.0 

Baseline Actual 36.3 75.0 5.2 5.2 5.2 2.7 

Projected Future Actual 163.6 247.9 12.7 12.7 12.7 4.6 

Demand Growth Adjustment 238.6 1,523.3 59.9 59.9 59.9 10.6 

B-00001 Boilers 

 

 

Unit Emissions Increase 0.0 0.0 0.0 0.0 0.0 0.0 

Baseline Actual 1.6 1.6 1.6 

Projected Future Actual 3.7 3.7 3.7 

Demand Growth Adjustment 

D-00001 Skim and Dross 

Unit Emissions Increase 2.1 2.1 2.1 

Baseline Actual 42.5 2,423.5 57.4 190.0 127.9 85.7 13,766.1 

Projected Future Actual 44.7 2,620.7 88.1 255.7 168.0 84.7 13,511.9 

Demand Growth Adjustment 0.7 156.5 9.5 7.2 12.1 5.9 6,198.2 

S-00001 Pre-bake Potline 

 

Unit Emissions Increase 1.5 40.7 21.2 58.6 28.0 0.0 0.0 

Baseline Actual 89.3 211.5 0.4 10.5 9.9 8.2 90.8 

Projected Future Actual 203.0 454.8 9.1 25.6 24.1 20.0 231.5 

Demand Growth Adjustment 112.3 243.2 0.5 12.1 11.3 9.4 104.5 

S-00002 Anode Bake Furnaces 

 

Unit Emissions Increase 1.5 0.0 8.2 3.1 2.9 2.4 36.2 

Baseline Actual 0.7 0.7 0.7 

Projected Future Actual 1.9 1.9 1.9 

Demand Growth Adjustment 0.8 0.8 0.8 

S-00003 Paste Production 

Plant (Green Mill) 

 

Unit Emissions Increase 0.5 0.5 0.5 

Baseline Actual 26.7 13.6 4.0 

Projected Future Actual 226.7 115.6 34.0 

Demand Growth Adjustment 15.4 7.9 2.3 

S-00004 Material Handling 

Operations 

 

Unit Emissions Increase 184.6 94.1 27.7 

Total Project Emissions: 116.1 248.6 130.2 691.0 385.2 156.2 14,603.2 

Significance Threshold 40.0 40.0 3.0 25.0 15.0 10.0 100.0 

As illustrated in the above table, all PSD pollutants are determined to have a significant 

emissions increase. The following table provides a summary of the Step 2 Significant 

Net Emission Increase Evaluation. Contemporaneous emissions increases and 

decreases are summarized below. Supporting calculations are provided in Appendix B, 

Table B2. 
ERM ALCOA 22

Table 7 – Significant Net Emissions Increase Evaluation 

Pollutant (Tons/Year) NOx SO2 TF PM PM-10 PM-2.5 CO 

Total Project Emissions 

(Project Actual - Demand Growth - Prior Actual)

135.3 248.7 137.3 673.9 379.5 165.8 14,623.0

Contemporaneous Emissions Decreases 

Unit ID Description

CARB-01 Carbon Plant 1.2 0.0 1.9 1.9 1.9 0.4 

E-WCST1 East Plant Castehouse 14.7 0.1 3.0 5.4 5.4 5.4 12.3 

P-OT001 Soderberg Potline 61.2 238.5 126.3 1,435.4 604.8 537.3 22,582.4

P-DIG01 Cathode Digging 0.2 0.1 0.0 

A-00001 Homogenizing and Heat Treat 

Furnaces 

22.4 0.1 0.1 1.7 1.7 1.7 18.8 

Total Contemporaneous Emissions Decrease 99.6 238.8 129.4 1,444.7 614.0 546.4 22,614.0

Net Emissions Increase 

(Total Project Emissions – Net Decreases): 

16.6 9.8 0.9 -753.8 -228.9 -390.2 -8,010.8

Significance Threshold 40.0 40.0 3.0 25.0 15.0 10.0 100.0 

Contemporaneous Emissions Increases 

Unit ID Description

M-00001 Salt Fluxing for MHA Furnaces 4.3 4.3 4.3 

C-00001 Chip Dryer No. 1 1.1 0.2 0.1 0.1 0.0 

Total Contemporaneous Emissions Increase 1.1 4.5 4.4 4.4 0.0 

Net Emissions Increase 

(Total Project Emissions + Net Increases): 

17.6 9.8 0.9 -749.3 -224.5 -385.8 -8,010.8

Significance Threshold 40.0 40.0 3.0 25.0 15.0 10.0 100.0 

Based on the above referenced modernization project netting analysis, there are no 

pollutants subject to PSD permitting. 
ERM ALCOA 23

4.0 NONATTAINMENT NEW SOURCE REVIEW (NSR) APPLICABILITY 

As discussed above, New York State is located in the Northeastern U.S. Ozone 

Transport Region. As a result, emissions of ozone precursor pollutants VOC and NOx 

are regulated as nonattainment pollutants. New and modified emission sources at 

facilities which are classified as “major” for nonattainment pollutants are regulated 

under the New York Nonattainment NSR program. The Nonattainment NSR Program 

is codified under 6 NYCRR Part 231-2, and is implemented by NYSDEC. Under Part 

231-2.2(a)(4), a facility is subject to Nonattainment NSR if an emissions increase of VOC 

or NOx: 

at an existing major facility, it is part of a significant source project for any such nonattainment contaminant 

which results in a significant net emission increase for that nonattainment contaminant. 

The Alcoa Massena East and West Plants are existing major facilities under Part 231. 

Therefore to assess applicability the following steps are necessary: 

 Determine prior and future “maximum annual potential” (MAP) emissions of VOC 

and NOx for each Title V emissions unit;

 Define the Part 231-2 “source project” by identifying any new emission units, and 

existing emission units which have an associated increase in MAP resulting from the 

project. Each emissions unit with an increase in MAP for either VOC or NOx is part 

of the “source project”; 

 For each emission unit that is determined to be part of the “source project”, 

determine the total “project emission potential” (PEP) of VOC and NOx; 

 Based on the PEP for VOC and NOx, determine if the project is a “Significant Source 

Project” by comparing the PEP to the significance thresholds (40 tons per year each 

for VOC and NOx); 

 If the project is a “Significant Source Project” for VOC or NOx, determine the net 

emissions increase (the PEP plus all creditable emission increases that are 

contemporaneous with the project, minus all emission reduction credits that are 

contemporaneous with the project); 

 Determine if there is a “Significant Net Emissions Increase” for the project by 

comparing the net emission increase for VOC or NOx to the respective significance 

thresholds (40 tons per year each for VOC and NOx). There is a “Significant Net 

Emissions Increase” if the net emissions increase exceeds the thresholds. Part 231-2 

applies to each contaminant for which there is a “Significant Net Emissions 

Increase”.

Details regarding each of the above referenced applicability steps are presented in the 

following sections. 
ERM ALCOA 24

4.1 SOURCE PROJECT DEFINITION AND EMISSION UNIT MAP ANALYSIS 

Consistent with Part 231-2(b)(40), a source project is: 

Any of the following proposed projects at an existing facility which results in an increase in emissions of a 

nonattainment contaminant but does not include any emission reductions: 

 (i) a new emission unit (replacement of an emission unit with similar equipment is addressed under 

subparagraph (ii) of this paragraph); or 

 (ii) a physical change in, or change in the method of operation of, an emission unit which results in an 

increase in the maximum annual potential of the emission unit; or 

 (iii) multiples or combinations of the above which are related actions and are included in, dependent on, or 

undertaken as a result of any long range plan of which each such emission unit is a part. 

It is important to note that for the purpose of Part 231 applicability, the term emissions 

unit means the NYSDEC defined Title V emissions unit (this is different than the 

emission unit referred to in the PSD applicability discussion). All current Massena 

modernization activities fall into Part 231-2(b)(40)(ii) above. That is, all new equipment, 

and physical/operational changes affect only existing Title V emissions units. In other 

words, there are no new Title V emission units being added. 

In order to determine which emission units are part of the source project, it is necessary 

to calculate the future (post modernization), and prior MAP for each Title V emission 

unit. Consistent with Part 231-2(b)(22), MAP is defined as:

The maximum annual capacity in tons per year of an emission unit to emit a nonattainment contaminant. 

Maximum annual potential shall:

(i) be determined after control equipment has been applied using the maximum enforceable permissible 

emission rate; and 

(ii) be based on continuous operation for 8,760 hours per year at maximum capability under the 

emission unit's physical and operational design, unless limited by enforceable permit conditions; and 

(iii) not include either secondary emissions or fugitive emissions. 

The MAP assessment and source project determination is presented in the following table. 

Supporting calculations are provided in Appendix C, Table C1. 

Table 8 – MAP Summary and Source Project Definition 

Future MAP Prior MAP Part of Source 

Project? 

 Emission 

Unit* 

NOX 

(tons/yr)

VOC + COS 

(tons/yr) 

NOX 

(tons/yr)

VOC + COS 

(tons/yr) 

Yes or No 

East Plant P-OT001 47.9 240.3 92.9 333.3 No 

A-00001 65.4 14.1 109.4 16.5 No 

A-00003 84.4 6.7 0 0 Yes 

B-00001 756.9 19.3 756.9 19.3 No 

S-00001 44.7 247.9 44.7 247.9 No 

S-00002 203.0 18.6 203.0 18.6 No 

S-00003 2.8 2.1 Yes 

West Plant 

S-00005 3.9 3.9 No 

*Only the emission units that emit NOX, VOC, or COS and are affected by the modernization project are listed in 

this analysis 
ERM ALCOA 25

4.2 PEP AND SIGNIFICANT SOURCE PROJECT EVALUATION 

In order to determine if the project is a significant source project, it is necessary to 

determine the PEP. Consistent with Part 231-2(b)(32), PEP is defined as:

(32) Project emission potential. 

(i) Except for an electric utility steam generating unit, project emission potential of a proposed source project 

shall consider only proposed increases in emissions of a nonattainment contaminant and shall equal the sum of 

the following: 

(a) for new emission units, the maximum annual potential of each such emission unit; and 

(b) for existing emission units, the difference between prior actual annual emissions or prior allowable 

annual emissions, whichever is less, and the subsequent maximum annual potential of each such emission 

unit. 

(ii) For an electric utility steam generating unit.... 

(iii) Project emission potential does not include secondary emissions. 

(iv) At an existing major facility, fugitive emissions are not included in determining whether the project 

emission potential exceeds the significant source project threshold ...unless the facility belongs to one of the 28 

source categories listed in section 231-2.2(c) of this Subpart. 

(v) At an existing major facility, regardless of whether the facility belongs to one of the 28 source categories 

listed in section 231-2.2(c) of this Subpart, once the project emission potential of a proposed source project is 

determined to exceed the significant source project threshold in sections 231-2.12 or 231-2.13 of this Subpart 

without including fugitive emissions, the project emission potential must include fugitive emissions, to the 

extent they are quantifiable, for subsequent permitting purposes (such as air quality analyses, offsets, etc.). 

A summary of source project PEP and resulting significance is presented in the 

following table. Supporting calculations are provided in Appendix C, Table C1. 

Table 9 – PEP and Significant Source Project Evaluation 

Future MAP Prior Actual (avg 06-07) PEP 

(Future MAP - Prior Actual) 

Emission 

Unit* 

NOX 

(tons/yr) 

VOC + COS 

(tons/yr) 

NOX 

(tons/yr)

VOC + COS 

(tons/yr) 

NOX 

(tons/yr) 

VOC + COS 

(tons/yr) 

A-00003 84.4 6.7 0 0 84.4 6.7 

S-00003 2.8 1.0 1.8 

Total 84.4 8.6 

Significance Threshold 40 40 

4.3 SIGNIFICANT NET EMISSIONS EVALUATION 

In order to determine if the project has a significant net emissions increase, it is 

necessary to determine the net emissions. Net emissions are calculated by adding the 

PEP and all creditable emission increases that are contemporaneous with the project, 

and then subtracting all emission reduction credits that are contemporaneous with the 

project. A summary of the net emissions evaluation along with comparison to the NOx 

and VOC significance threshold is presented in the following table. Please note that 

emission reduction credit applications for contemporaneous emission decreases will be 

included in the Title V Permit modification application. 
ERM ALCOA 26

Table 10 –Part 231-2 Significant Net Emissions Increase Evaluation 

Future MAP Prior Actual (avg 06- PEP 

07) (Future MAP - Prior 

Actual) 

Emission 

Unit* 

NOX 

(tons/yr) 

VOC + 

COS 

(tons/yr) 

NOX 

(tons/yr) 

VOC + 

COS 

(tons/yr) 

NOX 

(tons/yr) 

VOC + 

COS 

(tons/yr) 

Source Project Contribution 

A-00003 84.4 6.7 0 0 84.4 6.7 

S-00003 2.8 1.0 1.8 

Significant Source Project Total 84.4 8.6 

Contemporaneous Emission Decreases 

P-OT001 47.9 240.3 61.2 251.6 -13.3 -11.3 

CARB-01 0 0 1.2 0.2 -1.2 -0.2 

E-WCST1 14.7 0.8 -14.7 -0.8 

A-00001 22.4 1.2 -22.4 -1.2 

Contemporaneous Emission Increases 

C-00001 1.1 0 1.1 0 

Net Emissions Increase 33.9 -4.9 

Significance Threshold 40 40 

Based on the above referenced modernization project netting analysis, the only 

pollutants subject to Part 231-2 permitting is NOx. Also, pursuant to the netting 

analysis and Part 231-2.2(a)(4), only sections 231-2.3, 231-2.4, 231-2.6, and 231-2.7 of that 

Subpart apply. 
APPENDIX A – Emission Unit Matrix 
Alcoa Massena East and West Plant Emission Unit Matrix

A-NOD01 This emissions unit consists of emissions 

sources located adjacent to the Anode Pin Room (on occassion this may also occur in other areas of the facility). There is one process identified within this emission unit (G01). This emission unit results in fugitive emissions and is not associated with the ventilation system.

G01 This process is for the channel cooling area. As the 

channels are removed from the pots, they are placed on a portable rack and allowed to cool prior to reforming in the channel press. Currently, this process is adjacent to the Anode Pin Room, but on occassion it may be done in other areas of the facility.

01580 Channel Cooling Area NA 

B-OIL01 I01 0122H Facility Boiler #2 (nat gas) 

0222H Facility Boiler #1 (nat gas) 0322H Facility Boiler #3 (nat gas) 

I03 0222H Facility Boiler #1 (#6 fuel oil) 

0322H Facility Boiler #3 (#6 fuel oil) 

C-RSH01 This emissions unit consists of emissions 

sources, control devices and emission points associated with the Crusher Building, Facility 82. There is one process associated with this emissions unit, process F01. The emission point identified as 82002 includes several power roof vents and therefore specific emission point data is not provided. This emissions unit also includes miscellaneous fugitive emissions generated from the process.

F01 The crusher building is used to crush spent carbon, scrap 

carbon paste, pot strippings and basement ore. These mateirals are then recycled into the Carbon Plant and potrooms. The materials to be crushed may be treated with various wetting agents to minimize dust generation during the crushing process. A baghouse is used to capture particulate emissions from the crushing operations.

00182 00282

Crushing operation Crushing operation

F0182 Baghouse 

NA

D-ROS01 This emission unit consists of emissions sources

associated with dross cooling processes and storage, facility 20 and 20C. This emission unit includes miscellaneous fugitive emissions from the processes.

Z01 This process is for the dross storage room. Dross, a 

mixture of various metal oxides, is generated from furnace skimmings. Dross is stored in a room prior to shipment to an outside vendor for reclamation.

01520 Dross storage room 

D-ROS02 This emission unit consists of emission sources 

associated with dross cooling in process Z01.

Z02 This process is for the dross cooling areas. After dross is 

removed from the furnace, it is allowed to cool prior to being placed into the dross storage room.

01720 Dross cooling area 

EAST PLANT EAST PLANT 

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

This emissions unit consists of emissions sources and emission points located in the Boiler Room, Facility 22H. There are two processes identified within this emissions unit, processes I01, and I03. These processes are identified in detail in the process description section of the application package.

This process is for the combustion of natural gas to produce steam for heating and cooling purposes throughout the plant. Each of the plant's three boilers has the capability to fire natural gas.This process is for the combustion of # 6 fuel oil to produce steam for heating and cooling purposes throughout the plant. Boilers #1 and #3 have the capability to fire #6 fuel 

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-1
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

C-ARB01 N02 This process is for a 9.8 mmBTU/ht HTM burner while 

firing natural gas. The burner is used to heat HTM oil. HTM oil is used in non-contact piping as a heat transfer medium to maintain the operation temperatures for the coal tar pitch storage and transfer operations, and to maintain the operation temperatures of the paste mixers in the Carbon Plant

00122 9.8 mmBTU/hr HTM burner (nat gas) 

N03 This process is for a 9.8 mmBTU/ht HTM burner while 

firing #6 fuel oil. The burner is used to heat HTM oil. HTM oil is used in non-contact piping as a heat transfer medium to maintain the operation temperatures for the coal tar pitch storage and transfer operations, and to maintain the operation temperatures of the paste mixers in the Carbon Plant

00122 9.8 mmBTU/hr HTM burner (#6 fuel 

oil)

N04 This process is the storage of petroleum coke and/or paste 

briquettes in two 2,000 ton petroleum coke storage silos.

00522 2000 ton petroleum coke storage silo 00622 2000 ton petroleum coke storage silo 

N05 01022 Anode Ball Mill N0222 Baghouse 

01222 Misc. Handling N0322 Baghouse 

N07 01322 Eight carbon paste mixers N0422 Dry coke scrubber 

01422 Coal tar pitch scales exhaust N0522 Dry coke scrubber 

N10 This process includes the coal tar pitch and the unloading 

operations. Coal tar pitch (pitch) is delivered to the site by rail in tank cars and is transferred to storage tanks to maintain an on-site inventory. The rail tank cars have an internal dip-pipe suitable for connection to a heated, flexible-top unloading pipe, a nitrogen gas connection and a vent line connection. The unloading pipe will be coupled to the two 120,000 gallon pitch storage tanks, the nitrogen gas line will be coupled to a liquid nitrogen system with an evaporator for producing medium pressure nitrogen gas, and the vent line will be connected to the closest pitch tank. Gaseous nitrogen will be admitted into the tank car forcing the transfer of liquid pitch to the storage tank.

00322 00422 

120,000 Gallon Coal Tar Pitch Tank Coal Tar Pitch Unloading 

N0922 N1022

Vented to 

Condensation Tank 

(22F), which is vented 

to a 55-gallon drum

E-WCST1 J01 0120G Furnace 7 

0220G SNIF 7 0320G Furnace 8 0420G SNIF 8 

J02 This process includes each of the cast house saws. 0620G #4 Saw 

00520 #5 Saw 00620 #3 Saw 

J04 00120 Furnace 2 

00220 Furnace 3 00320 Furnace 4 01820 ACD Degasser 

HMO This process includes the gas homogenizer furnace. This 

source is not subject to SMACT.

0520G Gas Homogenizing Furnace 

This emissions unit consists of emissions sources, control devices and emission points associated with the Carbon Plant (Anode side), Facility 22. There are seven processes identified within this emissions unit, processes N02, N03, N04, N05, N07, N08 and N10. This emissions unit also includes miscellaneous fugitive emissions generated from these processes. 

This process includes the miscellaneous petroleum coke handling and processing operation in the anode portion of the Carbon Plant. Petroleum coke is transferred from the coke silos to the Carbon Plant where it undergoes a number of handling and processing operations, including, sorting, crushing (via the anode ball mill), weighing and mixing. Two baghouses are used to control particulate matter emissions from this process - one for the anode ball mill and one for the miscellaneous handling equipment.This process includes the carbon paste mixers and the coal tar pitch scales. The carbon paste mixers are used to mix and weight the appropriate ratios of petroleum coke with the coal tar pitch to form the anode paste. The anode paste is then dumped into portable boxes for transfer into the potrooms. Both the coal tar pitch scales and the carbon paste mixers are vented to a dry coke scrubber to remove particulate matter and coal tar pitch volatiles.

This emission unit consists of emission sources and emission points located in the East and West casthouses. There are four processes identified within the emission unit; process J01, J02, J04 and HMO. The furnaces are natural gas fired melter/holders. This emission unit also includes miscellaneous fugitive emissions generated within the East and West casthouse.

This process includes furnaces 7 and 8, their associated SNIF units. Furnaces 7 and 8 and the SNIF units use reactive flux.This process includes furnaces 2, 3, and 4, and the degassing unit for furnace number 4. The Alcan Degassing Unit uses only Argon Gas. Furnaces 2, 3, and 4 use reactive flux introduced by flux wands.

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-2
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

P-AINO1 This emission unit consists of emission sources 

associated with the paint shop, facility 31. There is one process associated with this emission unit, process Q01. This emission unit consists of fugitive emissions generated from the process.

Q01 This process is for the facility paint shop. The paint shop is 

used primarily for maintenance painting, including vehicle touch-up and repair, furnace refinishing, storage tank refinishing, etc. Paint is applied manually and with spray guns.

00131 Facility Paint Shop 

P-ARTW1 This emission unit consists of parts washers 

located throughout the Alcoa East facility.

PW1 This process consists of batch cold cleaning degreasers in 

use plant wide.

PART1 batch cold cleaning degreasers 

P-DIG01 This emissions unit consists of emission 

sources, control devices, and emission points associated with the Cathode Digging Area, Facility 85.

E02 This process represents the cathode digging process. The 

cathode digging process involves several digging and skimming operations to remove the spent potliner from the cathode shell. Spent potliner is then placed in proper containers for shipment.

46185 Cathode Digging Process E4685 Baghouse 

P-OT001 A02 E5152 Dry Scrubber - South 

B5156 Wet Scrubber - North 

C5156 Wet Scrubber - South 

E5354 Dry Scrubber - Central B5156 Wet Scrubber - North 

C5156 Wet Scrubber - South 

E5556 Dry Scrubber - North B5156 Wet Scrubber - North 

C5156 Wet Scrubber - South 

00051 Pot Roof Vent 101-184 00152 Pot Roof Vent 201-284 00153 Pot Roof Vent 301-384 00154 Pot Roof Vent 401-484 00155 Pot Roof Vent 501-584 00156 Pot Roof Vent 601-684 

A05 This process consists of cathode baking. 05152 Cathode Baking Operation

05354 Cathode Baking Operation05556 Cathode Baking Operation

A06 This process consists of pot cut-out. 05152 Pot cut-out operation

05354 Pot cut-out operation05556 Pot cut-out operation

B01 E5152 Scrubber - Dry Alumina 

Injection

E5354 Scrubber - Dry Alumina 

Injection

E5556 Scrubber - Dry Alumina 

Injection

B5156 Wet Scrubber - North 

C5156 Wet Scrubber - South 

PS002 Pot Roof Vents 

Anode Cooling E5152 Scrubber - Dry Alumina 

Injection

E5354 Scrubber - Dry Alumina 

Injection

E5556 Scrubber - Dry Alumina 

Injection

B5156 Wet Scrubber - North 

C5156 Wet Scrubber - South 

NA NA 

This process consists of fugitive hydrogen fluoride emissions from transport of anodes from the potline, and hydrogen fluoride emissions from passive anode cooling.

ANO AC001

PS001

This emission unit consists of the three potlines. One Pre-Bake Potline and the Anode Cooling Area

This process is for the pots venting to the fume control 05152 Potline 1system.

05354 Potline 205556 Potline 3

This process consists of one pot line of electrolytic cells and associated control equipment. this pot line is categorized as a center work prebake (cwpb) as described in the definitions section of epa's primary aluminum MACT regulations. 

Electrolytic Reduction Pot Line

Same controls and emission pSame controls and emission p

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-3
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

0-CRUCE A03 01320 Cruce Lid Cleaning L2002 Baghouse 

01420 Cruce Augering 0142B Baghouse 01520 Cruce Augering E4685 Baghouse 

U-LDG01 P01 0125A Alumina unloading hopper, elevator, 

and trasnsfer point

P0225 Baghouse 

0125B Coke/Briquette unloading hopper 

0125C Unloading shed fugitives 0125D Coke/Briquette elevator and transfer 

point

P0125 Baghouse 

P03 00125 Ore Gallery 

00225 Alumina conveying B0125 Baghouse 00325 Alumina/coke conveyance operation B0225 Baghouse 

0125A Alumina/coke conveyance operation B0325 Baghouse 0125B Alumina/coke conveyance operation B0425 Baghouse 

0125C Alumina/coke conveyance operation B0525 Baghouse 0125D Alumina/coke conveyance operation B0625 Baghouse 

00325 Ore Gallery Coke/Briquette 

Conveying

00126 Bath Filling Area P0125/P0225 Fabric Filter 00127 Bath Filling Area P0125/P0225 Fabric Filter 00128 Bath Filling Area P0125/P0225 Fabric Filter 00129 Bath Filling Area P0125/P0225 Fabric Filter 00130 Transfer Pt for alumina P0125/P0225 Fabric Filter 00131 Bath Storage Silo Transfer Point P0125/P0225 Fabric Filter 00132 Aluminum Fluoride Filling Area P0125/P0225 Fabric Filter 

W-WTR01 This emission unit consists of emission sources 

and emission points associated with the wastewater treatment operations, facility 63, 63A-63J, 65, 65A, 65B, and 66. There is one process associated with this emission unit, process WW1. This emission unit includes miscellaneous fugitive emission sources.

WW1 This process consists of water and wastewater treatment 

operations at the facility, including, but not limited to, ponds, lagoons, settling tanks, wastewater treatment operations, etc. This unit primarily contains fugitive emissions.

WWT01 Wastewater treatment operations 

This process includes the alumina and coke and/or briquette conveyance systems and miscellaneous bath filling and storage along with associated transfer points to their storage silos. Baghouses are employed to control particulate emissions from this process.

This emission unit consists of emission sources, control devices and emission points associated with the process of cruce augering and cleaning and cruce lid cleaning.This emission unit consists of emission sources, control devices and emission points associated with the Unloading Shed, facility 25. There are 2 processes associated with this emission unit, processes P01 and P03. There are four silos located in the courtyard, which are inactive; however, they provide structural support to the ore gallery and will not be removed. These are not air contamination sources, as they are not used and contain no product. Therefore these four silos, 25A, 25B, 25C, and 25D, are not identified as emission sources within this package.

This process includes unloading and transfer operations for alumina ore, petroleum coke and/or paste briquettes and aluminum fluoride. The alumina hopper, elevator, and transfer point in the ore gallery are vented to a baghouse as is the coke/briquette operation.This process consists of cruce augering and cleaning and cruce lid cleaning.

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-4
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

AI014 6500 Ton Press Pre-Heat

AI15A 6501 Ton Press Pre-HeatAI15B 5300 Ton Press Pre-Heat

AI026 Homogenized Heat Treat FurnaceAI027 Homogenized Heat Treat FurnaceAI043 Homogenized Heat Treat FurnaceAI046 Homogenized Heat Treat Furnace

AFC1A Heat Treat FurnaceAFC1B Heat Treat Furnace

AFC1C Heat Treat FurnaceAFC1D Heat Treat Furnace

AFC1E Heat Treat Furnace

AF01A Heat Treat FurnaceAF01B Heat Treat Furnace

AF01C Heat Treat FurnaceAF01D Heat Treat Furnace

AF01E Heat Treat Furnace

AF075 Heat Treat FurnaceAF076 Heat Treat Furnace

AF74A Heat Treat FurnaceAF74B Heat Treat Furnace

AF014 Heat Treat Furnace #13AF015 Heat Treat Furnace #14

AF02A Heat Treat Furnace #15AF02B Heat Treat Furnace #16AF78A Heat Treat Furnace #17AF78B Heat Treat Furnace #18

FAB Small crucible located in the Fabricating Shop used 

occasionally to melt lead, lead bismuth, zinc or tin babbit. Cruce heated by natural gas fired burner.

AF062 Crucible (Nat Gas fired)

AF031 Small Nat Gas Oven

AF063 Small Nat Gas OvenAF064 Small Nat Gas OvenAF065 Maintenance Painting RoomAF067 Maintenance Painting Room

AI047 Homogenized Heat Treat FurnaceAI048 Homogenized Heat Treat FurnaceAI049 Homogenized Heat Treat FurnaceAI050 Homogenized Heat Treat FurnaceAI051 Homogenized Heat Treat FurnaceAI052 Homogenized Heat Treat FurnaceAI053 Homogenized Heat Treat Furnace

M004A Molten Aluminum Melting and 

Holding Furnaces (permitted to use salt fluxes)

M004B Molten Aluminum Melting and 

Holding Furnaces (permitted to use salt fluxes)

M004C Molten Aluminum Melting and 

Holding Furnaces (permitted to use salt fluxes)

M004D In-Line Filterbox Fluxing Units

M004E In-Line Filterbox Fluxing Units

M004F In-Line Filterbox Fluxing Units

B0001 Boiler (when burning nat gas)B0002 Boiler (when burning nat gas)B0003 Boiler (when burning nat gas)B0004 Boiler (when burning nat gas)B0001 Boiler (when burning #6 oil)B0002 Boiler (when burning #6 oil)B0003 Boiler (when burning #6 oil)B0004 Boiler (when burning #6 oil)

A-00003 Homogenizing and Melting/Holding furnaces 

with associated in-line filterbox fluxing units for the Melting/Holding furnaces.process heaters treat solid aluminum and emit small quantities of process emissions due to residuals on the aluminum. emissions comingle with products-of-combustion (poc) from natural gas burners.

HM1 Homogenizing heat treat furnaces. each uses multiple 

direct fire natural gas burners. chemical additive prevents oxidation of surface of metal and produces incidental hydrogen fluoride emissions as a by-product.

A-00001

heat treat furnaces #30, 31, 32, 33, 34, 35, 36, 37, 38.

HT2 heat treat furnaces #13, #14 and #15.

homogenizing heat treat furnaces. each uses multiple direct fire natural gas burners. chemical additive prevents oxidation of surface of metal and produces incidental hydrogen fluoride emissions as a by-product.

HMO

B-00001 four package boilers firing either natural gas or 

#6 fuel oil.

GAS four boilers when burning natural gas.

three (3) small natural gas ovens and two (2) maintenance painting rooms used in maintenance shops. 

OIL four boilers when burning no. 6 fuel oil.

MH1 molten aluminum melting and holding furnaces which are 

permitted to use salt fluxes at the time of title v application submission. all furnaces are reverberatory, center charged. no gas fluxing is done in any furnace.

FBB in-line filterbox fluxing units.

A-00002 insignificant shop sources.

WEST PLANT WEST PLANT 

EPH one 6500 ton press pre-heat, one 1500 ton press pre-heat, 

and one 5300 ton press pre-heat furnace. each uses multiple direct fire natural gas burners.

HT1

MRS

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-5
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

CD1 chip dryer #1 dries aluminum machining chips with heated C0029 Chip Dryer #1 (Dry) C029A Single Cyclone

C029B Direct Flame 

Afterburner

CM1 chip melter #1 melts clean aluminum machining chips. C0030 Chip Dryer #1 (Melt)

CD2 chip dryer #2 dries aluminum machining chips heated with 

air.

C0044 Chip Dryer #2 (Dry) C044A Multiple Cyclone W/O 

Fly Ash Injection

C044B Thermal Oxidizer

CM2 chip melter #2 melts clean aluminum machining chips. C0045 Chip Dryer #2 (Melt)

ALB aluminum burnisher DF142 Aluminum Burnisher DFF42 Centrifugal

CCT emulsified oil and water system for the continuous caster. DII42 Emulsified Oil and Water System

PRT fabricated aluminum bars pass through an enclosed spray 

chamber where a clear protective coating is applied to the base metal. the coating is transparent and uses the undercoat aluminum as a reflective base. emissions pass through a mist collector and vent inside the building.

DF073 Enclosed Spray Chamber

SKD skim and dross area used for passive cooling of skim 

and dross.

DI116 Skim and Dross Area DI016 Fabric Filter

FB1 fugitives from the bull block. process applies high boiling 

point (greater than 300f) solvent to slightly hot metal to adhere metal to block. voc emissions are included on the annual emissions statement.

FFFB1 Bull Block Fugitives

FB2 fugitives from the ink jet printer. methyl ethyl ketone (mek) 

used as a carrier solvent. 

FFFB2 Ink Jet Printer Fugitives

FB3 fugitives from wax dipping and air drying coils. wax is 

mixed with water and heated.

FFFB3 Wax Dipping Fugitives

FC1 fugitives from the rod oiler associated with the continuous 

caster. 

FIFC1 Rod Oiler Fugitives

FC2 fugitives from the automatic lathe. FIFC2 Automatic Lathe FugitivesFC3 two (2) mold shop bake ovens. small oven is used to 

volatilize oil impregnated in graphite rings. 

FIFC3 2 Mold Shop Bake Ovens

M001A Molten Aluminum Melting and M001B Molten Aluminum Melting and 

M024C Molten Aluminum Melting and M024D Molten Aluminum Melting and 

M024F Molten Aluminum Melting and 

M001C Molten Aluminum Melting and M001D Molten Aluminum Melting and 

M0034 Molten Aluminum Melting and M0035 Molten Aluminum Melting and 

M003A Molten Aluminum Melting and 

M003C Molten Aluminum Melting and 

M001E In-Line Filterbox Fluxing Units

M0036 In-Line Filterbox Fluxing Units

M003E In-Line Filterbox Fluxing UnitsM024E In-Line Filterbox Fluxing Units

P-00001 This emission unit consists of all the parts washers in the facility. PWS This process consists of all the cold cleaning parts washers. PARTS Facility cold cleaning parts washers 

F-00001 alcoa engineered products (aep) fugitives.

M-00001 aluminum melting and holding furnaces. all 

furnaces are reverberatory, center charged. furnace charge molten aluminum, clean scrap, alloying ingredients and salt. no gas fluxing is done in any furnace.

M-00002 in-line filter box fluxing units use a mixture of 

argon and chlorine gas to purify molten aluminum as it is being cast into ingots or rod. 

FBA in-line filterbox fluxing units.

MHA molten aluminum melting and holding furnaces. currently, 

these furnaces are not permitted to use salt fluxes.

MHS molten aluminum melting and holding furnaces which are 

permitted to use salt fluxes at the time of title v application submission. all furnaces are reverberatory, center charged. no gas fluxing is done in any furnace.

C-00002 chip dryer #2 with associated control equipment 

(cyclone and afterburner) and chip melter #2.

D-00001 miscellaneous point sources.C-00001 chip dryer #1 with associated control equipment 

(cyclone and afterburner) and chip melter #1. 

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-6
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

SS198 Electrolytic reduction pot line SA398 Scrubber - Dry Alumina 

Injection

SPRV1 Potline roof vents 

S-00002 anode baking furnace and associated alumina injection dry scrubber. BAK anode baking furnace and associated alumina injection dry scrubber. SS078 Anode Baking Furnace SS78S Scrubber - Dry Alumina Injection S-00003 paste production plant and associated coke injection scrubber. GMS paste production plant and associated coke injection scrubber. SS099 Paste Production Plant SS100 Scrubber - Dry Coke Injection 

M01 building 332 dust collection equipment includes a stub hole 

cleaner which uses air to blow coke dust out of stub holes. process m01 also includes two small induction furnaces used for melting iron, and anthracite coal handling and storage.

SS415 Small Induction Furnaces SS015/SS016/

SS017

Fabric Filter

M02 electric welder used to weld aluminum, copper, and steel 

together. weld is produced under high current and hydraulic pressure.

SS483 Electric Welder SS083 Fabric Filter

M03 packed coke drilled out of anode stub holes. SS495 Packed Coke Drilling Operation SS095 Fabric Filter

M04 dry scrubber alumina loading and unloading area. SS490 Alumina Loading and Unloading SS090 Fabric Filter

M05 rough cleaning of spent anodes. 423AB Spent Anode Rough Cleaning S23AB Fabric FilterM06 bath handling, crushing and crucible digging operations. 423AA Bath Handling, Crushing and Crucible Digging Operations S23AA/S23AC Fabric Filter

M07 transfer point in building 441 for two alumina belt 

conveyors.

SS441 Transfer Pt. For 2 Alumina belt 

conveyors (Build 441)

SS041 Fabric Filter

M08 butt crushing. SS438 Butt Crushing SS038 Fabric FilterM09 anode butt storage, storage filling, aggregate blending, 

coke crushing, storage discharge, ball mill classifying, and intermediate classifying.

SS449 See Process Description SS049/SS050/

SS051/SS052/SS053/SS060/

SS061/SS449

Fabric Filter

M10 storage tank 440a and 440b fluidizer for alumina SS486 STORAGE TANK 440A AND 440B SS086 Fabric FilterM11 track hopper dust collector for alumina unloading and 

alumina airlift tower dust collector.

SS492 Truck Hopper Unloading SS092/SS093 Fabric Filter

M12 transfer point 441c serves st441c and the transfer of 

alumina to st441b.

SS443 Transfer Pt 441C SS043 Fabric Filter

M13 alumina transfer point 446a from reactors to storage 

tanks.

SS446 Alumina Transfer Pt. 446A SS046 Fabric Filter

M14 alumina transfer point 446b from reactors to storage 

tanks.

SS447 Alumina Transfer Pt. 446B SS047 Fabric Filter

M15 alumina transfer point 446c from reactors to storage SS448 Alumina Transfer Pt. 446C SS048 Fabric FilterM16 pot digging and spent potlining handling operations 

controlled by a fabric filter to limit particulate emissions to the environment.

SS402 Pot Digging/Spent Potlining 

Operations

SS102 Fabric Filter

SS088 Tar Pitch Storage TankSS089 Tar Pitch Storage Tank

SSFP2 Pitch Recirculating Pumps

SS073 Rail Car Unloading StationSS077 Rail Car Unloading Station

SSFP1 Pitch Recirculating Pumps

electrolytic reduction of alumina into aluminum. 

POT one pot line of electrolytic cells and associated 

control equipment. this pot line is categorized 

as a center work prebake-1 (cwpb-1) as 

described in the definitions section of epa's 

primary aluminum mact regulations. 

S-00001S-00005 coal tar pitch unloading and storage. 

PUN coal tar pitch unloading includes a single emission point (ep) serving each of two railcar unloading stations, and 

fugitives including but not limited to those associated with the pitch unloading pumps. some of these fugitives are exhausted through the ventilator building designated as ep 

073

PST coal tar pitch includes a single emission point (ep) serving 

each of two coal tar pitch storage tanks, and fugitives including but not limited to those associatedwith the pitch recirculating pumps located in building 352f.

S-00004 material handling operations for alumina, carbon 

and other miscellaneous solid materials. each are controlled by a fabric filter to limit particulate emissions to the environment.

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-7
Alcoa Massena East and West Plant Emission Unit Matrix

Unit ID Unit Description Process 

ID

Process Description Source ID Source Description Control ID Control Description

FA1 total suspended solid (i.e. particulate) fugitives from coke 

unloading.

SSFA1 Coke Unloading Operations

FA2 total suspended solid (i.e. particulate) fugitives from coke 

storage and handling.

SSFA2 Coke Handling and Storage 

Operations

FA3 total suspended solid (i.e. particulate) fugitives from 

clamshell bucket operations in the anode baking furnace room.

SSFA3 Clamshell Bucket Operations

FAC when spent anodes are placed in building 380 and 376 to 

cool, there are fugitive emissions from passive anode cooling. some hydrogen fluoride is emitted as a result of the residual bath on the anodes. emissions are included on the annual emissions statement.

SSFAC Fugitives from passive anode cooling

FSM seam mix operations include: low temperature pitch 

unloading and storage, the mixing of pitch, anthracite coal and liquid methylnapthalene, and the placing of final product in bags. fugitive emissions consist of polycyclic organic matter.

SSFSM Seam Mix Operations

OWT treatment of miscellaneous oily wastewaters using a 

precoate vacuum filter. vacuum exhaust is the emission point.

W0068 Miscellaneous oily wastewater 

treatment

W0070 WW Treatment Operations W0069 Sodium - Alkali 

Scrubbing

W0071 WW Treatment Operations W0069 Sodium - Alkali 

Scrubbing

W-00001 wastewater treatment operations.

S-00006 smelting and anode plant fugitives excepting pot 

line fugitives (the pot line fugitives are regulated under primary aluminum mact regulations).

WWT wastewater treatment consists of chemical pre-treatment, 

and biological treatment.

Red Text Indicates New SourcesBlue Text Indicates Sources to be Removed Table A-8
 APPENDIX B – PSD APPLICABILITY 

SUPPORTING CALCULATION
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Emissions Summary

NOx SO2 TF PM PM10 

Projected 

Actual

Demand 

Growth Prior Actual

Projected 

Actual

Demand 

Growth Prior Actual

Projected 

Actual

Demand 

Growth Prior Actual

Projected Actual

Demand 

Growth Prior Actual

Projected Actual

Demand 

Growth Prior Actual

Unit ID Description Moderization Impact lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year lb/Year 

East Plant

A-NOD01 Anode Pin Room Shut Down

B-OIL01 Boilers No change - Not included in PSD

C-RSH01 Crusher Building Shut Down

D-ROS01 Dross Storage Room No change - Not included in PSDD-ROS02 Dross Cooling No change - Not included in PSD

C-ARB01 Carbon Plant Shut Down 2,463 15 3,839 3,839 

E-WCST1 Cast House Shut Down 29,402 176 5,927 10,880 10,880 

P-OT001 Potline Replaced by new pre-bake potline 122,457 477,080 252,668 2,870,868 1,209,664 P-OT001 Potline New Pre-Bake Line 95,864 414,533 184,046 607,772 359,928 P-OT001 Anode Cooling New Anode Cooling Area 2,220

0-CRUCE Cruce Augering Cruce Augering 99,751 221 50,873 113 

P-AINO1 Paint Shop No change - Not included in PSD

P-ARTW1 Parts Washers No change - Not included in PSD

U-LDG01 Unloading and Transfer Chages to include some equipment elimination, and new 

bath filling, bath storage, and AlFl3 Filling Station. 169,164 21,110 86,274 10,766 

W-WTR01 Wastewater Treatment No change - Not included in PSD

P-DIG01 Cathode Digging Shut Down 479 244 

West Plant

A-00001 Homogenizing and Heat Treat Furnaces Some sources will not change. Three homogenizing 

furnaces will be removed. 44,782 269 112 3,403 3,403 

A-00002 Insignificant Shop Combustion Sources No change - Not included in PSDA-00003 New Homogenizing and Heat Treat 

Furnaces, New Melter/Holder Furnaces and Associated Filterbox Fluxing Units

Seven new Homogenizing Furnaces, Three new Melting/Holding Furnaces, and Three new Filterbox Fluxing Units 130,343 1,185 15,330 28,907 28,907 

B-00001 Boilers Increase in load demand 327,158 477,223 72,505 495,811 3,046,588 149,978 25,375 119,850 10,456 25,375 119,850 10,456 

C-00001 Chip Dryer #1 No change - Not included in PSDC-00002 Chip Dryer #2 No change - Not included in PSDD-00001 Miscellaneous metal finishing and 

skim/dross cooling

Increase in Skim and Dross due to increased throughput 7,402 3,232 7,402 3,232 

F-00001 Miscellaneous fugitive sources No change - Not included in PSD

M-00001 Melting/Holding Furnaces with no gas 

fluxing (salt only)

No change - Not included in PSD

M-00002 In-line filter box gas fluxing units No change - Not included in PSD

P-00001 Parts Washers No change - Not included in PSDS-00001 Pre-bake Potline Increased throughput 89,430 1,392 85,057 5,241,393 313,034 4,846,915 176,172 18,981 114,805 511,478 14,300 380,019 335,984 24,166 255,784 

S-00002 Anode Bake furnaces Increased throughput 406,091 224,529 178,529 909,558 486,493 423,063 18,224 926 805 51,210 24,125 20,980 48,138 22,678 19,721 S-00003 Paste Production Plant (Green Mill) Increased throughput 3,815 1,581 1,331 3,815 1,581 1,331 S-00004 Material Handling Operations Some souces will have increased thoughput, others will not 

change. 453,353 30,876 53,330 231,210 15,747 27,198 

S-00005 Coal Tar Pitch Unloading and Storage Increased throughputS-00006 Smelting and anode Fugitives (not 

including potline)

Some souces will have increased thoughput, others will not chance.

W-00001 Wastewater Treatment No change - Not included in PSD

Contemporaneous Changes

M-00001 Permitting for Salt Fluxing N/A 8628 8628 

C-00001 Chip Dryer No 1 afterburner retrofit N/A 2170 13 304 124 

B1-1
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions

Emission Unit C-ARB01Carbon Plant

19

HTM Burner Natural Gas Usage, Process N02 Source 2006 2007 Avg 06-07 Pollutant North End (MCF) 41,908 7,344 24,626 Carbon Monoxide -The HTM Burner did not fire #6 fuel oil in the last five years. Sulfur Dioxide 

Particulate Matter Nitrogen Oxides 

Volatile Organic Compounds 

*PM-Filterable Particulate

Natural Gas Combustion Emissions, Process N02Natural Gas 2006 2007 North End (lb/yr)Carbon Monoxide 1,467 257 862Sulfur Dioxide 25 4 15Particulate Matter 587 103 345Nitrogen Oxides 4,191 734 2,463Volatile Organic Compounds 117 21 69Notes: 1. Maintenance included in North end.2. HTM burner included in North end.2006 Process Emissions 06-07 Avg Process Emissions

Process Description Part (lb/yr) VOC (lb/yr) Part (lb/yr) VOC (lb/yr)

N04 Coke silos 1,953 0 977 0N05 Coke handling 4,688 0 2,344 0N07 Paste Mixers 348 511 174 256N10 Pitch Storage/unloading 0 105 0 53

*Processes not operated in 2007

B1 - 2
Alcoa Massena Modernization Project

Table B-1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions

Emissions Unit E-WCST1 East Plant Cast House

Emission factors for HF and F2 were developed from stack testing data collected in July 1999, by Adirondack Environmental Services. Emission factors for HF and F2 were developed from stack testing data collected in July 1999, by Adironda

PM emission factors were obtained from the SMACT testing in the fall of 2002. Two scenarios were PM emission factors were obtained from the SMACT testing in the fall of 2002. Two scenarios weretested, as the furnace emissions are dependant on the amount of reactive flux used. Based on casthouse knowledge, tested, as the furnace emissions are dependant on the amount of reactive flux used. Based on casthouse knoit can be assumed that 90% of the time the furnace operates similar to the normal case scenario and 10% of time it would meet the it can be assumed that 90% of the time the furnace operates similar to the normal case scenario and 10% of 

worst case scenario. Furnace 4 emission factors were used because they are the most representative of normal and worst case operations. worst case scenario. Furnace 4 emission factors were used because they are the most representative of norm

2007 Emissions Calculations Pre-October 2007 2006 Emissions Calculations Pre-October 2006 

PM (90%) 0.1100 87,048.9 65,381.1 6,473 PM (90%) 0.1100 92,436.0 9,151PM (10%) 0.5100 87,048.9 65,381.1 3,334 PM (10%) 0.5100 92,436.0 4,714PM oily scrap 0.1100 87,048.9 183.1 20 Total PM 13,865Total PM 9,827 HF 0.0594 92,436.0 5,494.9HF 0.0594 87,048.9 5,175 F2 0.0066 92,436.0 610.2

F2 0.0066 87,048.9 575 TF 6,105.1

TF 5,749

2007 Emissions Calculations Oct - Dec 2007 

PM 0.0100 55,461.6 554.6SNIF production calculated by multiplying the casthouse

PM Oct.-Dec. 0.0980 87,048.9 21,484.5 2,105 production by 3/5 *Taken from Fall 2007 SMACT testing on furnace 4 (furnace 8 not tested)

2007 Production Summary Fuel Use Natural Gas

Source MMCF Natural GasEast Casthouse 163.1 Pollutant (lb/106 ft3) Pollutant West Cashouse 199.6 CO 84 CO Total 362.7 SO2 0.6 SO2 

NOx 100 NOx 

Jan - Oct. 2007 131128676 65564.338 130762473 65381.24 366203 183.10 NMTOC 5.5 NMTOC 

Oct. - Dec 2007 42969080 21484.54 42664166 21332.08 304914 152.462007 Totals: 174097756 87048.9 173426639 86713.3 671117 335.6

Pollutant 2006 2007 average TPY HMO Adj 

NOx 36,274 38,097 37,185 18.59 7,783.0 

SO2 218 229 223 0.11 46.7 

TF 6,105.1 5,749 5,927 2.96 0.0 

PM 14,420 12,455 13,438 6.72 2,558.0 

CO 30,470 32,001 31,236 15.62 6,537.7 

PM 0.0100 52,229.3 522.3 VOC 1,995 2,095 2,045 1.02 428.1 SNIF production calculated by multiplying the casthouseproduction by 3/5 

HMO Furnace

Fuel Use Natural Gas MMBTU/hr Rating 18Source MMCF Furnace 7&8 production: 9,423,884 lbs/mo avg (based on Jan 08 - Aug 08 productiEast Casthouse 186.4 Pollutant (lb/106 ft3) Pollutant (lbs) TPY 60% through HMO furnace: 5,654,331 lbs/mo avg

West Cashouse 194.6 CO 84 CO 32,001 16.00 200,000 lbs / firing: 28.27 firing/mo avg

Total 381.0 SO2 0.6 SO2 229 0.11 13 hrs / firing 367.53 hrs / mo

NOx 100 NOx 38,097 19.05 Full Fire 6,615.57 MMBTU/moNMTOC 5.5 NMTOC 2,095 1.05 6.49 MMCF/mo at 1,020 btu/cf

7,783.0 lbs NOx/yr 428.1 lbs NMTOC/yr6,537.7 lbs CO/yr 2,558.0 lbs PM 

46.7 lbs SO2/yr

*No TF emissions as ammonium fluoroborate is not used in the HMO furnace at the East Plant

Contaminant

Emission 

Factor* 

(lb/ton)

Aluminum 

Production 

(Tons/yr)

2006 Cast House Process Emission Calcul

Contaminant

Emission 

Factor (lb/ton)

Aluminum 

Production 

(Tons/yr)

Total 

Emissions 

(lb/yr)

Contaminant

SMACT 

Emission 

Aluminum Factor (lb/ton)

Production 

to Oct. 

Total 

Emissions 

(lb/yr)

Total 

Emissions 

(lb/yr)

Aluminum 

Production 

(Tons/yr)

Emission 

Factor 

(lb/ton)

Aluminum 

Production 

(Tons/yr)

Aluminum 

Production 

to Oct. 

Total 

Emissions 

(lb/yr)

Aluminum 

Production 

(Tons/yr)

Total 

Emissions 

(lb/yr)

2007 Cast House Process Emission Calculations 

Total 

Aluminum 

Production 

(lbs/yr) 

Total 

Aluminum 

Production 

(tons/yr) 

2006 Combustion Emissions

AP-42 Factors

Aluminum 

Production - 

Oily Scrap 

(tons/yr)

Contaminant

Homogenizing Furnace Adjustments

Natural Gas

Oily Scrap 

Charged 

through Fce 

(MT/yr)

Oily Scrap 

Charged 

through Fce 

(lbs/yr)

Aluminum 

Production - 

Oily Scrap 

(lbs/yr)

2007 Combustion Emissions

AP-42 Factors

SMACT 

Emission 

Factor 

Contaminant (lb/ton)

B1 - 3
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions

Emissions Unit P-DIG01East Plant Pot Digging

Pot Digging Baghouse Emissions Factor

0.096 lb/ton of material dug

06-07 Pot Digging Emissions

Year Spent Potliner (lb/yr) PM (lb/yr) PM10 (lb/yr) PM2.5 (lb/yr)

2006 4342 416.8 212.6 62.52007 5628 540.3 275.5 81.0

Average: 478.6 244.1 71.8

-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

B1 - 4
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions 

Emission Unit P-OT001, Process A02Old East Plant Soderberg Potline

Carbon Monoxide Emission Calculations

Carbon monoxide (CO) emissions are calculated differently from the other pollutants. CO generation is dependent upon the 

2006 Plant Production: 107,142.0 tons "current efficiency" of the reduction operations. Current efficiency (CE) is defined as the ratio of actual aluminum production

to theoretical production: 

CE = Actual Production / Theoretical Production

Theoretical production for a Soderberg facility is defined according to the following equation:

CO 402.900 N/A N/A 93% 0% 0% Theoretical Production = (17.752 lb/pot-day)(Amperage, kA)Nox-2008 Test Data 1.370 NA NA 93% 0% 0%*Mass Balance Thus, increases in aluminum production are driven by increases in current efficiency and operating amperage.

CO generation can be represented by the following chemical equation, which is referred to as the "back reaction":

lb/TAP lb/yr lb/TAP lb/yr lb/TAP lb/yr

*TF Emission Sum 0.029 3,107 2.33 249,641 2.36 252,748 2 Al + 3 CO2 ===> Al2O3 + 3 CO

HF Emission Sum 0.008 879 1.05 112,499 1.06 113,378**Part F Emission Sum 0.021 2,250 1.28 137,142 1.30 139,392 The back reaction is the major mechanism for the loss of aluminum production in reduction cells and it decreases the Filterable PM/Test Data 1.613 172,820 21.82 2,337,838 23.43 2,510,658 current efficiency of the reduction operations. Based on molecular weight ratios, 1.555 pounds of CO is produced per Filterable PM10(1) 100,236 724,730 824,966 pound of Al involved in the back reaction. PM2.5(w/ condensables)(2) 446,268 5.22 559,281 1,005,549

CO 374.697 40,145,777 28.20 3,021,725 402.90 43,167,502 The above information can be used to calculate CO emissions from actual production operations given the operating amperage 

Nox 1.274 136,510 0.096 10,275 1.37 146,785 in kiloamps, the production rate in pounds per pot-day, and the number of pots in operation. *TF Roof Monitor Emission Factor based on actual tested emissions, averaged monthly (When calculating the the average TF emission factor for 2006,  the PMACT TF limit of 2.4 lb/TAP was used for those months where the PMACT TF limit was exceeded and the tested actual TF emissions were  used for those months where the PMACT TF limit was met.)**Particulate F = TF - HFHF primary emissions based on fraction that was gaseous times the average 2004 total lb/ton calc for wet scrubber Input Data 2006 2007

(1)Calculated using AP-42 Table 12.1-2 (PM10: primary emissions = 58% of total PM and roof monitor emissions = 31% of total PM) Average Operating Amperage 88.91 91.36 kA(2)Calculated using AP-42 Table 12.1-2 and 2008 tested emissions (PM2.5: primary emissions = 40% of total PM + (condensables emission rate * TAP) Average Production 1,397 1,448 lb/pot-day

 and roof monitor emissions = PM2.5 (w cond.) 2008 tested emission rate * TAP Average Production 107,142 126,611 tons/yr

Equations Average # Pots in Operation 420 479For calculations based on Test Data:Primary Emissions = (Primary Emission Factor)(Production) CO Emission CalculationsRoof Monitor Emissions = (Secondary Emission Factor)(Production) Theoretical Production 1,578 1,622 lb/pot-day

Aluminum Lost in Back Reaction 181 173 lb/pot-day

For calculations based on other methods (Engr Report, Mass Balance, etc.): CO Generation 281 270 lb/pot-dayPrimary Emissions = (Generation Rate)(Production)(Capture Efficiency)(1 - Control Efficiency) CO Generation 402.900 372.497 lb/TAPRoof Monitor Emissions = (Generation Rate)(Production)(1 - Capture Efficiency) CO Emissions 43,167,502 47,162,179 lb/yr

PRIOR EAST PLANT POTLINE ACTUAL NOX EMISSIONS CALCULATIONYear

Total East 

Plant 

Emissions

Max (99 TPY 

Cap)

Delta (Max - 

Total)

Initial Potroom 

(1)

Final Potroom

for Analysis (2)

2006 (lb/yr) 223,609 198,000 -25,609 146,785 121,176

2007 Plant Production: 126,611.0 tons 2007 (lb/yr) 247,720 198,000 -49,720 173,457 123,737

06-07 avg (lb/yr) 235,665 198,000 -37,665 160,121 122,45706-07 avg (ton/yr) 118 99 -19 80 61

(1) Calculated using annual production and 2008 emission factor(2) Final Potroom emissions = Delta + (Initial potroom emissions)

CO 372.50 N/A N/A 93% 0% 0%Nox-2008 Test Data 1.370 NA NA 93% 0% 0%

*Mass Balance Massena East Roof Vent

East Plant 2008 

Tested Emission 

Rates

Contribution to 

Total PM w/ 

Condensables

(lb/ton Al)

Filter Total PM 10.42

lb/TAP lb/yr lb/TAP lb/yr lb/TAP lb/yr Filter PM10 Not tested

TF Emission Sum 0.015 1,899 1.98 250,690 2.00 252,589 Filter PM2.5 1.7

HF Emission Sum 0.004 484 0.72 91,160 0.72 91,644 Condensable 3.52 25.3%

*Part F Emission Sum 0.011 1,416 1.26 159,530 1.27 160,945 PM10 (w cond.) Not tested

Filterable PM/Test Data 0.731 92,553 18.29 2,315,715 19.02 2,408,268 PM2.5 (w cond.) 5.22 37.4%

Filterable PM10(1) 53,681 717,872 771,552

PM2.5(w/ condensables)(2) 482,692 5.22 660,909 1,143,601

CO 346.422 43,860,826 26.07 3,301,352 372.50 47,162,179 Pollutant / Info SourceNox 1.274 161,315 0.096 12,142 1.37 173,457 lb/TAP lb/yr

*Particulate F = TF - HF TF Emission Sum 2.18 252,668HF primary emissions based on fraction that was gaseous times the average 2007 total lb/ton calc for wet scrubber HF Emission Sum 0.89 102,511

(1)Calculated using AP-42 Table 12.1-2 (PM10: primary emissions = 58% of total PM and roof monitor emissions = 31% of total PM) *Part F Emission Sum 1.29 150,169(2)Calculated using AP-42 Table 12.1-2 and 2008 tested emissions (PM2.5: primary emissions = 40% of total PM + (condensables emission rate * TAP) PM w/ condensables/Test Data 21.23 2,870,868 -06-07 Avg. Filterable PM + (emission rate for condensables * 06-07 Avg. production)

 and roof monitor emissions = PM2.5 (w cond.) 2008 tested emission rate * TAP PM10 w/ condensables 1,209,664 -06-07 Avg. Filterable PM10 + (emission rate for condensables * 06-07 Avg. production)

Equations PM2.5 w/ condensables 1,074,575For calculations based on Test Data: CO 387.70 45,164,840Primary Emissions = (Primary Emission Factor)(Production) Nox 1.37 160,121 -Prior Actual NOx emissions calculated in table above by subtracting initial NOx calculatRoof Monitor Emissions = (Secondary Emission Factor)(Production) from the difference between the Total East Plant NOx emissions and the 99 TPY CapFor calculations based on other methods (Engr Report, Mass Balance, etc.):Primary Emissions = (Generation Rate)(Production)(Capture Efficiency)(1 - Control Efficiency)Roof Monitor Emissions = (Generation Rate)(Production)(1 - Capture Efficiency)

Roof Monitor 

Emission Factor 

(lb/TAP)

Overall 

Removal

2007 Potroom Emission Calculations - Primary and Roof Monitor Emissions

Overall 

Remova

Roof Monitor 

Emission Factor 

(lb/TAP)

06-07 Avg Total Emissions

(Primary + Secondary)

Pollutant / Info Source

Pollutant / Info Source

Control 

Efficiency

Generation Rate

(lb/TAP)

Capture 

Efficiency

Primary Emissions Total Emissions Roof Monitor Emissions

Primary Emission 

Factor (lb/TAP)

2006 Potroom Emission Calculations - Primary and Roof Monitor Emissions

Pollutant / Info SourcePollutant / Info Source

Control 

Efficiency

Generation Rate

(lb/TAP)

Capture 

Efficiency

Primary Emissions (Primary + Secondary) Roof Monitor Emissions

Primary Emission 

Factor (lb/TAP)

B1 - 5
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions 

Emission Unit P-OT001, Process A02Old East Plant Soderberg Potline

Sulfur Dioxide and Carbonyl Sulfide Generation Calculations

Mass Balance DerivationSulfur dioxide is emitted as a result of the oxidation of the sulfur contained in the anode paste. Anode paste is a mixture of petroleum coke and coal tar pitch. Typically, anode paste is 76% petroleum coke and 24% coal tar pitch. The conv

S + O2 ===> SO2

For the purposes of these emission calculations, it is assumed that 100% of the sulfur is converted to sulfur dioxide. Therefore the sulfur dioxide generation rate is as follows: (1 mol SO2 / 1 mol S)(1 mol S / 32.06 lb)(64.06 lb / mol SO 2) = 1.998 lb SO2 / lb S

Sulfur dioxide generation rates will be developed for a range of sulfur contents in both the petroleum coke and the coal tar pitch from previous years data and with our current maximum sulfur allowed in the coke and pitch specifications.Testing at various Alcoa Smelters has determined that 91.8% of the Sulfur in the paste will evolve off as SO2, with the remaining Sulfur forming COS. (1 mol COS/1 mol of S)(1 mol S/32.06 lb)(60.065 lb/ mol of COS) = 1.874 lb COS/lb SPrior Actual Emissions Summary Table

Year S022006 (lb/yr) 477,3572007 (lb/yr) 476,804Average (lb/yr) 477,080Average (ton/yr) 239

Parameter January February March Quarterly Total April May June Quarterly Total July August September

Quarterly 

Total October November December

Quarterly 

Total YTD 

Coke Content (% by wt) 73.10% 73.20% 72.40% 73.70% 73.80% 73.70% 73.70% 73.30% 73.40% 73.60% 73.60% 74.40% 73.49%

Coke Sulfur (by wt) 0.0236 0.0232 0.0225 0.0234 0.0239 0.0235 0.0234 0.0230 0.0234 0.0230 0.0239 0.0217 0.0232 

Pitch Content (% by wt) 26.90% 26.80% 27.60% 26.30% 26.20% 26.30% 26.30% 26.70% 26.60% 26.40% 26.40% 25.60% 26.51% 

Pitch Sulfur Content 

(by wt.) 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055 0.0055

S Generation Rate (lb 

S/lb paste) 0.0187 0.0185 0.0178 0.0187 0.0191 0.0188 0.0187 0.0183 0.0186 0.0184 0.0190 0.0176 0.0185

SO2 Generation (lb 

SO2/lb briquettes) 0.0344 0.0339 0.0327 0.0343 0.0350 0.0344 0.0343 0.0336 0.0342 0.0337 0.0349 0.0322 0.0340

Briquettes Poured (lbs) 12,121,628 11,028,454 11,027,298 34,177,380 9,647,478 11,277,730 12,498,777 33,423,985 9,359,781 10,258,083 9,192,535 28,810,399 11,776,133 8,826,593 10,544,066 31,146,792 127,558,5

Carbon Waste (lbs) 92,200 115,740 94,180 140,840 139,720 217,020 91,540 178,220 128,780 45,180 113,300 127,360 

Scrapped Anodes (lbs) 998,680 998,680 998,680 998,680 998,680 998,680 998,680 998,680 998,680 998,680 998,680 998,680 

Aluminum Production 

lbs 21,261,246 19,222,633 20,306,559 60,790,438 19,257,285 19,751,822 17,808,156 56,817,263 16,622,497 15,421,520 14,914,460 46,958,477 15,494,220 16,197,420 18,025,483 49,717,123 214,283,3

Aluminum Production 

Tons 10,631 9,611 10,153 30,395 9,629 9,876 8,904 28,409 8,311 7,711 7,457 23,479 7,747 8,099 9,013 24,859 107,14

SO2 Generation (lb 

SO2/Ton Al) 41.01 40.91 37.31 36.51 42.10 50.88 40.96 47.48 44.88 53.57 40.59 39.79 43.00

Pot Capture Efficiency 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93.0% 

Control Efficiency SO2 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96.3% 

Overall Control SO2 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 89.6% 

Primary Control (lb 

SO2/ton Al) 1.41 1.41 1.28 1.26 1.45 1.75 1.41 1.63 1.54 1.84 1.40 1.37 1.48

Primary Control (lb 

SO2) 15,003 13,530 13,035 12,096 14,309 15,589 11,713 12,599 11,515 14,280 11,311 12,341 157,32

Roof Vent (lb SO2/ton 

Al) 2.87 2.86 2.61 2.56 2.95 3.56 2.87 3.32 3.14 3.75 2.84 2.79 3.01

Roof Vent (lb SO2) 30,521 27,524 26,518 24,607 29,108 31,712 23,828 25,629 23,426 29,050 23,010 25,105 320,03

Total SO2 45,524 41,054 39,553 126,131 36,703 43,416 47,300 127,419 35,540 38,228 34,941 108,710 43,330 34,321 37,445 115,097 477,35

 East Plant - 2006 Sulfur Dioxide Emissions by Month

B1-6
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions 

Emission Unit P-OT001, Process A02Old East Plant Soderberg Potline

Parameter January February March Quarterly Total April May June Quarterly Total July August September

Quarterly 

Total October November December

Quarterly 

Total YTD 

Coke Content (% by wt) 73.63% 73.64% 73.64% 73.49% 72.81% 72.62% 72.59% 72.47% 72.67% 72.99% 72.81% 72.93% 73.02%

Coke Sulfur (by wt) 0.0231 0.0242 0.0238 0.0231 0.0231 0.0232 0.0195 0.0192 0.0203 0.0184 0.0179 0.0180 0.0212 

Pitch Content (% by wt) 26.37% 26.36% 26.36% 26.51% 27.19% 27.38% 27.41% 27.53% 27.33% 27.01% 27.19% 27.07% 26.98% 

Pitch Sulfur Content 

(by wt.) 0.0055 0.0063 0.0055 0.0049 0.0050 0.0053 0.0056 0.0055 0.0055 0.0055 0.0056 0.0057 0.0055

S Generation Rate (lb 

S/lb paste) 0.0185 0.0194 0.0190 0.0183 0.0182 0.0183 0.0157 0.0155 0.0163 0.0149 0.0145 0.0147 0.0169

SO2 Generation (lb 

SO2/lb briquettes) 0.0339 0.0357 0.0349 0.0336 0.0334 0.0335 0.0288 0.0283 0.0298 0.0274 0.0266 0.0269 0.0311

Briquettes Poured (lbs) 13,378,720 12,153,306 12,997,313 38,529,339 12,196,609 13,007,401 11,865,177 37,069,187 13,152,009 11,406,415 10,873,009 35,431,433 12,660,964 11,053,631 10,789,425 34,504,020 145,533,9

Carbon Waste (lbs) 176,080 76,140 170,900 93,900 42,600 124,820 0 138,520 85,400 92,780 139,240 0 

Aluminum Production 

lbs 19,187,030 17,344,949 19,993,260 56,525,239 19,657,062 21,424,464 20,991,443 62,072,969 22,424,349 22,646,008 22,004,094 67,074,451 22,610,120 22,076,746 22,863,328 67,550,194 253,222,8

Aluminum Production 

Tons 9,594 8,672 9,997 28,263 9,829 10,712 10,496 31,036 11,212 11,323 11,002 33,537 11,305 11,038 11,432 33,775 126,61

SO2 Generation (lb 

SO2/Ton Al) 47.74 50.22 45.77 41.89 40.64 38.17 33.81 28.81 29.64 30.84 26.92 25.44 36.66

Pot Capture Efficiency 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93% 93.0% 

Control Efficiency SO2 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96% 96.3% 

Overall Control SO2 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 90% 89.6% 

Primary Control (lb 

SO2/ton Al) 1.64 1.73 1.58 1.44 1.40 1.31 1.16 0.99 1.02 1.06 0.93 0.88 1.26

Primary Control (lb 

SO2) 15,760 14,986 15,745 14,167 14,979 13,785 13,043 11,225 11,221 11,997 10,225 10,005 157,13

Roof Vent (lb SO2/ton 

Al) 3.34 3.52 3.20 2.93 2.84 2.67 2.37 2.02 2.07 2.16 1.88 1.78 2.57

Roof Vent (lb SO2) 32,060 30,486 32,030 28,820 30,472 28,042 26,533 22,834 22,827 24,405 20,802 20,354 319,66

Total SO2 47,820 45,472 47,775 141,067 42,987 45,451 41,827 130,265 39,575 34,059 34,049 107,683 36,402 31,027 30,360 97,788 476,80

Pitch Sulfur Content for January and March 2007 was not available. In this case, used the average for 2007 for this value. Paste plant not functioning in 2007 - only briquettes used for anode production.

 East Plant - 2007 Sulfur Dioxide and Carbonyl Sulfide Emissions by Month

B1-7
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit P-OT001, Process B01 Pollutant NOx SO2 New East Plant Pre-Bake Potline (modeled after West Plant Pre-Bake Potline) lb/yr 95,864 414,53

Aluminum Production 160,040 tons/yr Fume Capture 98.5% COS Control 25.0% Process Weight Calculations - 2007

% Sulfur in Coke 2.5% SO2 Control 94.0% January February March April 

Potroom emission factors Metal Production 23,675,009 21,580,908 24,168,592 23,889,2Pollutant

Emission Factor Source Gross Carbon 0.539 0.541 0.553 0.546 

NOx 0.599 lb/ton Aluminum (June 2008 Method 7E Emission Test) Carbon Used 8,103 7,418 8,497 8,280 TF 1.15 lb/ton Aluminum (MACT Standard) Fluoride MT 167 179 164 173 Monitor condensables 0.298 lb/ton Aluminum (from Mt. Holly data on next page) Alumina MT 20,683 18,605 21,227 20,76Monitor PM 10 with condensables 0.329 lb/ton Aluminum (from Mt. Holly data on next page) Total Alumina 45,597,742 41,016,583 46,797,044 45,769,7Monitor PM 2.5 with condensables 0.316 lb/ton Aluminum (from Mt. Holly data on next page) Total Carbon 12,760,830 11,675,271 13,365,231 13,043,5A-398 condensables 0.202 lb/ton Aluminum (from Mt. Holly data on next page) Cover Material 1,823,175 1,669,050 1,911,825 1,863,0A-398 PM 10 with condensables 1.920 lb/ton Aluminum (from Mt. Holly data on next page) Soda ash lbs 15,825 13,950 14,725 5,600 

A-398 PM 2.5 with condensables 0.816 lb/ton Aluminum (from Mt. Holly data on next page) Fluoride lbs 368,168 394,623 361,554 381,39

Total Process Wt 60,565,740 54,769,478 62,450,380 61,063,2

Potroom Emissions Days 31 28 31 30 

(1)PM calculation PM10 calculation PM2.5 calculation Lbs/hr 81,406 81,502 83,939 84,81

607,772 lb PM w/ cond. 359,928 lb PM10 w/ cond. 181,131 lb PM2.5 w/ cond. Limit (lbs/hr) 46.8 46.8 47.8 48.1 

TF calculation Limit (lbs/ton) 2.94 2.92 2.94 2.90 

184,046 lb TF 

Emissions (lbs/ton) 2.05 1.32 1.48 1.26 

NOx calculation routine:

Emission Factor 0.599 lb/ton Carbon Monoxide Emission Calculationsthrough A-398's (98%) 94,426 lb/yrthrough monitor (2%) 1,438 lb/yr Carbon monoxide (CO) emissions are calculated differently from the ot

95,864 lb NOx "current efficiency" of the reduction operations. Current efficiency (CE) 

to theoretical production: 

CO calculation CE = Actual P

through A-398's (98%) 28,533,596 lb/yr Theoretical production for a Pre-Bake facility is defined according to the through monitor (2%) 434,522 lb/yr

Total CO: 28,968,118 lb CO Theoretical Product

(1)Total Particulate based on process weight emission limit scaled for increase in production from west plant to east plant and emission rates for condensables Thus, increases in aluminum production are driven by increases in curr

Process Data Units Value Rationale for Calculations CO generation can be represented by the following chemical equation, Aluminum Production lbs 320,080,340

Aluminum Production tons 160,040 assumed to be the maximum production based on process limiting factors upstream in the process 2 Al + 

%S in Baked Anodes % 2.30 % S in coke * (maximum ratio of anode sulfur to coke sulfur from 1974-2003, see below)

Pots Operating No. 208 Given The back reaction is the major mechanism for the loss of aluminum pro

Net Carbon lb carbon/lb Al 0.419 Highest averaging year for net carbon (2006) current efficiency of the reduction operations. Based on molecular weig

Ratio S converted to SO2 0.908 Given pound of Al involved in the back reaction. 

SO2 from carbon lb/ton 34.96 % S in baked anodes/100*2000*(MW Ratio S to SO2)*net carbon*%S converted to SO2

Total SO2: lb/ton 34.96 Total The above information can be used to calculate CO emissions from act

98.5% through A-398's (SO2) lb/yr 5,510,328 in kiloamps, the production rate in pounds per pot-day, and the number 

1.5% through monitor (SO2) lb/yr 83,914

SO2 Control through A-398's % 94 Given

COS control through A-398's % 25 Given Production: 160,040 tons

Total SO2: lb SO2 5,594,242 Al Production*Total SO2 (lb/ton) Current Efficiency: 0.945

Total Emitted SO2: lb SO2 414,533 Total SO2*(1-SO2 Control) Theoretical Production: 169,355 tons

Al lost in back reaction: 9,315 tons

18,629,014 lbs

1986* 1.97 1.81 0.92 Lbs CO 28,968,118 lbs

*1986 had the highest ratio of anode sulfur to  coke sulfur from 1974-2003.

YEAR % S in Coke % S in Anode

Ratio of Anode 

Sulfur to Coke 

Sulfur

B1 - 8
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Future Actual Fine Particulate Emission Rates 

Emission Unit P-OT001, Process B01New East Plant Pre-Bake Potline (modeled after West Plant Pre-Bake Potline)Sampling Location Pollutant Emission Rate Back-half % PM2.5 Front PM10 to PM2.5 TSP>PM10 PM10 Front TSP Back

Total Emission Rate w/ Condensables

Contribution to Total PM w/ Condensables

Total EmissiRate (Filteraonly)

Potroom Roof PM2.5 0.61 lb/ton Al 49% 4.7 4.5 0.61 52.6% 0.3

PM10 0.83 lb/ton Al 36% 3.3 8 4.5 0.83 71.6% 0.5Total PM 1.16 lb/ton Al 26% 5 13 4.5 1.16 --- 0.8

Dry Scrubber PM2.5 0.21 lb/ton Al 94% 1.2 18.4 0.21 77.8% 0.0

PM10 0.24 lb/ton Al 24% 2.3 3.5 18.4 0.24 88.9% 0.0Total PM 0.27 lb/ton Al 75% 2.7 6.2 18.4 0.27 --- 0.0

Mt Holly Data Mt Holly basis

Method 202

(lb/ton Al) (lb/ton Al)

Potroom Roof Filter Total PM 0.862 0.049 = process weight emission limit (2.93 lb/TAP) scaled for increase in production from west plant to east plant (1.13) * 1.

Filter PM10 0.531 0.030 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.312 0.018 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.298 0.298 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.829 0.329 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.610 0.316 = Filter PM2.5 + Condensables

Dry Scrubber Mt Holly Data Mt Holly basis

(lb/ton Al) (lb/ton Al)

Filter Total PM 0.068 3.248 = process weight emission limit (2.93 lb/TAP) scaled for increase in production from west plant to east plant (1.13) * 98

Filter PM10 0.036 1.718 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.013 0.614 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.202 0.202 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.238 1.920 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.215 0.816 = Filter PM2.5 + Condensables

Summary of Fine Particulate Results

B1-8A
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit P-OT001, Process ANO Pollutant Anode Butt Cooling lb/yr 

Description Production HF

Value (lb/yr)

Anode Butt Cooling (1) 208 2,220

(1)Maximum pots operating per day (pots = W):

W pots (16 pairs/24 days)* (289 gram/pair) * (2.2 lb/1000 gram) * (365 day/yr) = X = 32,180X * (1-Y) + X * Y * Z

Y = Capture Efficiency = 95%Z = Removal Efficiency = 98%

B1 - 9
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions Emission Unit 0-CRUCE, Process A03

Cruce Auger Emission Calculations

Particulate Matter EmissionsParticulate Matter Emission Factors

A search of AP-42 emission factors found no emission factors for augering of potroom bath material. In the absence of such a factor, a grinding and screening operation factor from Brick and Structural Clay Manufacturing was selectedto estimate the uncontrolled emssions of the cruce auger.Controlled emissions will be calculated using a tested emission factor from the Alcoa East Plant pot digging dust collector exThis dust collector (installed in the late 90's) controls emissions generated from materials similar to which the cruce auger pr

8.5 lb/ton material

0.0062 lb/ton material

0.096 lb/ton material

1,2Emission Factor taken from AP-42, Fifth Edition, Volume 1 Chapter 11: Mineral Products Industry, Section 11.3, Brick and Structural 

 Clay Product Manufacturing - Table 11.3-1. Particulate Matter Emission Factors for Brick Manufacturing Operations. Factors are based on inlet and outlet measurements of a fabric filter dust collector servicing grinding and screening operations 

 of brick raw materials.

3Emission factor obtained by stack testing on the outlet of the pot digging dust collector in March of 2000. This factor was selected

 over the controlled AP-42 factor as it is more representative of the cruce auger process than the controlled AP-42 Factor.

Process Assumptions and Specifications

350 lb Bath/cruce

1.5 cruces/hour

10,057 SCFM12,571 SCFM

Controlled PM Emission = (Bath Generation)(Controlled Emission Factor)(# of Cruces cleaned per hour)/2000

0.03 lb PM/hr

8,760 Estimated hours of use for controlled emissions 

221 lb PM/yr 113 lb PM10/yr 33 lb PM2.5/yr 

-Includes Lid Cleaning Emissions-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

Bath Generation (Engineering Study conducted in 1998)New design gas flow (with dust collector installed).Average # of Cruces Cleaned - Based on 30 to 36 cruces cleaned per 24 hoursExisting exhaust design gas flow.

Emission Factor Description of the Emission Factor

Process Parameter Description of the Parameter

Uncontrolled Grinding and Screening Operations Emission Factor processing dry material 1Controlled (fabric filter) Grinding and Screening Operations Emission Factor (Not Used) 2Controlled (modern fabric filter) Pot Digging dust collector East Plant 3

B1 - 10
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions

Emission Unit U-LDG01

Unloading Shed, Process P03 Ore Gallery, Process P01

Alumina, aluminum fluoride and petroleum coke are delivered to the Plant in rail cars that are offloaded Once the raw materials have entered the ore gallery, they are distributed to vin the Unloading Shed. The Unloading Shed is split into two sections - one for alumina and aluminum is fed to one of two 2,000-ton bulk storage silos (22D or 22E) and aluminum ffluoride and the other for petroleum coke. Alumina and aluminum fluoride are unloaded into a hopper, bulk storage silo (50A). Alumnia can be stored in any number of 2,500-ton butransferred up an elevator, and dropped onto the ore gallery conveyor. Each of these transfer points 50E, 50G, or 50H), but for the purposes of these calculations it will be assum(rail car to hopper, hopper to elevator, and elevator to conveyor) is controlled by baghouse. Petroleum to the 15,000-ton bulk storage silo (50R). Silo 50R feeds the dry alumina scrcoke is unloaded into a hopper, transferred up an elevator, and dropped onto the coke conveyor. Coke scrubber is stored in one of two 800-ton storage silos (50S or 50T). It will be unloading into the hopper from the rail car is uncontrolled and only generates fugitive emissions (which received was fed to the dry scrubber.are assumed to "fallout" within the unloading shed due to the buildings size and design). The other transfer points (hopper to elevator and elevator to conveyor) are controlled by a baghouse. Both baghouses are The following silos are equipped with baghouses to control particulate emissiassumed to 99% efficient in the removal of particulate emissions. 50A, 50F, 50G, 50H, 50R, 50S, and 50T. Those silos without baghouses are 

of fugitive emissions and will not be included in this analysis. Transfers from 

There is no site-specific emission data for this process. EPA's Compilation of Emission Factors (AP-42) will be assumed to negligible. provides particulate matter (PM) emission factors for Material Handling and Transfer in Section 11.24 Metallic Mineral Processing. The PM emission factors listed are 0.12 pounds PM per ton per transfer point for all minerals except alumina and bauxite, and 1.1 pounds PM per ton per transfer point for alumina andbauxite. These emission factors will be used to estimate PM emissions from the unloading operations for each raw material.2006-2007 Unloading Shed Emissions 2006-2007 Ore Gallery Emissions

Quantity Received Quantity Received PM Emission 2006 2007 Quantity Processed Quantity Processed PM Emission 

in 2006 in 2007 Factor Transfer Control PM Emissions PM Emissions in 2006 in 2007 Factor 

Raw Material (tons) (tons) (lb/ton-transfer) Points Efficiency (lbs) (lbs) Raw Material (tons) (tons) (lb/ton-transferAlumina 204,592 206,310 1.1 3 99% 6,752 6,808 Alumina 204,592 206,310 1.1 Aluminum Fluoride 1,543 1,008 0.12 3 99% 6 4 Aluminum Fluoride 1,543 1,008 0.12 Petroleum Coke* 16,278 0 0.12 2 99% 39 0 Petroleum Coke 16,278 0 0.12 Total 222,413 207,318 6,796 6,812 Enriched Ore 162,344 206,310 1.1 *No petroleum coke in 2007 due to 100% usage of briquettes. Total 384,757 413,628 Process PM10 PM2.5 P-225 Plant Production 160,040 tonsP01 14,306 7,296 2,146 Average Current East Plant Aluminum Production 124,059 tons

P03 6,804 3,470 1,021 Scaling Factor = 1.29-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

=Emissions linked to Summary Table

2006 and 2007 Average PM 

Emissions (lb/yr)

B1 - 11
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

U-LDG01 and 0-CRUCE units Pollutant PM PM10 PM2.5 Pollutant PEast Plant Material Handling U-LDG01 (lb/yr) 169,164 86,274 25,375 0-CRUCE (lb/yr) 99

Emission Potential Potential Potential Blower Permissible Permissible Perm

Unit Process ID Operation Operating Operating Design Outlet Emission Emi

(hr/day) (days/yr) (hr/yr) (dscfm) (gr/dscf) (lb/hr) (lb

P

U-LDG01 P04 24 365 8,760 5,000 0.05 2.14 

 

U-LDG01 P05 24 365 8,760 5,000 0.05 2.14 

 

U-LDG01 P06 24 365 8,760 5,000 0.05 2.14 

 

U-LDG01 P07 24 365 8,760 5,000 0.05 2.14 

 

U-LDG01 P08 24 365 8,760 4,100 0.05 1.76 

 

U-LDG01 P09 24 365 8,760 5,000 0.05 2.14 

 

U-LDG01 P10 24 365 8,760 5,000 0.05 2.14 

 

0 - CRUCE A03 24 365 8,760 14,000 0.05 6.00 

 

-Emissions for process P08 modeled after West Plant sources in Emission Unit S-00004-PM10/PM2.5 emissions based on AP-42 Factors from Appendix B.2 Category 3 of Table B.2.2 (15% PM 2.5 and 51% PM10)Emission Unit P-OT001, Process A03Existing Cruce Augering Operations Future Allowable Emissions

12570 scf 0.05 grains 60 min 8760 hr = 47,191 lbs PM

7000 grains

24,068 PM

Emission Unit U-LDG01 7,079 PM

Unloading Shed (P01) Ore Gallery (P03)Alumina, aluminum fluoride and petroleum coke are delivered to the Plant in rail cars that are offloaded Once the raw materials have entered the ore gallery, they are distributed to various bulk storagin the Unloading Shed. The Unloading Shed is split into two sections - one for alumina and aluminum is fed to one of two 2,000-ton bulk storage silos (22D or 22E) and aluminum fluoride is conveyefluoride and the other for petroleum coke. Alumina and aluminum fluoride are unloaded into a hopper, bulk storage silo (50A). Alumna can be stored in any number of 2,500-ton bulk storage silos (5transferred up an elevator, and dropped onto the ore gallery conveyor. Each of these transfer points 50E, 50G, or 50H), but for the purposes of these calculations it will be assumed that all fresh a(rail car to hopper, hopper to elevator, and elevator to conveyor) is controlled by baghouse. Petroleum to the 15,000-ton bulk storage silo (50R). Silo 50R feeds the dry alumina scrubber and enrichecoke is unloaded into a hopper, transferred up an elevator, and dropped onto the coke conveyor. Coke scrubber is stored in one of two 800-ton storage silos (50S or 50T). It will be assumed that 2/3 unloading into the hopper from the rail car is uncontrolled and only generates fugitive emissions (which received was fed to the dry scrubber.are assumed to "fallout" within the unloading shed due to the buildings size and design). The other transfer points (hopper to elevator and elevator to conveyor) are controlled by a baghouse. Both baghouses are The following silos are equipped with baghouses to control particulate emissions from the transassumed to 99% efficient in the removal of particulate emissions. 50A, 50F, 50G, 50H, 50R, 50S, and 50T. Those silos without baghouses are assumed to gene

of fugitive emissions and will not be included in this analysis. Transfers from the silos to the m

There is no site-specific emission data for this process. EPA's Compilation of Emission Factors (AP-42) will be assumed to negligible. provides particulate matter (PM) emission factors for Material Handling and Transfer in Section 11.24 Metallic Mineral Processing. The PM emission factors listed are 0.12 pounds PM per ton per transfer point for all minerals except alumina and bauxite, and 1.1 pounds PM per ton per transfer point for alumina andbauxite. These emission factors will be used to estimate PM emissions from the unloading operations for each raw material.Worst Case Unloading Shed Emissions from 2001-2007 Worst Case Unloading Shed Emissions from 2001-2007

Quantity Received PM Emission Quantity Processed PM Emission

in 2001 Factor Transfer Control PM Emissions in 2001 Factor Transfer Control PM Em

Raw Material (tons) (lb/ton-transfer) Points Efficiency (lbs) Raw Material (tons) (lb/ton-transfer) Points Efficiency (lAlumina 265,036 1.1 3 99% 8,746 Alumina 265,036 1.1 5 99% 14Aluminum Fluoride 2,660 0.12 3 99% 10 Aluminum Fluoride 2,660 0.12 1 99% Petroleum Coke 54,371 0.12 2 99% 130 Petroleum Coke 54,371 0.12 1 N/A 6,Total 322,067 8,886 Enriched Ore 176,691 1.1 1 99% 1,

Total 498,758 23

Process

Scaling 

Factor

PM 

Emissions 

(lb/yr)

PM10 

Emissions 

(lb/yr)

PM2.5 

Emissions 

(lb/yr) P-225 Plant Production 160,040 tons

P01 1.29 11,448 5,839 1,717 Average Current East Plant Aluminum Production 124,059 tons

P03 1.29 29,694 15,144 4,454 Scaling Factor = 1.29

-PM10/PM2.5 emissions based on AP-42 Factors from Appendix B.2 Category 3 of Table B.2.2 (15% PM 2.5 and 51% PM10)

=Emissions linked to Summary Table

23,048

8,886

Worst Case Emissions between 

2001 and 2007 (lb/yr)

lb

dscf hr yr yr

Bath Filling StationAlumina Filling StationBath StorageBath Filling StationTransfer Point for two alumina belt conveyors - fabric filterBath Filling Station

Description

New Cruce Cleaning - fabric filterBath Filling Station

B1 - 12
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit A-00001Furnaces to be romoved as part of the project (emissions used in the netting analysis)

Emission Factors

Existing Homogenizing Furnaces MMBTU/hr(1) MMCF/yr Fuel Type Heat Input NOx(1) VOC(2) SO2(2) 

#16 Homogenizing Heat Treat 30.0 262.8 (MMBtu/hr) lb/MM#17 Homogenizing Heat Treat 35.0 306.6 Natural Gas <100 100 5.5 0.6 #18 Homogenizing Heat Treat 33.6 294.3

(1)MMBTU values are based on Alcoa Information

(1) AP-42, Fifth Edition and Supplements (7/98), Table 1.4-1(2) AP-42, Fifth Edition & Supplements (7/98), Table 1.4-2,

 VOC as non-methane total organic compounds (NMTOC)

(3) Based on mass balance involving 0.76 lb HF/lb of NH4BF4 additive

MMBTU 8760 HR 1 MMCF = MMCFHR 1 YR 1000 MMBTU YR

16 Homo 18 Homo

Loads Time (hrs) % Utiliz'n Loads Time (hrs) % Utiliz'n Loads

2006 268 6515.9 74.6 469 8186.6 93.7 6052007 204 5481.5 62.7 438 7691.4 88 492

Existing Furnace POC Emissions NOx NMTOC(1) SO2 TF PM CO

#16

2006 (lb/yr) 19,605 1,078 118 49 1,490 16,468 =(MMCF/yr)*emission 2007 (lb/yr) 16,478 906 99 41 1,252 13,841 =(MMCF/yr)*emission 

#17 (Idle since 2002)

2006 (lb/yr) 0 0 0 0 0 02007 (lb/yr) 0 0 0 0 0 0

#18

2006 (lb/yr) 27,579 1,517 165 69 2,096 23,167 =(MMCF/yr)*emission 2007 (lb/yr) 25,902 1,425 155 65 1,969 21,757 =(MMCF/yr)*emission 

06-07 Avg (lb/yr) 44,782 2,463 269 112 3,403 37,617

06-07 Avg (ton/yr) 22 1 0 0 2 19

(1) NMTOC is calculated using VOC emission factor

HMO furnace utilization

B1 - 13
Alcoa Massena Moderization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit A-00003, Process HM1West Plant Homogenizing Furnaces

Existing Homogenizing Furnaces MMBTU/hr(1) MMCF/yr Pollutant NOx SO2 TF PM PM10/2.5 CO

#18 Homogenizing Heat Treat 33.6 288.6 105,120 866 10,950 25,404 25,404 121,197#19 Homogenizing Heat Treat 30.0 257.6 42,048 309 4,380 10,162 10,162 43,285

147,168 1,175 15,330 35,566 35,566 164,482

Future Furnaces MMBTU/hr(1) MMCF/yr#18 size furnaces 33.6 288.6#19 size furnaces 30.0 257.6Emission Factors(1)

HF 0.25 lb/hrBased on mass balance using on Aluminum Fluoroborate InputHMO Furnace #19 1999 application ERPs:PM 0.58 lb/hrNOx 2.4 lb/hrProcess Emissions hrs/yr lbs/yrHF 8760 2190.0Combustion Emissions #18 Size #19 Size Using 1999 ERPs #16 Size #17 SizeCO (lb/yr) 24,239 21,642 21,642 25,249SOx (lb/yr) 173 155 155 180PM (lb/yr) 2,193 1,958 1,958 2,284NOx (lb/yr) 14,428 12,882 25,765 30,0591998 AP-42 Emission Factors

CO SOx PM NOx

(lbs/MMCF) 84.0 0.6 7.6 50.0

MMBTU 8760 HR 1 MMCF = MMCF

HR 1 YR 1020 MMBTU YR

(1)MMBTU and HF emission values are based on Alcoa Information

West Plant Homogenizing Furnaces NOx SO2 TF PM PM10/2.5 COEmission Unit A-00003, Process HM1 81,570 600 15,330 19,713 19,713 83,969NOx emissions limitations

Total NOx emissions: 73.584 TPY

Desired NOx emissions: 40.785 TPY

0.08 lb 1020 MMBtu 0.0408 ton

2000 lb MMCF

40.785 ton 999.6 MMCF

0.0408 ton

Combustion Emissions Total Heat Input Required to Run all Furnaces: 228 MMBtu/hrCO (lb/yr) 83,969 NG required to run all furnaces at max heat input: 0.224 MMCF/hrSOx (lb/yr) 600 Hours of operation of all furnaces at max heat input: 4472.039 hrs/yrPM (lb/yr) 19,713 Percent heat input attainable for 8760 hr/yr operation: 51.1%NOx (lb/yr) 81,570

21,024

5,081

--

Two #19 Size (lb/yr)Five #18 Size (lb/yr)

Total (lb/yr)

Pollutant

Total (lb/yr)

=

MMBtu MMCF

ton

=

MMCF

yr yr

B1 - 14
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit A-00003, NOx SO2 PM PM10/2.5 COProcesses MH1 and FBB 47,235 567 58,400 58,400 79,355New Melting/Holding Furnaces at West Plant 19,324 232 17,520 17,520 32,464 with Gas Filterboxes 66,559 799 75,920 75,920 111,819

240,000 lb Unit 180,000 lb Unit 773 9 1,898 1,898 1,299

MMBTU/hr 55 45MMCF/yr 472.35 386.47Charge Size (lbs) 200,000 120,000Charges Per Day 2 2Days of Operation 365 365Daily Capacity (lbs) 400,000 240,000Annual Capacity (lbs) 146,000,000 87,600,000Annual Capacity (Tons) 73,000 43,800Filter Box MMBTU/hr 0.6 0.6Filter Box MMCF/yr 5.15 5.15Process EmissionsPM (lb/yr) Furnace 29,200 17,520

Filter Box 730 438

Combustion EmissionsCO (lb/yr) Furnace 39,678 32,464

Filter Box 433 433

SOx (lb/yr) Furnace 283 232

Filter Box 3 3

PM** (lb/yr) Furnace 3,590 2,937

Filter Box 39 39

NOx (lb/yr) Furnace 23,618 19,324

Filter Box 258 258

0.4 lb PM/ton of aluminum produced (permit allowable emission factor for furnaces)

0.01 lb PM/ton of aluminum produced (permit allowable emission factor for filter boxes)

1998 AP-42 Emission Factors CO SOx PM NOx(lbs/MMCF) 84.0 0.6 7.6 50.0

*NOx emission factor for low NOx burners

MMBTU 8760 HR 1 MMCF = MMCFHR 1 YR 1020 MMBTU YR

**PM emissions from the process include combustion emissions, therefore these emissions are not included in the summary

Pollutant NOx SO2 PM PM10/2.5 CO

Total (lb/hr) 48,000 576 7,296 7,296 80,640

Total NOx emissions: 33.28 TPY

Desired NOx emissions: 24 TPY

24 ton MMCF 960 MMCF

50.0 lb yr

Combustion Emissions Total Heat Input Required to Run all Furnaces: 155 MMBtu/hrCO (lb/yr) 80,640 NG required to run all furnaces at max heat input: 0.152 MMCF/hrSOx (lb/yr) 576 Hours of operation of all furnaces at max heat input: 6317.419 hrs/yrPM (lb/yr) 7,296 Percent heat input attainable for 8760 hr/yr operation: 72.1%NOx (lb/yr) 48,000

One 180K lb Unit

Two 240K lb Units

Pollutant (lb/yr)

Total MH1

=

yr

Three Filter Boxes

B1 - 15
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit B-00001West Plant Boilerhouse Emissions

Avg Fuel Usage (06-07) Yearly Units MMBTU

Natural Gas 573.186 106 ft3 584,650

Propane 0 1000 gallons 0No. 2 Fuel Oil 0 1000 gallons 0No. 6 Fuel Oil 635.39 1000 gallons 95,309Natural Gas assumes - 1,020 Btu/cfNo.6 Fuel Oil assumes - 150,000 Btu/gal

Natural Gas Propane No. 2 Fuel Oil No. 6 Fuel Oil Natural Gas Natural Gas 

Pollutant (lb/106 ft3) (lb/ 1000 gal) (lb/ 1000 gal) (lb/ 1000 gal) Pollutant (lb/MMbtu) (lb/MMcf) 

Carbon Monoxide 7.14 19 5 2.0 Carbon Monoxide 0.007 7.14 

Sulfur Dioxide 0.6 0.018 71 236 Nitrogen Oxides 0.08 81.6 

Particulate Matter 7.6 0.4 2 9.6 Particulate Matter 

Nitrogen Oxides 81.6 14 20 40.5 Natural Gas assumes - 1,020 Btu/cfVolatile Organic Compounds 5.5 0.5 0.2 0.76 No.6 Fuel Oil assumes - 150,000 Btu/galEmission Factors in red are based on 2006 boiler test data and the rest are 1998 AP-42 emission factors

Yearly Emissions

Yearly

Natural Gas Propane No. 2 Fuel Oil No. 6 Fuel Oil Total

Pollutant (lbs) (lbs) (lbs) (lbs) (lbs)Carbon Monoxide 4,093 0 0 1,239 5,332Sulfur Dioxide 344 0 0 149,634 149,978Particulate Matter 4,356 0 0 6,100 10,456Nitrogen Oxides 46,772 0 0 25,733 72,505Volatile Organic Compounds 3,153 0 0 483 3,635

Fuel Emission Factors 2006 Boiler Teste

Emissions by Fuel Type

B1 - 16
Alcoa Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit B-00001 Pollutant NOx SO2 West Plant Boilerhouse Emissions lb/yr 327,158 495,811 

18.03% increase in MMBTU annual demand due to carbon plant production doubling

Percentage increase calculated by scaling double the 2007 total carbon plant steam usage (16%) by the potline scaling factor (1.13)

Max Fuel Usage (03-07) Yearly Units MMBTU MMBTU

MMCF or 1000 gal P-225 Plan

Natural Gas 681.7 106 ft3 695,300 125,384 125.4 Average West Plant Aluminum 

No. 6 Fuel Oil 1782.2 1000 gallons 267,334 48,208 321.4 Sca

Natural Gas assumes - 1,020 Btu/cfNo.6 Fuel Oil assumes - 150,000 Btu/gal

Natural Gas Natural Gas No. 6 Fuel Oil No. 6 Fuel Oil

Pollutant (lb/MMbtu) (lb/MMcf) (lb/MMBtu) (lb/ 1000 gal)Carbon Monoxide 0.007 7.14 0.013 2.0

Nitrogen Oxides 0.08 81.6 0.27 41Particulate Matter 0.064 10NOx 0.3 306 0.3 45

PM 0.1 15Natural Gas assumes - 1,020 Btu/cfNo.6 Fuel Oil assumes - 150,000 Btu/gal

Natural Gas No. 6 Fuel Oil

Pollutant (lb/106 ft3) (lb/ 1000 gal)

Carbon Monoxide 7.14 2.0Sulfur Dioxide 0.6 236Particulate Matter 7.6 9.6Nitrogen Oxides 306 45.0Emission Factors in red are based on 2006 boiler test data and the rest are 1998 AP-42 emission factors

Emission Factors in blue are based on Permit emission limitsYearly Emissions

Yearly

Natural Gas No. 6 Fuel Oil Natural Gas No. 6 Fuel Oil Worst Case Total

Pollutant (lbs) (lbs) (lbs) (lbs) (lbs) (lbs)Carbon Monoxide 4,867 3,475 895 627 895 9,238Sulfur Dioxide 409 419,715 75 75,687 75,687 495,811Particulate Matter 5,181 17,109 953 3,085 3,085 25,375Nitrogen Oxides 208,590 80,200 38,367 14,463 38,367 327,158

Additional Emissions

2006 Boiler Tested Emission Factors

Emissions by Fuel Type

Fuel Emission Factors

Permit Emission Limits

B1 - 17
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Demand Growth Emissions 

Emission Unit B-00001West Plant Boilerhouse Emissions

Max Heat Demand (2003) Yearly* Units MMBTU

Natural Gas 1996.107 106 ft3 2,036,030

Propane 0 1000 gallons 0No. 2 Fuel Oil 0 1000 gallons 0No. 6 Fuel Oil 13573.53 1000 gallons 2,036,030Natural Gas assumes - 1,020 Btu/cfNo.6 Fuel Oil assumes - 150,000 Btu/gal*assuming entire heat demand supplied by one fuel type

Natural Gas Propane No. 2 Fuel Oil No. 6 Fuel Oil Natural Gas Natural Gas 

Pollutant (lb/106 ft3) (lb/ 1000 gal) (lb/ 1000 gal) (lb/ 1000 gal) Pollutant (lb/MMbtu) (lb/MMcf) 

Carbon Monoxide 7.14 19 5 2.0 Carbon Monoxide 0.007 7.14 Sulfur Dioxide 0.6 0.018 71 236 Nitrogen Oxides 0.08 81.6 Particulate Matter 7.6 0.4 2 9.6 Particulate Matter Nitrogen Oxides 81.6 14 20 40.5 Natural Gas assumes - 1,020 Btu/cfEmission Factors in orange are based on 2006 boiler test data and the rest are 1998 AP-42 emission factors No.6 Fuel Oil assumes - 150,000 Btu/gal

Yearly Emissions

Natural Gas Propane No. 2 Fuel Oil No. 6 Fuel Oil

Pollutant (lbs) (lbs) (lbs) (lbs)Carbon Monoxide 14,252 0 0 26,468Sulfur Dioxide 1,198 0 0 3,196,566Particulate Matter 15,170 0 0 130,306Nitrogen Oxides 162,882 0 0 549,728*No. 6 fuel oil supplying entire heat demand provides the greatest emissions per pollutant

Fuel Emission Factors 2006 Boiler Test

Emissions by Fuel Type

B1 - 18
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 2006-2007 Prior Actual Emissions 

Emission Unit D-00001, Process SKDSkim and Dross Passive Cooling

Source Process Description PM PM

ID (lb/hr) (hr/yr) (lb/yr)

Skim and Dross

DI116 SKD Skim and Dross (SKD): 0.3690 8,760 3,232

Skim/Dross Exhaust 1994 Stack Testing Results

lb/hr

Particulate 0.0015 gr/dscf 0.3690

B1 - 19
Alcoa Massena Moderization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit D-00001, Process SKD Pollutant PM Skim and Dross Passive Cooling lb/yr 7402 

=Max PM Emissions * sc

3232 lb/yr All emissions are fugitive

MHS Furnaces

Current UtilizationFurnaces listed in Assumptions: 294,190,000 =avg TPY (03-07)*2000 lb/tonNew Furnace Capacity(2) 240,000 lb units = 292,000,000 lbs per year180,000 lb unit = 87,600,000 lbs per year

379,600,000 lbs per year Total

Scaling FactorCurrent production: 294,190,000 lbs per yearTotal Future Capacity: 673,790,000 lbs per year =current production + new furnace capacity

Scaling Factor: 2.290

Annual Production from existing furnaces (14, 15, 5M, 6M, 32, and 33)

2007 2006 2005 2004 2003

176,055 138,251 139,030 141,717 140,422 TPY

AVG 147,095 TPY

*Assumptions: Three new furnaces are being installed, two 240,000 lb units and one 180,000 lb unit

240,000 lb units can handle two charges of 200,000 lbs per day180,000 lb units can handle two charges of 120,000 lbs per dayassume 100% utilization of new furnaces(see Melter Holder Furnaces and Filter Box Emissions for further info)Current utilization based on average production from furnaces 14, 15, 5M, 6M, 32, and 33 for 2003 through 

Max PM Emissions (2001-2007)

B1 - 20
Alcoa Massena East Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline 

Carbon Monoxide Emission Calculations

06-07 Avg Aluminum Production 141,998 tons/yr Fume Capture 98.0%

Carbon monoxide (CO) emissions are calculated differently from the other pollu

Tested Emissions "current efficiency" of the reduction operations. Current efficiency (CE) is defin

2006 2007 Avg 06-07 to theoretical production: 

A-398 Total-Fluoride 0.040 0.047 0.044 lb/ton Aluminum CMonitor Total-Fluoride 0.650 0.880 0.765 lb/ton AluminumPotline Total-Fluoride 0.690 0.927 0.809 lb/ton Aluminum Theoretical production for a Pre-Bake facility is defined according to the followi

 Part F - Roof 0.250 0.360 0.305 lb/ton AluminumPart F - A-398 0.019 0.027 0.023 lb/ton Calculated value TheoreA-398 Filterable Particulate 0.612 0.310 0.461 lb/ton AluminumMonitor Filterable Particulate 1.620 1.810 1.715 lb/ton Aluminum Thus, increases in aluminum production are driven by increases in current effic Total Filterable Particulate 2.232 2.120 2.176 lb/ton Aluminum

-emission factors are given in red CO generation can be represented by the following chemical equation, which is 

Potroom emission factors Pollutant

Emission 

Factor Source 

NOx 0.599 lb/ton Aluminum (June 2008 Method 7E Emission Test)

Monitor condensables 0.298 lb/ton Aluminum (from Mt. Holly data on next page)

Monitor PM 10 with condensables 1.355 lb/ton Aluminum (from Mt. Holly data on next page)

Monitor PM 2.5 with condensables 0.918 lb/ton Aluminum (from Mt. Holly data on next page)

A-398 condensables 0.202 lb/ton Aluminum (from Mt. Holly data on next page)

A-398 PM 10 with condensables 0.446 lb/ton Aluminum (from Mt. Holly data on next page) The back reaction is the major mechanism for the loss of aluminum production 

A-398 PM 2.5 with condensables 0.289 lb/ton Aluminum (from Mt. Holly data on next page) current efficiency of the reduction operations. Based on molecular weight ratio

pound of Al involved in the back reaction. 

06-07 Avg Potroom Emissions

PM calculation The above information can be used to calculate CO emissions from actual prod

380,019 lb PM w/ cond. 255,784 lb PM10 w/ cond. 171,469 lb PM2.5 w/ cond. in kiloamps, the production rate in pounds per pot-day, and the number of pots 

TF calculation

114,805 lb TF Input Data 2006 2007 

Average Operating Amperage 238.22 240.12 

NOx calculation routine: Average Production 3977 4016 

Emission Factor 0.599 lb/ton Average Production 141371 142624 

through A-398's 83,355 lb/yr Average # Pots in Operation 194.77 198 through monitor 1,701 lb/yr

85,057 lb NOx CO Emission Calculations

Theoretical Production 4,229 4,263 

CO calculation Aluminum Lost in Back Reaction 252 247 

CO Generation 391 384 

through A-398's 26,981,493 lb/yr CO Generation 197 190.99 through monitor 550,643 lb/yr CO Emissions 27,824,582 27,239,688 

Total CO: 27,532,135 lb CO

B1 - 21
Alcoa Massena East Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Fine Particulate Emission Rates

Sampling Location Pollutant Emission Rate Back-half % PM2.5 Front PM10 to PM2.5 TSP>PM10 PM10 Front TSP Back

Total Emission Rate w/ Condensables

Contribution to Total PM w/ Condensables

Total Emission Rate (Filterable only)

Cto F

Potroom Roof PM2.5 0.61 lb/ton Al 49% 4.7 4.5 0.61 52.6% 0.31 

PM10 0.83 lb/ton Al 36% 3.3 8 4.5 0.83 71.6% 0.53 Total PM 1.16 lb/ton Al 26% 5 13 4.5 1.16 --- 0.86

Dry Scrubber PM2.5 0.21 lb/ton Al 94% 1.2 18.4 0.21 77.8% 0.01 

PM10 0.24 lb/ton Al 24% 2.3 3.5 18.4 0.24 88.9% 0.04 Total PM 0.27 lb/ton Al 75% 2.7 6.2 18.4 0.27 --- 0.07

Mt Holly Data Mt Holly basis

Method 202

(lb/ton Al) (lb/ton Al)

Potroom Roof Filter Total PM 0.862 1.715 = 06-07 Avg. PM emission rate

Filter PM10 0.531 1.057 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.312 0.620 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.298 0.298 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.829 1.355 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.610 0.918 = Filter PM2.5 + Condensables

Dry Scrubber Mt Holly Data Mt Holly basis

(lb/ton Al) (lb/ton Al)

B1 - 21A
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline

Prior Actual Emissions Summary TableYear S022006 (lb/yr) 4,890,6412007 (lb/yr) 4,803,189Average (lb/yr) 4,846,915Average (ton/yr) 2,423

Process Data Units January February March April May June July August September October November December YTD Pro

Aluminum Production lbs 23,837,260 21,776,505 24,168,424 23,177,620 23,910,767 23,166,122 23,757,780 23,747,632 23,313,273 24,331,724 23,319,230 24,235,688 282,742,025 AluAluminum Production tons 11,919 10,888 12,084 11,589 11,955 11,583 11,879 11,874 11,657 12,166 11,660 12,118 141,371 Alu

Green Anode Production MT 6,984 6,027 6,426 6,438 7,445 6,217 5,636 6,448 5,505 6,191 6,731 6,024 76,072 GreGreen Anode Production tons 7,699 6,644 7,083 7,097 8,207 6,853 6,213 7,108 6,068 6,824 7,420 6,640 83,855 GreBaked Anode Production MT 6,423 5,526 6,392 6,393 6,642 6,294 6,445 7,448 6,030 5,977 5,787 5,977 75,334 BaBaked Anode Production tons 7,080 6,091 7,046 7,047 7,322 6,938 7,104 8,210 6,647 6,589 6,379 6,589 83,041 Ba%S in Baked Anodes % 2.34 2.43 2.24 2.02 2.25 2.16 2.08 2.08 2.08 2.35 2.31 2.21 2.21 %S 

%S in Reacted Alumina % 0.302 0.274 0.261 0.251 0.260 0.313 0.264 0.311 0.332 0.332 0.358 0.359 0.301 %S 

Pots Operating No. 192.6 195.0 195.9 194.4 195.2 194.9 194.5 194.8 194.9 196.5 194.5 194.0 194.771 Pot

Net Carbon lb carbon/lb Al 0.421 0.418 0.419 0.417 0.421 0.421 0.418 0.415 0.420 0.420 0.425 0.418 0.419 Net 

Al2O3 Feed Rate ton/hr 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.200 Al2% S converted to SO2 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 % S SO2 from carbon lb/ton 35.78 36.89 34.09 30.59 34.40 33.03 31.58 31.35 31.73 35.85 35.66 33.55 33.708 SO

SO2 from Al2O3 lb/ton 0.905 0.812 0.771 0.749 0.777 0.934 0.768 0.935 0.984 0.975 1.061 1.058 0.894 SO

Total SO2: lb/ton 36.69 37.70 34.86 31.34 35.18 33.96 32.35 32.29 32.71 36.82 36.72 34.61 34.603 Tot

98% through A-398's lb/yr 428,492 402,314 412,828 355,956 412,188 385,514 376,551 375,700 373,703 439,017 419,559 411,007 4,792,829 98% 2% through monitor lb/yr 8,745 8,210 8,425 7,264 8,412 7,868 7,685 7,667 7,627 8,960 8,562 8,388 97,813 2% Total SO2: lb SO2 437,237 410,524 421,253 363,220 420,600 393,382 384,236 383,367 381,329 447,976 428,121 419,395 4,890,641 Tot

2006 ALCOA MASSENA WEST PLANT POTLINE- SULFUR DIOXIDE EMISSIONS BY MONTH

B1 - 22
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline

Process Data Units January February March April May June July August September October November December YTD Pro

Aluminum Production lbs 23,675,009 21,580,608 24,168,592 23,889,200 24,444,425 23,442,332 24,202,097 24,263,108 23,628,742 24,268,206 23,460,642 24,225,349 285,248,310 AluAluminum Production tons 11,838 10,790 12,084 11,945 12,222 11,721 12,101 12,132 11,814 12,134 11,730 12,113 142,624 Alu

Green Anode Production MT 6,728 5,359 7,575 6,364 6,953 6,539 6,788 5,531 5,417 6,646 7,099 6,727 77,726 GreGreen Anode Production tons 7,416 5,907 8,350 7,015 7,664 7,208 7,482 6,097 5,971 7,326 7,825 7,415 85,678 GreBaked Anode Production MT 6,519 5,883 6,516 6,312 6,497 6,321 6,541 5,898 5,770 5,962 6,298 6,656 75,173 BaBaked Anode Production tons 7,186 6,485 7,183 6,958 7,162 6,968 7,210 6,501 6,360 6,572 6,942 7,337 82,864 Ba%S in Baked Anodes % 2.03 2.20 2.09 2.08 2.27 2.17 2.30 2.06 1.98 2.34 2.56 2.00 2.17 %S 

%S in Reacted Alumina % 0.319 0.337 0.338 0.294 0.318 0.333 0.320 0.294 0.305 0.316 0.320 0.309 0.317 %S 

Pots Operating No. 190.5 192.8 196.1 197.5 197.0 195.5 193.8 195.0 196.1 194.4 193.0 194.5 194.658 Pot

Net Carbon lb carbon/lb Al 0.418 0.418 0.416 0.414 0.416 0.416 0.418 0.417 0.414 0.414 0.411 0.419 0.416 Net 

Al2O3 Feed Rate ton/hr 1.2 1.2 1.2 1.2 1.2 1.2 1.0 1.0 1.0 1.0 1.0 1.0 1.100 Al2% S converted to SO2 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 % S SO2 from carbon lb/ton 30.82 33.40 31.58 31.28 34.30 32.79 34.92 31.20 29.77 35.19 38.21 30.44 32.824 SO

SO2 from Al2O3 lb/ton 0.962 1.007 0.999 0.879 0.929 1.015 0.762 0.721 0.744 0.775 0.786 0.759 0.861 SO

Total SO2: lb/ton 31.78 34.41 32.58 32.15 35.23 33.80 35.68 31.92 30.52 35.96 39.00 31.20 33.685 Tot

98% through A-398's lb/yr 368,688 363,840 385,796 376,396 421,939 388,268 423,126 379,504 353,314 427,620 448,334 370,302 4,707,126 98% 2% through monitor lb/yr 7,524 7,425 7,873 7,682 8,611 7,924 8,635 7,745 7,210 8,727 9,150 7,557 96,064 2% Total SO2: lb SO2 376,212 371,265 393,669 384,077 430,550 396,192 431,761 387,249 360,524 436,347 457,484 377,859 4,803,189 Tot

2007 ALCOA MASSENA WEST PLANT POTLINE- SULFUR DIOXIDE EMISSIONS BY MONTH

B1 - 23
Alcoa Massena Modnization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit S-00001 Pollutant NOx West Plant Pre-Bake Potline lb/yr 89,430 

Aluminum Production 149,298 tons/yr Fume Capture 98.0% Process Weight Calculations - 2007

% Sulfur in Coke 2.5% SO2 Control 0.0% January February March 

West Plant Potroom Emission Factors Metal Production 23,675,009 21,580,908 24,168,592 Pollutant

Emission 

Factor Gross Carbon 0.539 0.541 0.553 

NOx 0.599 lb/ton Aluminum (June 2008 Method 7E Emission Test) Carbon Used 8,103 7,418 8,497 TF 1.18 lb/ton Aluminum (Permit Limit) Fluoride MT 167 179 164 Monitor condensables 0.298 lb/ton Aluminum (from Mt. Holly data on next page) Alumina MT 20,683 18,605 21,227 Monitor PM 10 with condensables 0.339 lb/ton Aluminum (from Mt. Holly data on next page) Total Alumina 45,597,742 41,016,583 46,797,044 Monitor PM 2.5 with condensables 0.322 lb/ton Aluminum (from Mt. Holly data on next page) Total Carbon 12,760,830 11,675,271 13,365,231 A-398 condensables 0.202 lb/ton Aluminum (from Mt. Holly data on next page) Cover Material 1,823,175 1,669,050 1,911,825 A-398 PM 10 with condensables 1.911 lb/ton Aluminum (from Mt. Holly data on next page) Soda ash lbs 15,825 13,950 14,725 A-398 PM 2.5 with condensables 0.812 lb/ton Aluminum (from Mt. Holly data on next page) Fluoride lbs 368,168 394,623 361,554 

Total Process Wt 60,565,740 54,769,478 62,450,380 

Potroom Emissions Days 31 28 31 

(1)PM calculation PM10 calculation PM2.5 calculation Lbs/hr 81,406 81,502 83,939 

511,478 lb PM w/ cond. 335,984 lb PM10 w/ cond. 169,399 lb PM2.5 w/ cond. Limit (lbs/hr) 46.8 46.8 47.8 

TF calculation Limit (lbs/ton) 2.94 2.92 2.94 

176,172 lb TF 

Emissions (lbs/ton) 2.05 1.32 1.48 

NOx calculation routine:

Emission Factor 0.599 lb/ton Carbon Monoxide Emission Calculationsthrough A-398's (98%) 87,641 lb/yrthrough monitor (2%) 1,789 lb/yr Carbon monoxide (CO) emissions are calculated differently from the other pollutants

89,430 lb NOx "current efficiency" of the reduction operations. Current efficiency (CE) is defined as 

to theoretical production: 

CO calculation CE 

through A-398's (98%) 26,483,279 lb/yr Theoretical production for a Pre-Bake facility is defined according to the following eqthrough monitor (2%) 540,475 lb/yr

Total CO: 27,023,754 lb CO Theoret

(1)Total Particulate based on process weight emission limit and emission rates of condensables through the roof monitor and the control device Thus, increases in aluminum production are driven by increases in current efficiency 

Process Data Units Rationale for Calculations CO generation can be represented by the following chemical equation, which is refer

Aluminum Production lbs 298,596,292

Aluminum Production tons 149,298 assumed to be the maximum production based on process limiting factors upstream in the process 

%S in Baked Anodes % 2.30 % S in coke * (maximum ratio of anode sulfur to coke sulfur from 1974-2003, see below)

%S in Reacted Alumina % 0.317 2007 average The back reaction is the major mechanism for the loss of aluminum production in redPots Operating No. 198 Given by design current efficiency of the reduction operations. Based on molecular weight ratios, 1.5Net Carbon lb carbon/lb Al 0.419 Highest averaging year for net carbon (2006) pound of Al involved in the back reaction. Al2O3 Feed Rate ton/hr 2.4 double 2007 feed rateRatio S converted to SO2 0.908 GivenSO2 from carbon lb/ton 34.96 % S in baked anodes/100*2000*(MW Ratio S to SO2)*net carbon*%S converted to SO2 The above information can be used to calculate CO emissions from actual productioSO2 from Al2O3 lb/ton 0.152 uses %S in Reacted Aluminum and Al2O3 Feed Rate in kiloamps, the production rate in pounds per pot-day, and the number of pots in opeTotal SO2: lb/ton 35.11 Total98% through A-398's (SO2) lb/yr 5,136,565 Production: 149,298 

2% through monitor (SO2) lb/yr 104,828

SO2 Control through A-398's % 0 Given

Total SO2: lb SO2 5,241,393 Al Production*Total SO2 (lb/ton) Current Efficiency: 0.945Total Emitted SO2: lb SO2 5,241,393 Total SO2*(1-SO2 Control)

YEAR % S in Coke % S in Anode Theoretical Production: 157,987 

1986* 1.97 1.81 0.92

*1986 had the highest ratio of anode sulfur to  coke sulfur from 1974-2003. Al lost in back reaction: 8,689 

17,378,620 

Lbs CO 27,023,754 

Sulfur to Coke 

Sulfur

B1 - 24
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Future Actual Fine Particulate Emission Rates 

Emission Unit S-00001West Plant Pre-Bake Potline 

Sampling Location Pollutant Emission Rate Back-half % PM2.5 Front PM10 to PM2.5 TSP>PM10 PM10 Front TSP Back

Total Emission Rate w/ Condensables

Contribution to Total PM w/ Condensables

Total EmissiRate (Filteraonly)

Potroom Roof PM2.5 0.61 lb/ton Al 49% 4.7 4.5 0.61 52.6% 0.3

PM10 0.83 lb/ton Al 36% 3.3 8 4.5 0.83 71.6% 0.5Total PM 1.16 lb/ton Al 26% 5 13 4.5 1.16 --- 0.8

Dry Scrubber PM2.5 0.21 lb/ton Al 94% 1.2 18.4 0.21 77.8% 0.0

PM10 0.24 lb/ton Al 24% 2.3 3.5 18.4 0.24 88.9% 0.0Total PM 0.27 lb/ton Al 75% 2.7 6.2 18.4 0.27 --- 0.0

Mt Holly Data Mt Holly basis

Method 202

(lb/ton Al) (lb/ton Al)

Potroom Roof Filter Total PM 0.862 0.066 = process weight emission limit (2.93 lb/TAP) * 2% through roof monitor

Filter PM10 0.531 0.041 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.312 0.024 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.298 0.298 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.829 0.339 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.610 0.322 = Filter PM2.5 + Condensables

Dry Scrubber Mt Holly Data Mt Holly basis

(lb/ton Al) (lb/ton Al)

Filter Total PM 0.068 3.231 = process weight emission limit (2.93 lb/TAP) * 98% through control deviceFilter PM10 0.036 1.710 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.013 0.611 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.202 0.202 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.238 1.911 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.215 0.812 = Filter PM2.5 + Condensables

Summary of Fine Particulate Results

B1 - 24A
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Demand Growth Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline 

Carbon Monoxide Emission Calculations

Aluminum Production Capacity 144,321 tons/yr Fume Capture 98.0%

Carbon monoxide (CO) emissions are calculated differently from the other pollu

Tested Emissions "current efficiency" of the reduction operations. Current efficiency (CE) is define

2006 2007 Max 06-07 to theoretical production: 

A-398 Total-Fluoride 0.040 0.047 0.047 lb/ton Aluminum CE Monitor Total-Fluoride 0.650 0.880 0.880 lb/ton AluminumPotline Total-Fluoride 0.690 0.927 0.927 lb/ton Aluminum Theoretical production for a Pre-Bake facility is defined according to the followin

 Part F - Roof 0.250 0.360 0.360 lb/ton AluminumPart F - A-398 0.019 0.027 0.027 lb/ton Calculated value TheoretA-398 Filterable Particulate 0.612 0.310 0.612 lb/ton AluminumMonitor Filterable Particulate 1.620 1.810 1.810 lb/ton Aluminum Thus, increases in aluminum production are driven by increases in current effici Total Filterable Particulate(1) 2.232 2.120 2.232 lb/ton Aluminum

(1)Total Filterable Particulate = 398 Filterable Particulate + Monitor Filterable Particulate

-emission factors are given in orange CO generation can be represented by the following chemical equation, which is 

Potroom emission factors Pollutant

Emission 

Factor Source 

NOx 0.599 lb/ton Aluminum (June 2008 Method 7E Emission Test)

Monitor condensables 0.298 lb/ton Aluminum (from Mt. Holly data on next page)

Monitor PM 10 with condensables 1.414 lb/ton Aluminum (from Mt. Holly data on next page)

Monitor PM 2.5 with condensables 0.953 lb/ton Aluminum (from Mt. Holly data on next page)

A-398 condensables 0.202 lb/ton Aluminum (from Mt. Holly data on next page)

A-398 PM 10 with condensables 0.526 lb/ton Aluminum (from Mt. Holly data on next page) The back reaction is the major mechanism for the loss of aluminum production A-398 PM 2.5 with condensables 0.318 lb/ton Aluminum (from Mt. Holly data on next page) current efficiency of the reduction operations. Based on molecular weight ratios

pound of Al involved in the back reaction. 

06-07 Avg Potroom Emissions

PM calculation PM10 calculation PM2.5 calculation The above information can be used to calculate CO emissions from actual prod

394,319 lb PM w/ cond. 279,950 lb PM10 w/ cond. 183,351 lb PM2.5 w/ cond. in kiloamps, the production rate in pounds per pot-day, and the number of pots 

TF calculation

133,786 lb TF Input Data Maximum (2003-2007)*

Average Operating Amperage 240 kA

NOx calculation routine: Average Production 3,994 lb/pot-day

Emission Factor 0.599 lb/ton Average Production 144,321 tons/yr

through A-398's 84,719 lb/yr Average # Pots in Operation 198

through monitor 1,729 lb/yr

86,448 lb NOx CO Emission Calculations

Theoretical Production 4,349 lb/pot-day

CO calculation Aluminum Lost in Back Reaction 355 lb/pot-day

CO Generation 552 lb/pot-day

through A-398's 39,130,056 lb/yr CO Generation 276.67 lb/TAP

through monitor 798,573 lb/yr CO Emissions 39,928,629 lb/yr

Total CO: 39,928,629 lb CO *Maximum values were taken from 2007

B1 - 25
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Demand Growth Fine Particulate Emission Rates 

Sampling Location Pollutant Emission Rate Back-half % PM2.5 Front PM10 to PM2.5 TSP>PM10 PM10 Front TSP Back

Total Emission Rate w/ Condensables

Contribution to Total PM w/ Condensables

Total Emission Rate (Filterable only)

Cto F

Potroom Roof PM2.5 0.61 lb/ton Al 49% 4.7 4.5 0.61 52.6% 0.31 

PM10 0.83 lb/ton Al 36% 3.3 8 4.5 0.83 71.6% 0.53 Total PM 1.16 lb/ton Al 26% 5 13 4.5 1.16 --- 0.86

Dry Scrubber PM2.5 0.21 lb/ton Al 94% 1.2 18.4 0.21 77.8% 0.01 

PM10 0.24 lb/ton Al 24% 2.3 3.5 18.4 0.24 88.9% 0.04 Total PM 0.27 lb/ton Al 75% 2.7 6.2 18.4 0.27 --- 0.07

Mt Holly Data Mt Holly basis

Method 202

(lb/ton Al) (lb/ton Al)

Potroom Roof Filter Total PM 0.862 1.810 = 06-07 Max PM emission rate

Filter PM10 0.531 1.116 = Filter Total PM * % Contribution to Total Filterable PMFilter PM2.5 0.312 0.655 = Filter Total PM * % Contribution to Total Filterable PMCondensable 0.298 0.298 = Total PM Back-half % * Total Emission Rate w CondensablesPM10 (w cond.) 0.829 1.414 = Filter PM10 + CondensablesPM2.5 (w cond.) 0.610 0.953 = Filter PM2.5 + Condensables

Dry Scrubber Mt Holly Data Mt Holly basis

(lb/ton Al) (lb/ton Al)

B1 - 25A
Alcoa Massena Modernization Project

Table B1 - PSD Applicabilty Supporting Calculations

Demand Growth Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline

Prior Actual Emissions Summary TableYear S022006 (lb/yr) 5,182,9622007 (lb/yr) 5,136,937Average (lb/yr) 5,159,949Average (ton/yr) 2,580

Process Data Units January February March April May June July August September October November December YTD Pro

Aluminum Production lbs 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 288,642,000 Alu

Aluminum Production tons 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 144,321 Alu

Green Anode Production MT 6,984 6,027 6,426 6,438 7,445 6,217 5,636 6,448 5,505 6,191 6,731 6,024 76,072 Gre

Green Anode Production tons 7,699 6,644 7,083 7,097 8,207 6,853 6,213 7,108 6,068 6,824 7,420 6,640 83,855 GreBaked Anode Production MT 6,423 5,526 6,392 6,393 6,642 6,294 6,445 7,448 6,030 5,977 5,787 5,977 75,334 BaBaked Anode Production tons 7,080 6,091 7,046 7,047 7,322 6,938 7,104 8,210 6,647 6,589 6,379 6,589 83,041 Ba%S in Baked Anodes % 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 %S 

%S in Reacted Alumina % 0.302 0.274 0.261 0.251 0.260 0.313 0.264 0.311 0.332 0.332 0.358 0.359 0.301 %S 

Pots Operating No. 192.6 195.0 195.9 194.4 195.2 194.9 194.5 194.8 194.9 196.5 194.5 194.0 194.771 Pot

Net Carbon lb carbon/lb Al 0.421 0.418 0.419 0.417 0.421 0.421 0.418 0.415 0.420 0.420 0.425 0.418 0.419 Net 

Al2O3 Feed Rate ton/hr 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.200 Al2% S converted to SO2 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 % S SO2 from carbon lb/ton 35.17 34.92 35.00 34.83 35.17 35.17 34.92 34.67 35.09 35.09 35.50 34.92 35.036 SO

SO2 from Al2O3 lb/ton 0.897 0.735 0.775 0.721 0.772 0.899 0.759 0.923 0.954 0.986 1.029 1.066 0.876 SO

Total SO2: lb/ton 36.07 35.65 35.78 35.56 35.94 36.07 35.68 35.59 36.04 36.07 36.53 35.98 35.913 Tot

98% through A-398's lb/yr 425,075 420,213 421,671 419,068 423,605 425,106 420,493 419,482 424,765 425,140 430,569 424,116 5,079,302 98% 2% through monitor lb/yr 8,675 8,576 8,606 8,552 8,645 8,676 8,581 8,561 8,669 8,676 8,787 8,655 103,659 2% Total SO2: lb SO2 433,750 428,789 430,276 427,621 432,250 433,782 429,074 428,043 433,434 433,816 439,356 432,771 5,182,962 Tot

2006 ALCOA MASSENA WEST PLANT POTLINE- SULFUR DIOXIDE EMISSIONS BY MONTH

B1 - 26
Alcoa Massena Modernization Project

Table B1 - PSD Applicabilty Supporting Calculations

Demand Growth Emissions 

Emission Unit S-00001West Plant Pre-Bake Potline

Process Data Units January February March April May June July August September October November December YTD Pro

Aluminum Production lbs 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 24,053,500 288,642,000 Alu

Aluminum Production tons 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 12,027 144,321 Alu

Green Anode Production MT 6,728 5,359 7,575 6,364 6,953 6,539 6,788 5,531 5,417 6,646 7,099 6,727 77,726 Gre

Green Anode Production tons 7,416 5,907 8,350 7,015 7,664 7,208 7,482 6,097 5,971 7,326 7,825 7,415 85,678 GreBaked Anode Production MT 6,519 5,883 6,516 6,312 6,497 6,321 6,541 5,898 5,770 5,962 6,298 6,656 75,173 BaBaked Anode Production tons 7,186 6,485 7,183 6,958 7,162 6,968 7,210 6,501 6,360 6,572 6,942 7,337 82,864 Ba%S in Baked Anodes % 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 2.30 %S 

%S in Reacted Alumina % 0.319 0.337 0.338 0.294 0.318 0.333 0.320 0.294 0.305 0.316 0.320 0.309 0.317 %S 

Pots Operating No. 190.5 192.8 196.1 197.5 197.0 195.5 193.8 195.0 196.1 194.4 193.0 194.5 194.658 Pot

Net Carbon lb carbon/lb Al 0.418 0.418 0.416 0.414 0.416 0.416 0.418 0.417 0.414 0.414 0.411 0.419 0.416 Net 

Al2O3 Feed Rate ton/hr 1.2 1.2 1.2 1.2 1.2 1.2 1.0 1.0 1.0 1.0 1.0 1.0 1.100 Al2% S converted to SO2 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 0.908 % S SO2 from carbon lb/ton 34.92 34.92 34.75 34.58 34.75 34.75 34.92 34.83 34.58 34.58 34.33 35.00 34.744 SO

SO2 from Al2O3 lb/ton 0.947 0.904 1.004 0.873 0.944 0.989 0.766 0.727 0.730 0.782 0.766 0.765 0.850 SO

Total SO2: lb/ton 35.87 35.82 35.75 35.46 35.70 35.74 35.68 35.56 35.31 35.37 35.10 35.77 35.594 Tot

98% through A-398's lb/yr 422,716 422,204 421,412 417,903 420,712 421,237 420,583 419,141 416,222 416,829 413,691 421,548 5,034,199 98% 2% through monitor lb/yr 8,627 8,616 8,600 8,529 8,586 8,597 8,583 8,554 8,494 8,507 8,443 8,603 102,739 2% Total SO2: lb SO2 431,343 430,821 430,012 426,431 429,298 429,833 429,167 427,695 424,716 425,336 422,134 430,151 5,136,937 Tot

2007 ALCOA MASSENA WEST PLANT POTLINE- SULFUR DIOXIDE EMISSIONS BY MONTH

B1 - 27
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit S-00002Anode Baking Furnace

Process Data06-07 Avg Green Anode Production 84,767 ton/yr06-07 Avg Baked Anode Production 82,954 ton/yrBaking Furnace Emission Data

Tested Emissions

2006 2007 06-07 Avg

Total Fluoride 0.017 0.002 0.010 lb/ton Green CarbonTotal Particulate 0.453 0.042 0.248 lb/ton (green carbon)POMS 0.060 0.030 0.045 lb/ton (green carbon)Particulate Fluoride 0.003 0.0003 0.002 lb/ton (green carbon)

Emission Factors

SO2 5.100 5.100 5.100 *lb/ton Baked Carbon

VOC 0.190 0.190 0.190 lb/ton Baked CarbonCO 2.190 2.190 2.190 lb/ton Baked Carbon (Based on June 2008 metNOx 20.380 20.380 20.380 lb/hr (new emission factor obtained w/Innovathe

*Baking Furnace lb SO2/ton - In 1997 two data points were collected from testing, 4.6 and 5.1 lb/ton Baked Carbon  To be conservative, the 5.1 lb SO2/ton Baked Carbon will be used.Based on Table B.2.2 Category 9 the PM2.5 fraction is 78% and the PM10 fraction is 94%

06-07 Avg Baking Furnace Emissions

PM calculation PM10 PM2.5

20,980 lbs PM 19,721 16,364

TF calculation

805 lbs TF

SO2 calculation

423,063 lb SO2

CO calculation

181,668 lb CO

NOx calculation

178,529 lb NOx

VOC calculation

15,761 lb NOx

B1 - 28
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit S-00002Anode Baking Furnace

Projected Future West Plant Green Anode Production

Max West Plant Green Anode Production between 2003-2007 85,678 tons (2007)

Projected Future West Plant Green Anode Production 182,243 tons

Scaling Factor 2.13

182,243 tons/yr Green 178,345 Tons/yr Baked

3% S in Coke Annual Average

S-00002 Emission FactorsTF 0.1 lb/ton Green Carbon (One Half of the MACT Standard)SO2 5.100 lb/ton Baked Carbon (1997 Emissions Testing)

CO 2.596 lb/ton Baked Carbon (June 2008 Method 10 Testing + 10% to accommodate worst-case emissions)NOx 2.277 lb/ton Baked Carbon (June 2008 Method 7E testing + 10% to accommodate worst-case emissions)S-00002 Anode baking furnace PM emission factors

Test # Date PM (lb/hr)

PM (lb/ton of Green Carbon Produced)

1 9/21/2003 2.03 0.2432 9/21/2003 2.3 0.2763 9/22/2003 2.35 0.2811 9/13/2004 1.73 0.2372 9/13/2004 1.21 0.1653 9/14/2004 1.35 0.1861 10/20/2005 1.09 0.1122 10/20/2005 0.43 0.0443 10/21/2005 0.64 0.0651 9/11/2006 12.06 1.2362 9/15/2006 1.04 0.1073 9/15/2006 0.16 0.0161 10/1/2007 0.43 0.0462 10/1/2007 0.39 0.0423 10/1/2007 0.37 0.039

AVERAGE 1.1815 0.142MAX 2.35 0.281=outlier (not used in average or max)

PM 51,210 lbs/yr -used max PM emission factor to remain conservativePM10 48,138 lbs/yr Based on AP-42 Table B.2.2 Category 9 the PM2.5 fraction is 78% andPM2.5 39,944 lbs/yr the PM10 fraction is 94%TF 18,224 lbs/yrSO2 909,558 lbs/yr

CO 462,983 lbs/yrNOx 406,091 lbs/yr

Projected Anode Baking Furnace Emissions

*Assume 98% conversion of green anode to baked anode based on 2006/2007 data

B1 - 29
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Demand Growth Emissions Emission Unit S-00002

Anode Baking Furnace

Process DataGreen Anode Production Capacity 182,243 ton/yrBaked Anode Production Capacity 178,344 ton/yrBaking Furnace Emission Data

Tested Emissions

2006 2007 06-07 Avg

Total Fluoride 0.017 0.002 0.010 lb/ton Green CarbonTotal Particulate 0.453 0.042 0.248 lb/ton (green carbon)POMS 0.060 0.030 0.045 lb/ton (green carbon)Particulate Fluoride 0.003 0.0003 0.002 lb/ton (green carbon)

Emission Factors

SO2 5.100 5.100 5.100 *lb/ton Baked Carbon

CO 2.190 2.190 2.190 lb/ton Baked Carbon NOx 2.260 2.260 2.260 lb/ton Baked Carbon (new emis

obtained w/Innovatherm startup 

*Baking Furnace lb SO2/ton - In 1997 two data points were collected from testing, 4.6 and 5.1 lb/ton Baked Carbon  To be conservative, the 5.1 lb SO2/ton Baked Carbon will be used.Based on AP-42 Table B.2.2 Category 9 the PM2.5 fraction is 78% and the PM10 fraction is 94%

Maximum Capacity Baking Furnace Emissions

PM calculation PM10 PM2.5

45,105 lbs PM 42,399 35,182

TF calculation

1,731 lbs TF

SO2 calculation

909,556 lb SO2

CO calculation

390,574 lb CO

NOx calculation

403,058 lb NOx

B1 - 30
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Units S-00003Green Mill

PM(2) PM VOC 

Unit Source Description

ID ID (lb/ton) (lb/hr) (hr/yr) (lb/yr) (lb/ton) (lb/hr

S-00003 SS099 Green Mill(1) 0.0157 1,331 0.0231 

GRAND TOTAL: 1,331 

(1)06-07 AverageAnnual Green Anode Production was 84,767 tons carbon(2)Emission factor based on Method 5 emission testing

B1 - 31
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit S-00003Green Mill

Projected Future West Plant Green Anode Production

182,243 tons/yr

PM(2) PM

Description

(lb/ton) (lb/yr)

Green Mill(1) 0.0157 2,861

GRAND TOTAL: 2,861

(1)Projected Annual Green Anode Production is 182,243 tons carbon(2) Emission factor based on Method 5 Emission Testing

1.333333 scaling factor for Green Mill emissions factors based on the addition of a fourth paste m

PM 0.0209 lb/ton Green Carbon

Rationale for Calculations

PM 3,815 lbs/yr Green Anode Production*scaled emission factor

Scaled S-00003 Green Mill (Paste Production Plant w/ Coke 

Scrubber) Emission Factors

Projected Actual Green Mill (Paste Production 

Plant w/ Coke Scrubber) Emissions

B1 - 32
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

 Demand Growth Emissions 

Emission Units S-00003Green Mill

PM(2) PM

Unit Source Description

ID ID (lb/ton) (lb/hr) (hr/yr) (lb/yr

S-00003 SS099 Green Mill(1) 0.0157 2,912

GRAND TOTAL: 2,912

(1)Annual Green Anode Production Capacity is 185,497 tons carbon(2)Emission factor based on Method 5 emission testing

ton/yr hr/yr ton/hr ton/y

2005 83125 4041 20.57 180,192006 83855 3960 21.18 185,492007 85678 4321 19.83 173,69

B1 - 33
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

2006-2007 Prior Actual Emissions 

Emission Unit S-00004SMELTING MATERIAL HANDLING

Source Description ERP ERP Baghouse Actual Actual Actual PTE 

ID Process ID Building (lb/hr) (lb/yr) Efficiency Operation Operating Operating Emissio

(hr/day) (days/yr) (hr/yr) (lb/hr) 

S0015 Stub Hole Cleaner - fabric filter M01 332 3.30 28,908 95% 6 260 1,560 0.17 

S0016 Induction Furnaces - fabric filter M01 332 36.70 321,492 98% 6 260 1,560 0.73 

S0017 Anthracite Coal Handling - fabric filter M01 332 48.00 Removed

TOTAL 88.00 0.90

S0083 Flash Welder - fabric filter M02 344 RemovedS0095 Stub Hole Drilling - fabric filter M03 351 12.50 95% 8 260 2,080 109,500 0.63 

S0090 Dry Scrubber Alumina - fabric filter M04 378 37.10 98% 8 365 2,920 324,996 0.40 

S023B Rough Cleaning - fabric filter M05 380 330.00 99.5% 12 208 2,496 2,890,800 1.65 

S23AA Bath Crushing/Storage - fabric filter M06 435 528.00 4,625,280 99.5% 20 365 7,300 2.64 

S23AC Cruce Cleaning - fabric filter M06 435 75.60 662,256 99.5% 6 365 2,190 0.38 

TOTAL 603.60 3.02

S0038 Butt Crushing - fabric filter M08 354B 34.00 98% 10 208 2,080 297,840 0.68 

S0049 Butt Storage (Butt Conveyor for An) - fabric filter M09 354C 35.00 306,600 98% 10 208 2,080 0.70 

S0050 Storage Filling - fabric filter M09 354C 72.00 630,720 98% 15 173 2,595 1.20 

S0051 Aggregate Blending - fabric filter M09 354C 87.00 762,120 98% 15 173 2,595 2.90 

S0052 Coke Crushing - fabric filter M09 354C 96.00 840,960 98% 15 173 2,595 1.92 

S0053 Storage Discharge - fabric filter M09 354C 72.00 630,720 98% 15 173 2,595 1.20 

S0060 Ball Mill Classifier - fabric filter M09 354C 46.00 402,960 98% 15 173 2,595 0.92 

S0061 Intermediate Classifier - fabric filter M09 354C 18.20 159,432 98% 15 173 2,595 0.36 

TOTAL 426.20 9.20

S0102 Spent Potlining Handling M16 469 89.10 98% 0 260 170 780,516 1.78 

GRAND TOTALS 1,620.5 18.3 

-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

B1 - 34
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Projected Future Actual/Allowable Emissions

Emission Unit S-00004WEST PLANT MATERIAL HANDLING

Method A Method B 

Description ERP ERP Baghouse Projected Projected Projected Emission Projected Flow Projected Emission P

Process ID Building (lb/hr) (lb/yr) Efficiency Operation Operating Operating Rate Emission Design Outlet Rate 

(hr/day) (days/yr) (hr/yr) (lb/hr) (lb/yr) (dscfm) (gr/dscf) (lb/hr) 

Stub Hole Cleaner - fabric filter M01 332 3.30 28,908 95% 24 365 8,760 0.17 1,445 1,200 0.017 0.17 

Induction Furnaces - fabric filter M01 332 36.70 321,492 98% 24 365 8,760 0.73 6,430 16,500 0.017 2.40 

Stub Hole Drilling - fabric filter M03 351 12.50 109,500 95% 24 365 8,760 0.63 5,475 9,400 0.017 1.37 Dry Scrubber Alumina - fabric filter M04 378 37.10 324,996 98% 24 365 8,760 0.40 3,504 3,250 0.017 0.47 

Rough Cleaning - fabric filter M05 380 330.00 2,890,800 99.5% 24 365 8,760 1.65 14,454 50,000 0.017 7.29 

Bath Crushing/Storage - fabric filter M06 435 528.00 4,625,280 99.5% 24 365 8,760 2.64 23,126 110,000 0.017 16.03 

Cruce Cleaning - fabric filter M06 435 75.60 662,256 99.5% 24 365 8,760 0.38 3,311 14,000 0.017 2.04 

Butt Crushing - fabric filter M08 354B 34.00 297,840 98% 24 365 8,760 0.68 5,957 38,150 0.017 5.56 

Butt Storage (Butt Conveyor for An) - fabric filter M09 354C 35.00 306,600 98% 24 365 8,760 0.70 6,132 2,700 0.017 0.39 Storage Filling - fabric filter M09 354C 72.00 630,720 98% 24 365 8,760 1.20 10,512 2,700 0.017 0.39 

Aggregate Blending - fabric filter M09 354C 87.00 762,120 98% 24 365 8,760 2.90 25,404 2,100 0.017 0.31 

Coke Crushing - fabric filter M09 354C 96.00 840,960 98% 24 365 8,760 1.92 16,819 9,800 0.017 1.43 

Storage Discharge - fabric filter M09 354C 72.00 630,720 98% 24 365 8,760 1.20 10,512 5,400 0.017 0.79 

Ball Mill Classifier - fabric filter M09 354C 46.00 402,960 98% 24 365 8,760 0.92 8,059 3,200 0.017 0.47 

Intermediate Classifier - fabric filter M09 354C 18.20 159,432 98% 24 365 8,760 0.36 3,189 1,000 0.017 0.15 

Spent Potlining Handling M16 469 89.10 780,516 98% 24 365 8,760 1.78 15,610 49,500 0.017 7.21 

Total 

-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

B1 - 35
Alcoa Massena Modernization Project

Table B1 - PSD Applicability Supporting Calculations

Demand Growth Emissions 

Emission Unit S-00004SMELTING MATERIAL HANDLING

Source Description ERP ERP Baghouse Actual Actual Actual PTE 

ID Process ID Building (lb/hr) (lb/yr) Efficiency Operation Operating Operating Emissio

(hr/day) (days/yr) (hr/yr) (lb/hr) 

S0015 Stub Hole Cleaner - fabric filter M01 332 3.30 28,908 95% 6 365 0.17 

2,190 

S0016 Induction Furnaces - fabric filter M01 332 36.70 321,492 98% 6 365 0.73 

2,190 

S0017 Anthracite Coal Handling - fabric filter M01 332 48.00 Removed

TOTAL 88.00 0.90

S0083 Flash Welder - fabric filter M02 344 RemovedS0095 Stub Hole Drilling - fabric filter M03 351 12.50 109,500 95% 8 365 0.63 

2,920 

S0090 Dry Scrubber Alumina - fabric filter M04 378 37.10 324,996 98% 8 365 0.40 

2,920 

S023B Rough Cleaning - fabric filter M05 380 330.00 2,890,800 99.5% 12 365 1.65 

4,380 

S23AA Bath Crushing/Storage - fabric filter M06 435 528.00 4,625,280 99.5% 20 365 2.64 

7,300 

S23AC Cruce Cleaning - fabric filter M06 435 75.60 662,256 99.5% 6 365 0.38 

2,190 

TOTAL 603.60 3.02

S0038 Butt Crushing - fabric filter M08 354B 34.00 297,840 98% 10 365 0.68 

3,650 

S0049 Butt Storage (Butt Conveyor for An) - fabric filter M09 354C 35.00 306,600 98% 10 365 0.70 

3,650 

S0050 Storage Filling - fabric filter M09 354C 72.00 630,720 98% 15 365 1.20 

5,475 

S0051 Aggregate Blending - fabric filter M09 354C 87.00 762,120 98% 15 365 2.90 

5,475 

S0052 Coke Crushing - fabric filter M09 354C 96.00 840,960 98% 15 365 1.92 

5,475 

S0053 Storage Discharge - fabric filter M09 354C 72.00 630,720 98% 15 365 1.20 

5,475 

S0060 Ball Mill Classifier - fabric filter M09 354C 46.00 402,960 98% 15 365 0.92 

5,475 

S0061 Intermediate Classifier - fabric filter M09 354C 18.20 159,432 98% 15 365 0.36 

5,475 

TOTAL 426.20 9.20

S0102 Spent Potlining Handling M16 469 89.10 780,516 98% 0.493 365 180 1.78 

GRAND TOTALS 1,620.5 18.3 

-PM10/2.5 calculated from AP-42 Appendix B.2 Table B.2.2 emission factors (51% PM10, 15% PM2.5)

B1 - 36
Alcoa Massena Modernization Project

Table 1 - PSD Applicability Supporting Calculations

Contemporaneous Increases

Salt Fluxing of Existing MHA furnaces at West Plant Cast HouseCombustion Emissions Process Emissions IncreasesNo increase in PM 4.3 TPYutilization is expected, * Based on Tested Factorstherefore combustion of salt fluxing versus no fluxingemissions will notchange.Chip Dryer #1 Afterburner Retrofit

177 MMCF Previous Maxim

Combustion Emissions Process Emissions 198 MMCF Future Maximum NOx 1.09 TPY PM 0.152 TPY

PM10 0.1 TPY THC** - TPY Pollutant AP-42 Factor SO2 0.01 TPY CO** - TPY lb/MMCF lb* Based on AP-42 Factors * Based on Tested Factors PM-10 5.7 12

** CO/VOC emissions were significantly NOx 100 217decreased as part of a compliance SO2 0.6 13issue, therefore not included in analysis

B1 - 37
APPENDIX C – NON-ATTAINMENT NSR APPLIC

SUPPORTING CALCULATION
Alcoa Massena Modernization Project

Table C1 - Part 231-2 MAP Analysis Summary

Part of Source 

Project?

Emission Unit*

NOX 

(tons/yr)

VOC + COS 

(tons/yr)

NOX 

(tons/yr)

VOC + COS 

(tons/yr)

Yes or No NOX 

(tons/yr)

VOC + COS 

(tons/yr)

P-OT001 47.9 240.3 92.9 333.3 No 61.2 251.6 

A-00001 65.4 14.1 109.4 16.5 NoA-00003 84.4 6.7 0.0 0.0 Yes 0.0 0.0 B-00001 756.9 19.3 756.9 19.3 NoS-00001 44.7 247.9 44.7 247.9 NoS-00002 203.0 18.6 203.0 18.6 NoS-00003 2.8 2.1 Yes 0.0 1.0 

S-00005 3.9 3.9 No

1,260 321 1,220 316 0.0 1.0 

Significant Source Project = PEP > Significance Threshold

*Only the emission units that emit NOX, VOC, or COS and are affected by the modernization project are listed in this analysis

Significance Threshold = 

East Plant

West Plant Total

West Plant

Future MAP = Prior MAP 

be m

Future MAP = Prior MAP 

be m

Future MAP = Prior MAP 

be m

Future MAP = Prior MA

physical change or chang

The emission unit will 

Future MAP < Prior MAP 

shu

Future MAP Prior Actual (avg 06-07) 

Prior MAP

C1 - 1
Part 231-2 MAP Analysis

Existing P-OT001 Old East Plant Soderberg Potline Units Values PRIOR EAST PLANT ACTUAL NOX EMISSIONS C

Potential Aluminum Production tons 135,583 assumed to be the maximum production based on process limiting factors upstream in the process Year

Total East Plant 

Emissions

Max (99 

TPY Cap)

D

Potential Aluminum Production lbs 271,166,000 2006 (lb/yr) 223,609 198,000 

2007 (lb/yr) 247,720 198,000 06-07 avg (lb/yr) 235,665 198,000 06-07 avg (ton/yr) 118 99 

(1) Calculated using annual production and 2008 emis

NOX 1.370 93% (2) Final Potroom emissions = Delta + (Initial potroom 

*Based on Method 7E Stack Testing in 2008-Method 25A stack testing of the Coke Injected Scrubber in 1997

PRIOR MAP NOx Fuel Usage 2006 2007 

Propane 55.661 69.2021 

lb/TAP lb/yr lb/TAP lb/yr lb/TAP lb/yr ton/yr

NOX 1.274 172,746 0.096 13,002 1.37 185,749 92.9 1998 AP-42 Emission FactorsEquations PropanePrimary Emissions (lb/yr) = (Generation Rate)(Production)(Capture Efficiency) Pollutant (lb/1000 gal)Roof Monitor Emissions (lb/yr) = (Generation Rate)(Production)(1 - Capture Efficiency) VOC 0.5

Prior MAP COS PRIOR EAST PLANT ACTUAL VOC AND COS EM

Year VOC (propane)* VOC** 

Parameter Value Rationale for Values 2006 (lb/yr) 28 235,776 

Coke Content (% by wt) 76.00% Given-conservative estimate based on previous years data 2007 (lb/yr) 35 235,776 

Coke Sulfur (by wt) 0.0300 Given 06-07 avg (lb/yr) 31 235,776 

Pitch Content (% by wt) 24.00% Given-conservative estimate based on previous years data 06-07 avg (ton/yr) 0 118 

Pitch Sulfur Content (by wt.) 0.0080 Highest Pitch Sulfur content of any month from 2001-2007 *emissions from propane combustion

S Generation Rate (lb S/lb paste) 0.0247 (% coke content*% S in coke)+(% pitch content*% S in pitch) **Total potroom emissions not including propane com

lb COS/lb S 1.8735 = (1 mol COS/1 mol of S)(1 mol S/32.06 lb)(60.065 lb/ mol of COS)

COS Generation Rate (lb COS/lb paste) 0.0038 (lb COS/lb S)*S Gen. Rate*0.082 Testing at various Alcoa Smelters has determined that 8.2% of the Sulfur in the paste will evolve as COS

Briquettes Poured (lbs) 157,005,114 Al Production*0.579 57.9% of Aluminum produced - based on 2007 values

Potential Aluminum Production lbs 271,166,000 Given

Potential Aluminum Production (Tons) 135,583 Given - assumed to be the maximum production based on process limiting factors upstream in the process

COS Generation Rate (lb COS/Ton Al) 4.40 (lb COS/lb paste)*lbs Briquettes Poured/tons Al Production

Pot Capture Efficiency 93% Given

Control Efficiency SO2 96% Given

Overall Control SO2 90% pot capture efficiency*SO2 control efficiency

Control Efficiency COS 34% Given

Overall Control COS 31% overall SO2 efficiency*COS control efficiency

Primary Control (lb COS/ton Al) 2.69 (lb COS/ton Al)*capture efficiency*(1-COS control efficiency)

Primary Control (lb COS) 364,874 tons Al Production*primary control

Roof Vent (lb COS/ton Al) 0.31 Roof vent/tons Al Production

Roof Vent (lb COS) 41,738 tons Al Production*(lb COS/tons Al)*(1-capture efficiency)

Total COS (lb/yr) 406,612 roof vent (lb COS) +primary control (lb COS)

Total COS (ton/yr) 203.3

Prior MAP VOC Given Given

Pollutant Run 1 Run 2 Run 3 Avg Pollutant

Conc. 

Effluent 

Gas*

South 

Scrubber 

Flow

North 

Scrubber 

Flow

South 

Scrubber North Scrubber Roof Vents** Plant Total

E

PPB PPB PPB PPM Molecular Wt. mg/M^3 M^3/min M^3/min lb/hr lb/hr lb/hr lb/hr 

Propane 180 190 210 0.19 44.0962 0.355 25,940 28,874 1.217 1.354 0.194 2.76 

Ethane 970 990 1100 1.02 30.0694 1.276 25,940 28,874 4.378 4.873 0.696 9.95 

Methane 17000 18000 19000 18.00 16.0426 12.012 25,940 28,874 41.216 45.878 6.555 93.65 

*converted ppmv using M.W. and a 24.04 L/gmol value**back calculated based on 93% capture efficiencyPollutant Run 1 Run 2 Run 3 Avg

Conc. 

Effluent 

Gas

South 

Scrubber 

Flow

North 

Scrubber 

Flow

South 

Scrubber North Scrubber Roof Vents Plant Total

E

PPM PPM PPM PPM mg/M^3 M^3/min M^3/min lb/hr lb/hr lb/hr lb/hr 

THC 25.82 24.6 24.84 25.09 16.74 25,940 28,874 57.440 63.936 9.136 130.51 1

Notes: On January 8th 2002,three summa can samples were collected at the fume system and analyzed by GC/MS VOC = THC + Propane - (Methane + Ethane) Calculations assume no control in the fume system and a 93% capture efficiency.

VOC = 259,996 lb/yr

= Input to Part 231-2 MAP Analysis Summary Table VOC = 130.0 ton/yr

Roof Monitor Emissions Total Emissions

Emission Factor

COS MAP Emissions Calculations

Pollutant

Generation 

Rate* (lb/TAP)

Capture 

Efficiency

NOX MAP Emissions Calculations

Primary Emissions

C1 - 2
Part 231-2 MAP Analysis

Future P-OT001

New East Plant Pre-Bake Potline (modeled after West Plant Pre-Bake Potline)

Units Values

Potential Aluminum Production tons 160,040 maximum production based on process limiting factors

Potential Aluminum Production lbs 320,080,340

Future MAP NOx

NOx MAP Emissions Calculations Units Values

Emission Factor lb/ton 0.599 2008 stack test data on West Plant Pre-Bake Potline

98% through A-398's lb/yr 94,426

2% through monitor lb/yr 1,438MAP NOx Emissions lb NOx/yr 95,864 Potential Al Production * emission factor

MAP NOx Emissions ton NOx/yr 47.9

Future MAP VOC (COS)

COS MAP Emissions Calculations Units Values Rationale for Calculations% Sulfur in Coke 3.0% Given

%S in Baked Anodes 2.76% % S in coke * (maximum ratio of anode sulfur to coke sulfur from 1974-2Pots Operating No. 208 GivenNet Carbon lb carbon/lb Al 0.419 Highest averaging year for net carbon between 06-07 (2006)% S converted to SO2 90.8% Given% S converted to COS 9.2% GivenTotal COS: lb/ton 3.98 % S in baked anodes*2000*(60/32)*net carbon*% S converted to COS% Fume Capture 98.5% Given98.5% through A-398's lb/yr 628,105 total COS (lb COS) * % Fume Capture1.5% through monitor lb/yr 9,565 total COS (lb COS)*(1-% Fume Capture)COS Control 25% GivenTotal COS: lb COS 637,670 total COS(lb/ton)*potential Al production (tons)Total Emitted COS: lb COS 480,643 98% through A-398's + 2% through monitor * (1-COS control)Total Emitted COS: ton COS 240.3

YEAR % S in Coke % S in Anode

1986* 1.97 1.81

*used year with highest ratio of anode sulfur to coke sulfur in calculations to remain conservative

Not Included in Source Project

Ratio of Anode Sulfur to 

Coke Sulfur

0.92

Decrease in MAP

C1 - 3
Part 231-2 MAP Analysis

A-00001 MAP PRIOR MAP NOx and VOC (Combustion Emissions) Homogenizing Furnaces, Preheat Furnaces and Heat/Treat Furnaces Emission Factors

Fuel Number Max. Fuel Usage Maximum Fuel Type Heat Input NOx

Process Description Type of of Each Burner Fuel Usage Nox VOC (MMBtu/hr) 

ID Burners (Mscf/hr) (Mscf/hr) (lb/yr) (lb/yr) Natural Gas <100 100 

Round Ingot

Natural Gas (low 

NOx burners) <100 50 

(1) AP-42, Fifth Edition and Supplements (7/98), Table 1.4-1 

Homogenizing Furnaces (2) AP-42, Fifth Edition & Supplements (7/98), Table 1.4-3,

HMO Homogenizing Furnace (#16 Homogenizing Heat Treat) N. Gas 6 5.1 30.6 26,806 1,474 VOC as non-methane total organic compounds (NMTOC)HMO Homogenizing Furnace (#17 Homogenizing Heat Treat) N. Gas 7 5.1 35.7 31,273 1,720HMO Homogenizing Furnace (#18 Homogenizing Heat Treat) N. Gas 8 4.3 34.3 30,022 1,651 DescriptionHMO Homogenizing Furnace (#19 Homogenizing Heat Treat)(2) N. Gas 6 5.1 30.6 21,024 1,474 1999 Permit Application ERP(3)

Total Homogenizing Furnaces: 100.6 109,125 6,320 or 

Preheat Furnaces (3)Emission factor based on vender guarantee and used in emissio

homogenizing furnace #19 and all new homogenizing furnaces mo

EPH 6500 Ton Press Preheat N. Gas many 20.4 20.4 17,870 983EPH 5300 Ton Press Preheat (NOx testing, max of 0.174 lb NOx/hr) N. Gas many 19.8 19.8 17,334 953EPH 1500 Ton Press Preheat N. Gas many 1.5 1.5 1,340 74

Total Preheat Furnaces: 41.7 36,545 2,010 PRIOR MAP VOC (Process Emissions)

Heat Treat Furnaces Heat Treat Furnaces

HT1 #37 Furnace Coils in Wax (fugitive) N. Gas 2 1.84 32,167 3,217 177 Process Description 

HT1 Contl Atmos Furn #32,33,34,35,36 N. Gas 150 0.21 269,396 26,940 1,482 (lbs/HT2 Age Anneal Furnace N. Gas 4 0.97 HT1 #37 Furnace Coils in Wax (fugitive) 0.1

N. Gas 4 2.67 HT1 Contl Atmos Furn #32,33,34,35,36(1) 0.05

127,523 12,752 701 HT2 Age Anneal Furnace #23, 24 0.0

HT2 56' Heat Treat #13, 14 15(1) N. Gas 36 0.36 HT2 Comb. Exhaust, 56' Heat Treats

N. Gas 48 0.36 HT2 Comb. Exhaust, 56' Heat Treats

267,949 15,155 1,474 HT2 56' Heat Treat #13, 14 15(2) 0.8

HT2 56' Heat Treat #16, 17, 18 N. Gas 84 0.36 267,949 15,155 1,474 HT2 56' Heat Treat #16, 17, 18(2) 0.8HT1 Heat Treat Furnace (#30,31) Electric N/A N/A N/A - - HT1 Heat Treat Furnace (#30,#31) 0.1HT1 Heat Treat/Artificial Age Furnace #38 Electric N/A N/A N/A - - HT1 Heat Treat/Artificial Age Furnace #38 0.0

Total HT1: 301,563 30,156 1,659 Total HT1 0.5 Total HT2: 663,421 43,062 3,649 Total HT2 1.7 

Total (ton/yr) 109 7 GRAND TOTAL: 2.2 

(1)NOx emission factor is based on source specific stack test data from #16 Homo furnace (1.73 lbs/hr) (2)1999 permit application ERP for NOx was used for furnace #19.

Future MAP NOx and VOC (Combustion Emissions) (1)Based on September 1994 stack test results of the 33/35 Contro

Homogenizing Furnaces, Preheat Furnaces and Heat/Treat Furnaces (2)Based on September 1994 stack test results of the 56' Heat Trea

Fuel Number Max. Fuel Usage Maximum

Process Description Type of of Each Burner Fuel Usage Nox VOC

ID Burners (Mscf/hr) (Mscf/hr) (lb/yr) (lb/yr) FUTURE MAP VOC (Process Emissions)

Round Ingot Heat Treat FurnacesHomogenizing Furnaces Process Description 

HMO Homogenizing Furnace (#19 Homogenizing Heat Treat)(3) N. Gas 6 5.1 30.6 21,024 1,474 (lbs/

Preheat Furnaces HT1 #37 Furnace Coils in Wax (fugitive) (1) 0.1

HT1 Contl Atmos Furn #32,33,34,35,36(1) 0.05

EPH 6500 Ton Press Preheat N. Gas many 20.4 20.4 17,870 983 HT2 Age Anneal Furnace #23, 24(1) 0.0

EPH 5300 Ton Press Preheat (NOx testing, max of 0.174 lb NOx/hr) N. Gas many 19.8 19.8 17,334 953 HT2 Comb. Exhaust, 56' Heat TreatsEPH 1500 Ton Press Preheat N. Gas many 1.5 1.5 1,340 74 HT2 Comb. Exhaust, 56' Heat Treats

Total Preheat Furnaces: 41.7 36,545 2,010 HT2 56' Heat Treat #13, 14 15(2) 0.8

Heat Treat Furnaces HT2 56' Heat Treat #16, 17, 18(2) 0.8

HT1 Heat Treat Furnace (#30,#31)(1) 0.1

HT1 #37 Furnace Coils in Wax (fugitive) N. Gas 2 1.84 32,167 3,217 177 HT1 Heat Treat/Artificial Age Furnace #38(1) 0.0HT1 Contl Atmos Furn #32,33,34,35,36 N. Gas 150 0.21 269,396 26,940 1,482 Total HT1 0.5 HT2 Age Anneal Furnace N. Gas 4 0.97 Total HT2 1.7 

N. Gas 4 2.67 GRAND TOTAL: 2.2 

127,523 12,752 701 

HT2 56' Heat Treat #13, 14 15(2) N. Gas 36 0.36

N. Gas 48 0.36 (1)Based on September 1994 method 18 stack test results

267,949 15,155 1,474 (2)Based on 1997 test report

HT2 56' Heat Treat #16, 17, 18 N. Gas 84 0.36 267,949 15,155 1,474HT1 Heat Treat Furnace (#30,31) Electric N/A N/A N/A - -HT1 Heat Treat/Artificial Age Furnace #38 Electric N/A N/A N/A - - Unit is NOT included in Source Project

Total HT1: 301,563 30,156 1,659Total HT2: 663,421 43,062 3,649

(1)Two new furnaces will be added identical to #19 and five new furnaces will be added identical to #18 Total (ton/yr) 65 4(2)NOx emission factor is based on source specific stack test data from #16 Homo furnace (1.73 lbs/hr)(3)1999 permit application ERP for NOx was used for homogenizing furnace #19 and all new homogenizing furnaces.

Decrease in MAP

C1 - 4
Part 231-2 MAP Analysis

A-00001 Prior Actual

Emission Unit A-00001Furnaces to be removed as part of the project (emissions used in the netting analysis)

Emission Factors

Existing Homogenizing Furnaces MMBTU/hr(1) MMCF/yr Fuel Type Heat Input NOx(1) 

#16 Homogenizing Heat Treat 30.0 262.8 (MMBtu/hr) lb/MM#17 Homogenizing Heat Treat 35.0 306.6 Natural Gas <100 50 #18 Homogenizing Heat Treat 33.6 294.3 Natural Gas <100 100 

(1) MMBTU values are based on Alcoa information

(1) AP-42, Fifth Edition and Supplements (7/98), Table 1.4(2) AP-42, Fifth Edition & Supplements (7/98), Table 1.4-3

 VOC as non-methane total organic compounds (NMTO

MMBTU 8760 HR 1 MMCF = HR 1 YR 1000 MMBTU 

16 Homo 18 Homo

Loads Time (hrs) % Utiliz'n Loads Time (hrs) % Utiliz'n

2006 268 6515.9 74.6 469 8186.6 93.72007 204 5481.5 62.7 438 7691.4 88

Existing Furnace POC Emissions NOx NMTOC#16

2006 (lb/yr) 19,605 1,078 =(MMCF/yr)*emission factor*%Utiliz'n2007 (lb/yr) 16,478 906 =(MMCF/yr)*emission factor*%Utiliz'n

#17 (Idle since 2002)

2006 (lb/yr) 0 02007 (lb/yr) 0 0

#18

2006 (lb/yr) 27,579 1,517 =(MMCF/yr)*emission factor*%Utiliz'n2007 (lb/yr) 25,902 1,425 =(MMCF/yr)*emission factor*%Utiliz'n

06-07 Avg (lb/yr) 44,782 2,463

06-07 Avg (ton/yr) 22.4 1.2

HMO furnace utilization

C1 - 5
Part 231-2 MAP Analysis

A-00003 MAP

Future MAP NOx and VOC (Combustion Emissions)

Homogenizing Furnaces, Melting/Holding Furnaces and Gas Fired Filterbox Fluxing Units Emission Factors

Fuel Number Max. Fuel Usage Maximum Fuel Type Heat Input NOx(1) VOC(2)

Process Description Type of of Each Burner Fuel Usage Nox VOC (MMBtu/hr) lb/MMscf

ID Burners (Mscf/hr) (Mscf/hr) (lb/yr) (lb/yr) Natural Gas <100 100 5.5

Round Ingot

Natural Gas 

(low NOx <100 50 5.5

(1) AP-42, Fifth Edition and Supplements (7/98), Table 1.4-1 

Homogenizing Furnaces (2) AP-42, Fifth Edition & Supplements (7/98), Table 1.4-3,

HM1 Homogenizing Furnace (#19 Homogenizing Heat Treat) (1) (2) N. Gas 6 5.1 30.6 VOC as non-methane total organic compounds (NMTOC)

HM1 Homogenizing Furnace (#19 Homogenizing Heat Treat)(1) (2) N. Gas 6 5.1 30.6HM1 Homogenizing Furnace (#18 Homogenizing Heat Treat) (1) (2) N. Gas 8 4.3 34.3 Description

HM1 Homogenizing Furnace (#18 Homogenizing Heat Treat) (1) (2) N. Gas 8 4.3 34.3 1999 Permit Application ERP(3)

HM1 Homogenizing Furnace (#18 Homogenizing Heat Treat) (1) (2) N. Gas 8 4.3 34.3 or 0.08 lb/MMBTU

HM1 Homogenizing Furnace (#18 Homogenizing Heat Treat) (1) (2) N. Gas 8 4.3 34.3 (3)Emission factor based on vender guarantee and used in emissions calc

HM1 Homogenizing Furnace (#18 Homogenizing Heat Treat) (1) (2) N. Gas 8 4.3 34.3 homogenizing furnace #19 and all new homogenizing furnaces modeled a

New Homogenizing Furnaces (capped fuel usage): 119,952 8,085

Total (ton/yr) 60 4.04 Three New Melting/Holding Furnaces at West Plant with Natural Gas 

Melting/Holding Furnaces Two sizes: Two 240,000 pound units and one 180,000 pound unit

MH1 Melting/Holding Furnace N. Gas 53.9 240,000 lb Un

MH1 Melting/Holding Furnace N. Gas 53.9 Max Heat Input (MMBTU/hr) 55 MH1 Melting/Holding Furnace N. Gas 44.1 Max Fuel Use Capacity (MMCF/yr) 472.35 

New Melting/Holding Furnaces (capped fuel usage): 48,000 5,280 Charge Size (lbs) 200,000 

Total (ton/yr) 24 2.64 Charges Per Day 2 

Filterboxes Days of Operation (/yr) 365 

FBB Melting/Holding Furnace N. Gas 6 0.1 0.6 263 29 Daily Capacity (lbs) 400,000 FBB Melting/Holding Furnace N. Gas 6 0.1 0.6 263 29 Annual Capacity (lbs) 146,000,00FBB Melting/Holding Furnace N. Gas 6 0.1 0.6 263 29 Annual Capacity (Tons) 73,000 

New Filterboxes: 788 87 Combustion Emissions for Three New Furnaces

Total (ton/yr) 0 0.04 NOx (low NOx burners) (lb/yr) 48,000 

NMTOC (lb/yr) 5,280 

(1)Two new furnaces will be added identical to #19 and five new furnaces will be added identical to #18 NOx (low NOx burners) (ton/yr) 24(2)1999 permit application ERP for NOx was used for homogenizing furnace #19 and all new homogenizing furnaces. NMTOC (ton/yr) 3

Maximum Fuel Usage Capacity for new HM1 Furnaces: 2037 MMCF/yr Maximum Fuel Usage Capacity for new MH1 Furnaces: 1331 MMCF/yr

Desired Cap on Fuel Usage for new HM1 furnaces: 1470 MMCF/yr Desired Cap on Fuel Usage for new MH1 furnaces: 960 MMCF/yr

0.08 lbs NOx 1020 MMBtu 81.6 lbs NOx 50 lbs NOx 960 MMCF 

MMBtu MMCF MMCF MMCF yr 

81.6 lbs NOx 1470 MMCF 119,952 lbs NOx 48,000 lbs NOx ton 

MMCF yr yr yr 2000 lbs 

119,952 lbs NOx ton 60 tons NOx

yr 2000 lbs yr

Unit is included in Source Project

==

NOx

Increase in MAP

2.4

(lb/hr)

===

C1 - 6
Part 231-2 MAP Analysis

B-00001

West Plant Boilerhouse

Natural Gas No. 6 Fuel Oil Natural Gas No. 6 Fuel Oil

Pollutant (lb/106 ft3) (lb/ 1000 gal) Pollutant (lb/MMbtu) (lb/MMBtu)

Volatile Organic Compounds 5.5 0.76 Nitrogen Oxides 0.08 0.27

Emission factors from method 7E emissions testing in 2006Natural Gas assumes - 1,000 Btu/cfNo.6 Fuel Oil assumes - 150,000 Btu/galEmission factors from 2006 emission testing

Boiler Maximum Heat Input:Fuel Oil 640 MMBTU/hrNatural Gas 800 MMBTU/hr

Prior and Future NOx MAP

#6 Fuel Oil 640 MMBTU 8760 HR 0.27 lb Nox 1,513,728 lb Nox 757 

HR 1 YR 1 MMBTU YR 

Natural Gas 800 MMBTU 8760 HR 0.08 lb Nox 560,640 lb Nox 280 

HR 1 YR 1 MMBTU YR 

Prior and Future VOC MAP

#6 Fuel Oil 640 MMBTU 8760 HR 10 gallons 1 1000 gallons 0.76 lb VOC 

HR 1 YR 1.5 MMBTU 1000 gallons 1 1000 gallons 

Natural Gas 800 MMBTU 8760 HR 1 MMCF 5.5 lb VOC 38,544 lb VOC 

HR 1 YR 1000 MMBTU 1 MMCF YR 

Not Included in Source Project

No Change

==

=

1998 AP-42 Fuel Emission Factors 2006 Boiler Tested Emission Factors

=

=

=

C1 - 7
Part 231-2 MAP Analysis

S-00001 MAP

West Plant Pre-Bake Potline

Future MAP

Units Values

Potential Aluminum Production tons 149,298 maximum production based on process limiting factors upstream 

Potential Aluminum Production lbs 298,596,000

NOx MAP Emissions Calculations Units Values

Emission Factor lb/ton 0.599 2008 stack test data, Method 7E

through A-398's lb/yr 87,641

through monitor lb/yr 1,789MAP NOX Emissions lb Nox/yr 89,430 Potential Al Production * emission factor

MAP NOX Emissions ton Nox/yr 45

COS MAP Emissions Calculations Units Value Rationale for Calculations% Sulfur in Coke 2.5% Given

%S in Baked Anodes 2.30% % S in coke * (maximum ratio of anode sulfur to coke sulfur from Pots Operating No. 198 GivenNet Carbon lb carbon/lb Al 0.419 Highest averaging year for net carbon between 06-07 (2006)% S converted to SO2 90.8% Given% S converted to COS 9.2% GivenTotal COS: lb/ton 3.32 % S in baked anodes*2000*(60/32)*net carbon*% S converted to % Fume Capture 98.0% Given98% through A-398's lb/yr 485,809 total COS (lb COS) * % Fume Capture2% through monitor lb/yr 9,914 total COS (lb COS)*(1-% fume capture)COS Control 0% GivenTotal COS: lb COS 495,723 total COS(lb/ton)*potential Al production(tons)Total Emitted COS: lb COS 495,723 98% through A-398's + 2% through monitor * (1-COS control)Total Emitted COS: ton COS 248

YEAR % S in Coke % S in Anode

1986* 1.97 1.81

*used year with highest ratio of anode sulfur to coke sulfur in calculations to remain conservative

Ratio of Anode Sulfur to 

Coke Sulfur

0.92

No Change

Not Included in Source Project

C1 - 8
Part 231-2 MAP Analysis

S-00002

Anode Baking Furnace

Max West Plant Green Anode Production between 2003-2007 85,678 tons (2007)

Potential West Plant Green Anode Maximum Production 182,243 tons

Scaling Factor 2.13

182,243 tons/yr Green 178,345 Tons/yr Baked

Emission FactorsPollutant Value UnitsVOC 0.209 lb/ton Baked Carbon Based on Method 25A Stack Testing in June 2008 + 10% to accommodate worst-NOx 2.277 lb/ton Baked Carbon Based on Method 7E Stack Testing in June 2008 + 10% to accommodate worst-ca

Prior and Future MAP Anode Baking Furnace Emissions

Pollutant Value UnitsVOC 37,274 lbs/yr =emission factor*potential west plant baked anode maximum productionNOx 406,091 lbs/yr =emission factor*potential west plant baked anode maximum production

VOC 18.6 tons/yrNOx 203.0 tons/yr

No Change

Not Included in Source Project

*Assume 98% conversion of green anode to baked anode based on 2006/2007 data

C1 - 9
Part 231-2 MAP Analysis

S-00003

Green Mill06-07 Average Green Anode Production

84,767 tons/yr

Potential West Plant Green Anode Maximum Production

182,243 tons/yr

VOC 0.0231 lb/ton Green Carbon -Method 25A stack testing of the Coke Injected Scrubber in 199706-07 Average Prior Actual Green Mill (Paste Production Plant w/ Coke Scrubber) EmissionsVOC 1,958 lbs/yr =current emission factor*06-07 average west plant green anode maximum productionVOC 1 ton/yrPrior MAP Green Mill (Paste Production Plant w/ Coke Scrubber) EmissionsVOC 4,210 lbs/yr =current emission factor*potential west plant green anode maximum productionVOC 2 ton/yr

1.333333 scaling factor for Green Mill emissions factors based on the addition of a fourth paste mixer

VOC 0.0308 lb/ton Green CarbonFuture MAP Green Mill (Paste Production Plant w/ Coke Scrubber) EmissionsVOC 5,613 lbs/yr =scaled emission factor*potential west plant green anode maximum productionVOC 3 ton/yr

Unit is Included in Source Project

Increase in MAP

Scaled Emission Factor

Current Emission Factor

C1 - 10
Part 231-2 MAP Analysis

S-00005

Pitch Unloading/StoragePotential West Plant Green Anode Maximum Production

182,243 tons/yr

Emission Factors

VOC

Description

(lb/hr)

Pitch Unloading 0.320Pitch Storage(1) 0.128

(1) Derived from 1994 stack test data (pre control). Assume that all particulate organics are condensed and that 90% gaseous organ

Potential Hours of Operation

8760 hrs

Unit S-00005, Process PUN Pitch Unloading MAP EmissionsVOC 5,606 lbs/yr =emission factor*8760 hrs/yr*2 emission sourcesVOC 3 ton/yrUnit S-00005, Process PST Pitch Storage MAP EmissionsVOC 2,243 lbs/yr =emission factor*8760 hrs/yr*2 emission sourcesVOC 1 ton/yrUnit S-00005 Total MAP EmissionsVOC 7,849 lbs/yrVOC 4 ton/yr

Not Included in Source Project

No Change

C1 - 11